Privacy Policy

Last Updated: April 2, 2024

The Tinybeans Promise

Giving families peace of mind is at the heart of everything we do at Tinybeans and so we wanted to share our commitment to you and your family:

  • You own your memories (photos and videos) at all times.
  • You control who can access your memories.
  • We will never share your personal information except as set forth in this Privacy Policy.

Welcome to the Tinybeans App and Tinybeans.com website (collectively referred to as the ‘Service’). The Service is provided to you by Tinybeans USA Ltd. or our affiliates, which also includes Red Tricycle – http://www.redtri.com (referred to herein as ‘we’, ‘us’, ‘our’, ‘Tinybeans’). This policy provides you with details on the information we collect from you and the uses we make of your information. If you do not want us accessing and/or using your Personal Information as described herein, please do not provide us with any.

This policy may be updated from time to time, so please check back periodically. We will notify you about significant changes in the way we treat Personal Information by placing a prominent notice on the Service or as may be required by law, so that you can choose whether to continue using it. If you continue to use or access the Service made available to you after such changes have been made, you hereby provide your consent to the changes.​

We encourage you to read this policy to learn more about what information of yours we collect, how we use it, and how you can ‘opt-out’ of certain communications and uses of your information. Additionally, this policy includes information about how we endeavor to protect your information. If you have any questions about our collection and use of your information, please contact us at info@tinybeans.com.

If you are a resident of California, please see the section titled “Information, Notices, and Rights Applicable To California Residents Only” for specific disclosures with respect to our collection, use, and disclosure of your information and additional rights you have under applicable California law. If you are located in the European Union (EU) or European Economic Area (EEA), please see the section entitled “EU Residents Rights and Disclosures” for specific disclosures with respect to our collection, use, and disclosure of your information and additional rights that you have under applicable law.

1. Information Collection

Unless otherwise indicated, for purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. 

(a) Information We Collect Directly From You. When you create an account for our Service, we may collect information that specifically identifies you, including without limitation your name, address, phone number, date of birth, gender, photos, credit card information, or e-mail address and other such Personal Information that you choose to provide us. Additionally, we may collect certain data associated with your photos, including location, depth information, captions, and audio. We do not collect any Personal Information unless you voluntarily share that information with us. For example, you may choose to send us Personal Information about yourself in an email, when registering for the Service or uploading content to the Service, by completing an online contact request form on the Service, or by purchasing a product or subscribing to the Tinybeans free or paid subscription products. We use this information to contact you to respond to your inquiry and as otherwise permitted by this policy. If you contact us, we may keep a record of that correspondence. You may also choose to, in a manner consistent with our Terms and Conditions, share information about your children or other family members including the name, birthdate, gender, weight, height, personal milestones, and other such information about those persons. When you choose to share your Personal Information or the Personal Information of your family members with other users of the Service (e.g., by inviting your friends, family members (either manually or through sharing access to your Contact List), or other users to see and interact with your albums etc.), you agree that they may view or otherwise access the Personal Information that you share with them and acknowledge that we cannot control and/or be liable for how they may use that information.

(b) Information We Automatically Collect. Our Service may collect certain information that does not specifically identify you, including without limitation clickstream data as described in Section 5, IP type, IP host address, ISP address, cookie IDs and segment IDs associated with cookie IDs, pages viewed and/or search terms entered, browser type, operating system, duration and frequency of visits, anonymous usage statistics including frequency of messaging and interaction with other users, clickstream data, other log file data, or social analytics and tracking measurements that do not identify any individual. We may also collect device type, make and model, operating system, carrier, user ID, similar device IDs, and information about the Services you use. Please note that we may use third parties to help operate and provide services in connection with our Service and these third parties may collect this information through our Service as well. To be clear, some types of information we automatically collect (including, for example, your IP address and certain unique device identifiers or cookie IDs), may be specific to a particular computer or device, and may be considered “personal data” or “personal information” as specifically defined in some jurisdictions. 

(c) Partnerships and Influencers. If you participate in our Partnerships & Influencers program as an influencer or an affiliate, we may collect Personal Information, including your email address, tax and banking information, and any other information required by our service providers. 

