Charlie Banana (operated by Charlie Banana USA LLC in the US and Winc Design LTD in all other countries) works hard to build and maintain a relationship of trust with you. So, when it comes to handling your information, we do so carefully and sensibly, and in ways that live up to that trust. This policy lets you know how we do that, including what information we collect, how we use and protect it, and how you can decide what we do with it. Our goal is to help you understand how we use your information to improve our content, products, advertisements, and services.
Here’s a short introduction to our privacy practicesWhat we collect?
- Information you give us
- Information we collect when you contact us, visit our sites, use our mobile applications or services, use our products or devices, or view our advertisements
- Information we get from other companies who have obtained your consent to share or sell it or have ensured that other companies from whom they have received your information can share it with them and, in turn, with us and/or other companies
- Information we get from other companies when you visit their websites
We may combine any and all of this information to help create better products, services, and consumer experiences.how we use your information
- Send you the products and services you ask for
- Tell you about our and our marketing partners’ products and services
- Help us run our sites and services
- When we have your consent, with our carefully selected partners so that they can send you offers, promotions, or ads about their products and services we believe you may be interested in
- With other companies we hire to help us run our business
- As part of a sale of theCharlie Banana brand or business to another company
- To help us protect our rights or property, e.g., fraud prevention or information security
- When required by law or government authorities
You can tell us how we can use your information by clicking on the links below:
If you live in the EU, you have certain personal data rights, including to access what personal information we have about you, make corrections or updates to it, tell us to delete that data, or receive a portable copy of that information. These rights don’t apply in all situations. Please click the links below to:
If you live in California, you may also have certain privacy rights, including to access what personal information we have about you, ask us to delete the personal information we collected from you, or request for us to not “sell” that data. These rights also don’t apply in all situations. To learn more about your rights and how to exercise them, please click the link below:
What we collect
We collect information when you give it to us, when you contact us, visit our sites, use our mobile applications or services, use our products or devices, or view our advertisements. We also receive information from other companies who have obtained your consent to share or sell it, have ensured that other companies from whom they have received your information can share it with them and, in turn, with us and/or other companies or have collected the information when you visit their websites.
Data elements in this category include names (including nicknames and previous names), titles, mailing address, email address, telephone/mobile number and contact information for related persons (such as authorized users of your account).Unique identifiers
Data elements in this category include unique ID number (such as customer number, account number, subscription number, rewards program number), system identifiers (including username or online credentials), device advertisers, advertising IDs and IP address.Government-issued identification information numbers
Data elements in this category include social security number, driver’s license number and passport number.Financial information
Data elements in this category include bank account number and details and payment card information.Biometric information
Data elements in this category include facial recognition data, voiceprint, fingerprint and a mathematical representation of your biometric identifier, such as the template maintained for comparison.Demographic Information and Preferences
Data elements in this category include personal characteristics and preferences, such as age range, marital and family status, shopping preferences, languages spoken, loyalty and rewards program data, household demographic data, data from social media platforms, education and professional information, hobbies and interests and propensity scores from third parties (likelihood of purchase, experiencing a life event, etc.).Transaction and Commercial Information
Data elements in this category include customer account information, qualification data, purchase history and related records (returns, product service records, records of payments, credits etc.), records related to downloads and purchases of products and applications, non-biometric data collected for consumer authentication (passwords, account security questions), customer service records.Inferred Information derived from other information listed in this section
We create inferred and derived data elements by analyzing our relationship and transactional information. Data elements in this category include propensities, attributes and/or scores generated by internal analytics programs.Online & Technical Information, including internet or other electronic network activity information
Data elements in this category include: IP address, MAC address, SSIDs or other device identifiers or persistent identifiers, online user ID, encrypted password, device characteristics (such as browser information), web server logs, application logs, browsing data, viewing data (TV, streaming), website and app usage, first party cookies, third party cookies, flash cookies, Silverlight cookies, web beacons, clear gifs and pixel tags.Audio Visual Information
Data elements in this category include photographs, video images, CCTV recordings, Call Center recordings and call monitoring records, and voicemails.