(d) Tinybeans Investors. When you register to invest or become shareholder in Tinybeans through the Interactive Investor Hub, we may collect certain Personal Information through Tinybeans and the Automic Registries Investor Portal. This may include your first and last names, email address, s708 / ASFL certificate, HIN/SRN, and survey responses. 

2. Information Usage

We may use your information to provide and improve the Service and to fulfill any other purpose for which you provide your information, to contact and correspond with you, as well as for our to prevent or address service, security, technical issues in connection with customer support matters, to verify your identity and, if applicable, authorization for you to use the Service, to provide you with notices about your account, to notify you about changes to our Services or any products or services we offer or provide through it, other business purposes such as to carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including our Terms and Conditions), adding you to our marketing lists, and for internal research for technological development and demonstration. We may also share or permit our vendors and subcontractors to access your information to help us provide the Service to you including payment processors, email providers, host providers, your credit card issuer, a third-party credit verification company, the product handler and the delivery service, data storage facilities, and other companies that help us provide the Service.

WE WILL NOT SELL, SHARE OR TRADE THE PERSONAL INFORMATION YOU SUBMIT TO ANY UNRELATED THIRD PARTIES, MASS MARKETERS, OR TO OTHER NON-AFFILIATED ENTITIES FOR THEIR MARKETING PURPOSES WITHOUT YOUR CONSENT. Your Personal Information will not be visible to other users of the Service unless you provide them with access to it. We may disclose your information, including your Personal Information, to service providers who are providing services on our behalf, as well as when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, or to enforce our legal rights, including but not limited to, fraud and situations involving potential threats to the safety of any person or property. In the event another company acquires all or most of our assets, all data compiled or owned by us may be among the items transferred in that transaction. In such event, all the information will continue to be governed by this  policy. Finally, please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in manner consistent with that consent.

We may, to the extent permitted by applicable law, collect or create information that is not Personal Information such as sets of aggregate data and other generalized information, including information about browsing, usage and interactions and de-identified personal information that does not reveal your identity. We retain the right to use and disclose such aggregated or anonymous information in any manner permitted by law. Notwithstanding anything to the contrary herein, Tinybeans may use automated processes and machine learning to analyze User Content, User Submissions, Feedback and Responses (as defined below), which helps us to aggregate response data and activity, identify trends, build product features that optimize responses, make product recommendations and provide guidance on which content, products and services work best in different scenarios.

Tinybeans may use any reports, comments, ratings, reviews and suggestions in any form regarding the Services that you provide (collectively the “Feedback”) and/or any responses to surveys, inquiries or questionnaires that you provide (collectively, the “Responses”). You grant Tinybeans a worldwide, non-exclusive, irrevocable, perpetual, royalty-free right and license to incorporate and use the Feedback and Responses. We use Feedback and Responses on an aggregated and anonymized basis. We will never sell individual Feedback or Response data or identify / contact individual respondents except on your request or where required by law. You agree that Tinybeans may use and share your Feedback and Responses in accordance with this policy and applicable data protection laws.

3. Cookies and Similar Technologies

A ‘cookie’ is a small amount of data sent to your browser from a web server and stored by your computer. 

We, our business partners and advertisers may use cookies (or clear gifs, web beacons or similar devices, including devices that function in the mobile environment and in emails) to collect information from users for purposes such as tracking Service visits and to measure visitor patterns or to determine whether an email and its contents have been viewed. 

This information is also used to improve the Service and enhance your experience. For example, we may use the information to provide you with services that are easy to use, enable you to move around the Service and use its features, such as accessing secure areas, and store information or preferences so that we can respond faster. Cookies are not used to retrieve Personal Information from your computer or device, or to retrieve other information from your computer or device for purposes that are unrelated to the Service or your interaction with the Service. We reserve the right to disclose or utilize any of this information in aggregate form, for any purpose permitted by law, in our sole judgment. Third party advertisers that serve ads on the Service may also use their own cookies. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. To learn about cookies in general you may visit https://www.allaboutcookies.org. Note that this may cause some features of the Service to work incorrectly. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, applications users may opt out of certain mobile tracking activities via their device settings.

Examples of cookies we use:

Analytics Cookies. We may also use and place cookies on your device from our third party service providers in connection with the website, such as an analytics provider that helps us manage and analyze website usage. For example, we use Google Analytics to understand how visitors interact with our Service. The type of information Google collects include pages visited, videos viewed, etc. This information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. For more information learn how Google uses data when you visit their partners’ sites or apps. You can opt out of Google Analytics on most browsers through the mechanisms made available by Google here. We also use the Facebook Pixel, which you can disable by following the instructions here.  For more information on Meta’s privacy practices, please read Meta’s Privacy Policy. Information on how to adjust your ad settings can be found here.

Session Cookies. We use session ID cookies and persistent cookies. Our persistent cookie remains active on your hard drive until they expire or are deleted.  A session ID cookie expires when you close your browser. These cookies collect and record your activities and movements across the Services throughout your browsing session and across different time sessions including to track button clicks such as interactions with pop-in campaigns, mouse movements, scrolling, resizing, touches, keystrokes, data entered, device information and orientation, browser visual elements, and screen size (“Session Data”), for purposes of our own internal analytics and improving the Service. We may share Session Data with our third-party analytics or service providers, which may change from time-to-time, for these purposes, who will use the Session Data solely on our behalf and for our benefit. 

4. Interest Based Advertising

Advertisements for our products and Service may appear on third-party websites around the Internet. Some websites and services deliver these advertisements based upon data that has been previously collected about your past behavior online. For example, if you have viewed websites about parenting, these websites or services may display to you an advertisement for our Service. This kind of targeted advertising is sometimes called interest-based, online behavioral advertising, or cross-context behavioral advertising. 

We do not control such third-party websites or services on which these advertisements appear. Further, we do not control how they collect and use data about your online activities. However, you may opt-out of being tracked online by certain companies by visiting http://www.aboutads.info/choices/ and http://www.networkadvertising.org/managing/opt_out.asp. If you opt-out, you will still receive advertisements, but they will not be delivered to you based upon your behavioral data possessed by the companies from whom you have opted-out. This process relies upon an opt-out cookie, so if you delete your cookies or use a different computer, you will have to repeat this process.

This Service is affiliated with Publisher First, dba Freestar (“Freestar”) for the purposes of placing advertising on the Service, and Freestar will collect and use certain data for advertising purposes. To learn more about Freestar’s data usage, click here.

5. Clickstream

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. We collect clickstream data using Session Cookies. For more information on our use of cookies including Session Cookies, please review Section 3. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Service. We may collect and/or use clickstream data to create aggregated data and determine how much time visitors spend on each page of the Service, how visitors navigate throughout the Service, and how the Service may be better tailored to meet the needs of visitors. This information will be used to improve the Service. 

6. Security

We have undertaken and will undertake commercially reasonable security procedures and practices appropriate to the nature of the Personal Information to prevent unauthorized Internet access to user data retained in our servers. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we adhere to industry standard practices and procedures to help safeguard and secure the information we collect. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online, and you assume this risk by using the Service. We may aggregate Personal Information and retain it for analytical purposes. We may retain your Personal Information, if provided by you through the Service, for as long as your inquiry and/or account is active (as determined by us) and for a reasonable time thereafter, or if applicable, for as long as you remain on our marketing list. We also may retain your Personal Information for a longer period of time as needed to provide you services or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate, anonymous data previously collected and/or anonymize and aggregate your Personal Information. To the fullest extent permitted by law, please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties, including third party host providers. For more information on how long we retain your Personal Information, please review Section 16. 

The Service or advertisements we may place may contain links to other websites or applications. Other websites or applications may also reference or link to our Service. Some of our third-party website or technology partners may place their own cookies and/or other data collection tools on your Internet browser. These other domains, websites and/or services are not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk

Our Service may also contain links to social media platforms, and you may be given the choice of connecting to one or more social media platforms from this Service. If you choose to do so, then depending upon your social media privacy settings, the Personal Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by others and we will have no control over such viewing and use. We do not control and are not responsible for any use of your information by or through any of the social media platforms. By linking to any social media platform, you will be assuming the risk that the information you provide on that platform may be viewed and/or used by third parties for any purposes and agree that we have no control or responsibility for such third party viewing and uses.