Data elements based on how it is collected include:
Information collected from consumer programs
- General health and symptom information or product interest
- Pregnancy related information, such as due date
Consumer Research Studies where you have provided your informed consent
- Information about physical or mental health, disease state, medical history or medical treatment or diagnosis, medicines taken and related information
Data elements in this category include smart device records, IoT products.Geolocation data
Data elements in this category include precise location (such as latitude/longitudeChildren’s data
We do not knowingly collect personal information directly from children under 16, except where we have the consent of the parents or guardians. We receive children’s data from parents and guardians.
How We Collect Your Information
We collect information about you in many ways from many places. Some of the information we collect may include personal information that can be used to identify you; for example, your name, email address, telephone number, or postal address. In some countries like those in the EU or in states like California, things like IP address or cookie and mobile device identifiers may also be considered personal information.Here are the ways we collect your information:
Please note: We may combine all of the information we collect about you to give you better products, services, and user experiences.You provide it to us directly.
You give us your information when signing up for an account on our websites or mobile apps or by calling or emailing us. We may ask for things like your name, email or home address, date of birth, payment information, your age, gender, the number of people in your family, and the way you want us to send you information about our products and services—for example, to your home address, email address, or by texting you.From sites and emails
To give you the best possible user experience, we may use technologies that collect information from your phone when you use our mobile apps or our “smart” devices in your home. You consent to do this when downloading the app or installing household internet connected devices. This information could include your mobile phone or other device advertising ID, information about your phone’s operating system, how you use the app or device, and your physical location. You will get a pop up notice on your phone or device that gives you the option to accept or reject allowing us to know your precise geolocation (exactly where you are standing or where you are accessing the internet).From other places
We may get information that other companies share with or sell to us. For example, you may have given consent for another company to share your personal information with us when you signed up for telecom services or a retailer loyalty points program. We may also collect information from places that you know everyone can see, such as from internet postings, blog entries, videos, or social media sites. We may also receive information from other companies, such as consumer data resellers, who are in the business of collecting or aggregating information about you sourced from publicly available databases (in line with local legal requirements as applicable) or from consent you have given to their use and subsequently our use of your information. This might be information about your income level, age, gender, number of people in your family, and products you have bought on the internet or from stores in your neighborhood.
How We Use Your Information
We use your information to help us meet our purpose of touching and improving the lives of people like you every day around the world. For example, we use your information to:
- Perform Services
- Identify and authenticate you to our different marketing programs and websites
- Respond to your questions or requests for information,
- Provide customer service
- Send transactional messages (such as account statements or confirmations),
- Send marketing communications, survey and invitations
- Process your payment for the products you buy from us
- Process and issue refunds and collections
- Send you products or samples you have requested
- Help you manage your Charlie Banana site or app preferences
- Allow you to enter our contests or sweepstakes
- Interact with you on social media
We also use your information for internal business purposes, such as:
- Quality control, training and analytics
- Safety Maintenance and verification
- System administration and technology management, including optimizing our websites and applications
- Security purposes, including detecting threats and protecting against malicious or fraudulent activity
- Recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information
- Risk management, audit, investigations, reporting and other legal and compliance reasons
We may also use your personal information to better understand you and our customers generally, including:
- For internal research
- To design and develop products, services and programs that delight our consumers
- To identify prospective consumers
Another way we use your information is to track your use of products, services and websites to make sure that what you hear from us is relevant and useful to you as an individual. For example, we may send you information about Charlie Banana feminine hygiene products if you have shown interest in our baby products by visiting charliebanana.com. When we do this, we may identify you or your device and associate you with different devices you may use in order to deliver more relevant advertising to you. We will use your information – a cookie ID or device ID -- to limit the number of times you see the same advertisement from Charlie Banana. We want you to hear from us about the products you use and love without you hearing the same message We may also use your personal information to learn more about what consumers want so that we can make new products or improve the ones we already have.