8. Information Relating to Children

We allow you to provide information and post about your children, including your children’s birthday, photos, audio recordings, videos, and any other information you choose to share on the Service. However, our Service is designed for those 18 years of age and older. This Service is not intended for, and we do not knowingly collect information from anyone under the age of 18. If we are made aware that we have received such information from anyone under the age of 18, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

9. Policy Modifications

We reserve the right, at our discretion, to modify, add, or remove portions from this policy at any time. However, if at any time in the future we plan to use any data in a way that materially differs from this policy, we will post such changes here. We encourage you to periodically review the Service for the latest information on our privacy practices.

10. Terms and Conditions


Use of this Service is governed by, and subject to, the legal notices contained at the Terms and Conditions available here. Your use, or access, of the Service constitutes your agreement to be bound by these provisions.

11. Opt-Out of Tinybeans Emails

By providing your email address to us, you expressly consent to receive email from us. To the extent you have provided us with such contact information, we may contact you by email, telephone or otherwise to verify your account, and for informational, application functionality and operational purposes (provided that we will not give your email address or mobile number to another party to promote their products or services directly to you). If you receive an email from us, you may unsubscribe from future unsolicited emails through a link, typically at the bottom of the e-mail.

If you have consented to have your Personal Information shared with any third party who may use such information for direct marketing purposes and you no longer wish to have your Personal Information shared with such parties, then you may opt-out of such disclosures by sending an email to info@tinybeans.com. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this privacy policy or your separate consent.

On most devices, App users may opt out of mobile communications via their device settings. You may also stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. In addition, you may request that we delete your Personal Information by emailing your request to info@tinybeans.com and we will process your request within a reasonable time after receipt.

Please note that we do not respond to or honor ‘do not track’ (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. However, if you do not want to receive targeted advertisements, then you can opt-out of being tracked by our vendors. For more information about how to opt-out of such tracking, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices/ or similar sites. Opting out of interest-based advertising does not mean that you no longer will see any advertisements; rather, you will still see advertisements that are general and not tailored to your specific interests and activities.

Please note that there might be a brief delay between when you submit your request to ‘opt-out’ and when it is processed and reflected in our systems; accordingly you may continue to receive communications from us for a limited time after you unsubscribe. We appreciate your patience.

12. Data Access Rights Requests

We use reasonable processes to ensure compliance with this privacy policy and periodically verify that the policy is accurate. We encourage you to raise any concerns using the contact information provided below, and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information. You can help us maintain the accuracy of your information by notifying us of any changes to your Personal Information. If you are a resident of the California or Europe, please review the California Privacy Notice and European Privacy Notice below anduse the following information to exercise your rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at info@tinybeans.com.

Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.

If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity, and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the Personal Information that we already have.

How to submit a request. To exercise the rights described above, please submit a request to us by emailing us at info@tinybeans.com or by using the form available at  https://tinybeans.com/contact-us/

We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Depending on applicable law, you may be limited in how many verifiable or authenticated consumer requests you can make within a twelve (12) month period. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:

We cannot respond to your request or provide you with Personal Information if we cannot verify or authenticate your identity or authority to make the request and confirm that the Personal Information relates to you. You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use personal information provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request. If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

13. California Privacy Notice

California law provides California residents with specific rights regarding information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (some of which may also constitute personal information as defined in California Privacy Notice. The California Consumer Privacy Act of 2018 and its amendments in the California Privacy Rights Act of 2020 (“CCPA”) refers to such information as “personal information”. This section describes the rights that California Consumers have and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA as well as other relevant California laws and regulations. The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information, as well as rights to access, correct, delete, and restrict the sale, use, and disclosure of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA.