How We Safeguard Your Information
We respect your personal information and take steps to protect it from loss, misuse, or alteration. Where appropriate, these steps can include technical measures like firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. We also use organizational and physical measures such as training staff on data processing obligations, identification of data incidents and risks, restricting staff access to your personal information, and ensuring physical security including appropriately securing documents when not being used
Your Rights and ChoicesMarketing
You can tell us to stop sending you email and text messages by following the opt-out instructions sent with these communications. You can also choose to stop receiving marketing email, SMS, or postal mailings by emailing us at email@example.com. While we will honor your choices, we may need to keep information to do so. For example, if you tell us to stop sending marketing emails, we will need your email address on file so that our systems remember that you no longer wish to receive marketing communications to that email addressAccounts
Depending upon the country where you registered, your Charlie Banana account may offer the ability to access your information and make updates to or delete your data. If not, you can email us at firstname.lastname@example.org to make a request.California residents
If you live in California, you may access the personal information we hold about you, request details about how we process your personal information, ask us to delete your data or request that we no longer “sell” your personal information (as “sell” is defined in the CCPA). To learn more and to exercise such rights, please contact us at email@example.comEuropean union residents
If you live in the EU/EEA, or are physically in the EU/EEA, you may access the personal data we hold about you, request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted, and ask us to provide your data in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time where we are relying on your consent for the processing of your personal data. And you may object to our processing of your personal data (this means ask us to stop using it) where that processing is based on our legitimate interest (this means we have a reason for using the data). If you would like more information about data protection and your personal data rights in general, please visit the European Data Protection Supervisor’s site at https://edps.europa.eu/data-protection/ . If you are not happy with our response to your requests, you may lodge a complaint with the data protection authority in your country. Please select from the following options to make your request:General requests
To make a request with respect to personal data used for marketing, which would include for example information you provided us as you registered through one of our websites or apps, please contact us firstname.lastname@example.orgMedia advertising
To make a request with respect to personal data used for advertising, which would include for example information we may have about you at a cookie or device ID level and which we use to provide you with relevant ads, please contact us at email@example.com . There may also be data associated with your cookie or device ID in our demand-side (or ad-serving) and ad verification partner platforms. For that data, please contact us at firstname.lastname@example.orgConsumer research
To make a request with respect to personal data we may have as part of your participation in one of our research studies, please see the contact information provided on your consent form or call or visit your research center.
When you visit our partner sites, we can show you ads or other content we believe you would like to see.We learn from groups of consumers sharing similar interests
We may place you into a particular group of consumers who show the same interests. For example, we may put you in the group of “cloth diaper aficionados” if we see you frequently purchase cloth diapers online or you could be a “bargain-shopper” if we notice you use online coupons or look for discounts or sales. We notice these things about you as you look at web pages, links you click on our websites and other websites you visit, mobile applications you use, or our brand emails you view and links you click in the emails. We group together cookie and device IDs to help us learn about general trends, habits, or characteristics from a group of consumers who all act similarly online and/or offline. By doing this, we can find and serve many others who “look like” those already in the group and thereby send them what we believe will be relevant and beneficial product offers and information.We link other information to your cookie and device IDs.
Your cookie and device IDs may be supplemented with other information, such as information about the products you buy offline or information that you provide directly to us when creating an account on our sites. We generally do this in ways that will not directly personally identify you. For example, we could know that cookie ID ABC12345 belongs to the cloth diaper aficionado group based on person’s web site visits, age, gender, and shopping habits, but we would not know that person’s name or address or other information that would identify him or her as a person. Should we ever want to personally identify your cookie or device information (web and app viewing history), we will always ask you before doing so.We may know you across all of your computers, tablets, phones, and devices
We may know that cookie ID ABC12345 is from a computer that that may be connected to the same person or household owning the mobile phone with device ID EFG15647. This means that you may search for diapers on your laptop, click on a Google search result link which we have sponsored, and then later see an ad for our Charlie Banana brand diapers on your mobile phone. We might assume or deduce that the same person owns the computer and phone because, for example, they sign on to the same WiFi network every day at the same time. Understanding what devices seem to be used by a person or household helps us limit the number of times you see the same ad across all of your devices. And this is important because that way you don’t get annoyed at us for spamming you with the same ad and we don’t pay for such repetitive ads that we don’t want you to receive.
How you can stop receiving interest-based ads.
To stop receiving Charlie Banana interest-based advertising, you can click here or click on the AdChoices icon on one of our sites. You can also prevent getting interest-based ads on websites by declining cookies in your browser(s), declining the “access to data” requests that apps usually present when you install them, or by adjusting the ad tracking settings on your device.You will still see “contextual” ads even if you opt out of interest-based ads
Even if we stop sending you interest-based ads, you will still get ads from our brands on your computer or mobile devices. These ads, however, are based on the context of the sites you visit and are called contextual ads. Unlike interest-based ads which are based on pages you visit on your mobile phone or computer viewing activities, contextual ads are ads shown to you based on the context of the specific site you are visiting. For example, you still may see an ad for one of our baby care brands while looking at nursery products online because these sites traditionally have had mostly new or expecting parents as visitors. You should also know that we may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud.Deleting cookies also deletes your opt out.