If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at info@tinybeans.com.

a. Information We Collect; How We Collect It; How We Use It

i. Personal Information We Collect

We may have collected the following categories of personal information about you over the last twelve (12) months:

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law. This may include:

The specific types of personal information we collect are further detailed in Sections 1-7 of this Privacy Policy. Personal information does not include information excluded from the scope of California privacy law.

ii. Sources of Personal Information

We may collect personal information about you from the following categories of sources:  

For example, we may collect your name, email address, from forms you complete on the Service. Identifiers that do not constitute personal iinformation (e.g., IP addresses, online identifiers) are collected indirectly from you through website technology, including web servers, cookies and similar tracking technology that interacts with your browser/device when you visit the Service. For example, we may collect your name, and payment card information from forms you complete on the Service. Commercial information is collected in connection with purchases you make from us (e.g., subscriptions). Internet or other similar network activity is collected indirectly from you through website technology, including web servers, cookies and similar tracking technology that interacts with your browser/device when you visit the Service. We also collect personal information from our vendors and subcontractors as well as third-party partners including social media networks and advertisers. We may supplement the information described above with information we obtain from other sources, including from both online and offline information providers.

iii. How We Use Your Personal Information

We use the personal information we collect about you for all of the purposes outlined in Sections 1 – 7 above.

We use the sensitive personal information we collect from you in Section 13(a)(i) only as necessary to facilitate your participation on the Service.

iv. To Whom We Disclose Personal Information

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this policy, for the operational purposes of our service providers and contractors, as well as to third parties in a manner consistent for other purposes compatible with the context in which the personal information was collected. This includes the business purposes described in Sections 1 – 7.

We may “sell” and/or “share”  personal information with third party partners as part of targeted advertising initiatives. That sharing may constitute a “sale” and/or “share” under California law, even though we do not receive monetary payment for sharing or disclosing personal information to these third parties.

In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal information:

b. Your California Privacy Rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information subject to applicable exceptions.

i. Right to Know About Personal Information Collected, Disclosed, or Sold

As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see, Section 13(d) below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following twice in a 12-month period:

ii. Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see, Section 13(d) below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we may retain personal information that has been de-identified or aggregated as described in Section 16. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

iii. Right to Correct

You have the right to request the correction of your inaccurate personal information. We may request additional information from you as necessary to complete your request. We will correct (and direct our service providers to correct) your personal information from our records, unless an exception applies subject to receiving and confirming your verifiable consumer request (see, Section 13(d) below).

iv. Right to Limit Use and Disclosure 

You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. As disclosed above, we currently only use your sensitive personal information for purposes necessary to facilitate your participation on the Service as described above in Section 13(a)(iii).

v. Notice of the Right to Opt Out of Sale/Sharing of Personal Information

You have the right to opt-out of the “sale” and/or “sharing” of your personal information by a business, as those terms are defined by California law. We “sell”/”share” certain of your personal information with our third-party advertising partners for purposes of cross-context behavioral advertising, as described in Sections 2-5 of this Privacy Policy.  

If you wish to opt-out of this “sale”/“sharing” activity, please follow the instructions in the in Section 13(d). You may also exercise the right to opt-out through the Digital Advertising Alliance’s (DAA) CCPA Opt Out Tools. You can opt out via both website and mobile app as described in the DAA CCPA Opt Out Tools. The opt-out operates by placing a cookie on your device that is unique to the browser and device you use to opt-out. If you change browsers or computers, or delete the cookies on your computer, you will need to opt-out again. You also can set your browser to notify you when a cookie is being set and block most cookies. Please note that the CCPA opt outs provided through the DAA apply to the sale of personal information by participating companies. You may still receive advertisements that do not involve the sale of personal information subject to the CCPA.

We do not sell the personal information of consumers less than 16 years of age, unless we receive affirmative authorization.

vi. Sharing with third parties for their own direct marketing purposes

We do not disclose personal information to third parties for their own direct marketing purposes. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided in Section 13(d) below. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond.

vii. Notice of Financial Incentives

We may offer promotions and discounts on products or services by joining our email subscription list or enrolling in other marketing opportunities, including our Influencer program. The availability of these promotions to you at any given time will vary.  If and when we offer such programs, we may ask for your Personal Information including: your email address and other required contact information as a prerequisite to your participation.

You may opt-in to the above promotions through the Service or navigating through your account with us. You may withdraw from these promotions at any time by contacting us at info@tinybeans.com. If you withdraw from these programs, we will not contact you for at least twelve (12) months before requesting your participation again.

The value we place on personal information collected for these promotions varies, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have email addresses, shopping history and preferences, or other collected information.

d. Exercising Your Rights

To exercise the rights described above, please follow the instructions in Section 12. . 

 Any disclosures we provide will only cover information collected on or after January 1, 2022. If doing so is impossible or would involve disproportionate effort, we will only provide you with information regarding information collected in the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.

f. Retention of Personal Information 

We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained as described in Section 16.

14. EU Residents Rights and Disclosures:

This European Privacy Notice applies to any individuals located within the European Economic Area (EEA), UK, or Switzerland from whom we may have collected personal data from any source, including through your use of the Service.  We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, access, rectification, erasure, restrict processing, data portability and to object with respect to collected personal data.  For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.

a. Data Subject Rights

Subject to local law, you may also have certain additional rights regarding information that we have collected and that is related to you. To exercise these rights, please follow the instructions in Section 12. Such individuals also have the following rights:

i. Right to Access 

This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and to obtain a copy of such personal data. It also allows individuals to request and obtain a copy of the details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data has been or will be disclosed and the purposes of the processing.

ii. Right to Rectify 

This right allows individuals to rectify any inaccurate, outdated, or incomplete Personal Data about him or her.

iii. Right to Restrict Processing 

This right allows individuals to make processing of Personal Data unavailable under certain circumstances.

iv. Right to Be Forgotten 

This right is also known as the “right to erasure.” It is an individual’s right to have Personal Data erased in specific circumstances.

v. Right of Data Portability

This right allows individuals to move, copy or transfer personal data from one place to another in a secure, structured, machine-readable, and commonly used format manner without interrupting the integrity and usability of the information.

vi. Right to Object to Processing

This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

vii.  Right to Withdraw Consent 

 You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data. You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA). You can view the contact information for your data protection authority here.

To exercise any of the above rights, please  follow the instructions in Section 12.

b. Legal Bases for Processing 

We rely on the following legal bases to process your personal data: (i) it may be necessary for us to use and disclose your personal data for the performance and fulfillment of the contract between us and to provide you with our services, including, but not limited to, those obligations in our terms of use; (ii) if you specifically consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent;  (iii) we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and (iv) as necessary to pursue our legitimate interests as further detailed below.

Legitimate business interests.  We may collect, process, and maintain personal  data to pursue the legitimate business interests outlined below.  To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

While our legitimate interests are most extensively detailed in Section 2 of this policy, they generally include:

Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing.  This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.ces; (ii) if you specifically consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent; and (iii) we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.

15. Cross Border Transfers

The Service is maintained in the United States of America. By using the Service, you authorize the export of your information to the USA and its storage and use as specified in this policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. Further, we may transfer your information from the EU and Switzerland to the USA and other countries, some of which have not been determined by the EU to have an adequate level of data protection. For such transfers, we take the necessary measures to ensure that your Personal Information receives an adequate level of protection. Personal data of EU residents will be transferred in compliance with the requirements of the GDPR.

Your acknowledgment of this policy followed by your submission of such information represents your agreement to that transfer. If you do not wish for your Personal Information to be transferred outside of your state, province, country or other governmental jurisdiction, you should not share your Personal Information by using the Service.

We will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

16. Retention

Tinybeans will retain your Personal Information for the period of time that is necessary to fulfil the original Tinybeans will retain your Personal Information for the period of time that is necessary to fulfill the original purposes for which it has been collected. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.

The criteria used to determine our retention periods include:

Whether your account with us is active. You may contact us to make your account inactive at any time.

Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Service.

17. Contact

For questions or concerns relating to this Privacy Policy or your information, we can be contacted using the information below. Our data privacy manager can be contacted here: info@tinybeans.com. If you are located in the European Union with rights under the GDPR and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.

Via Email: info@tinybeans.com

Via Regular Mail: 228 Park Ave S, PMB 41497, New York, NY 10003-1502