When you opt out of interest-based advertising, we send an opt-out cookie to your browser that tells us that you no longer want to receive interest-based ads from us. Your opt-out cookie will be deleted if you decide to delete all cookies. This means that you will need to opt-out again if you still do not want to receive interest-based ads.
European Union Data Processing, Retention, and Transfers
This section applies only to our processing of personal data of EU country residents. It aims to provide increased transparency into our processing, retention, and transfer of EU resident personal data that is in line with the letter and spirit of the General Data Protection Regulation.Entities
Different Charlie Banana entities may be the controller of your personal data. A data controller is the entity which directs the processing activity and is principally responsible for the data. The chart below identifies our data controllers for EU country data. For example, when you register for email on one of our French (.fr) websites, the Charlie Banana entity listed next to that country name will be the controller of that personal data (e.g., Winc Design Ltd, a Hong Kong resident and registered company)Processing and retention
As a general rule, we keep your data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations. This chart tells you the type of data we collect, the purposes for which we use it, why such uses comply with the law (legal basis), and how long we usually keep it (retention period).
|Type of Data||Why We Collect This Data||Legal Basis||Retention Period|
Email, name, phone number, postal address, your affinities, your interests, your profession, your habits, what you bought, the photos or videos you upload, information about your children and your home, your family composition, the number of people in your household, your hair type, your skin type, your favorite scent, whether you have a pet, etc.
|To send you materials, including advertisements, marketing our products or services or the products or services of our partners||Your consent for email and SMS and, where we obtain it, consent for postal. Legitimate interests for everything else.||Until you request to delete the personal data or withdraw your consent. If you do not make such a request, the personal data will be deleted on the following schedule:
Email: after <50 months of all-channel inactivity. We define inactivity through several internal criteria.
SMS: after <50 months of all-channel inactivity. We define inactivity through several internal criteria.
Postal address: after <50 months of all-channel inactivity. We define inactivity through several internal criteria.
Email, name, phone number, sometimes other data.
|To provide contest participants with information about the contest, including announcing the winner(s) of the contest.||Your consent.||For 24 months unless local law requires us to retain it longer.|
Email, name, phone number, payment information (including bank account IBAN or Paypal details), sometimes other data.
|To process your purchases of our products, cashback offers, or warranties and to send you relevant communications related to that purchase.||Your consent.||As long as necessary to fulfill your order and follow up with communications about your order unless local law requires us to retain it longer. We also generally retain data for 24 months for cashback offers and 10 years for warranties.|
Email, name, phone number, payment information (including bank account IBAN or Paypal details), sometimes other data.
|To address your inquiries and make sure we follow up appropriately or as may be required by law or Charlie Banana policy.||Our legitimate business interest in managing consumer inquiries, as well as your consent for special category data which may be collected in some adverse event cases.||From 0 to 10 years, depending on the nature of the inquiry, our legitimate interests for processing the data, and our legal obligations.|
Email, name, phone number, address, identifiable photos or videos, sometimes other data.
|To test our product ideas and learn about your preferences and practices so that we can improve our products and the lives of our consumers.||Your consent.||We will retain the personal data collected as part of substantive clinical research for as long as we need it for the purpose for which it was collected, and/or for as long as may be required to retain it by local law or regulation, which may be up to 25 years. For non-clinical research, we will retain your substantive personal data for a maximum of 5 years. We will retain your signed informed consent documents|
Advertising cookies, device ID, demographic information such as gender and age, behavioral data such as page views, and sometimes other data.
|To learn about your Internet interests and customize the ads we send you.||Our legitimate business interests in serving you with relevant advertising in all EU/EEA countries, except for France and United Kingdom, where we rely on consent. We will obtain your consent for the deployment of cookies on our own websites in accordance with ePrivacy requirements.||We will retain this data for thirteen months from the date we collect it or until you opt out, whichever is earlier.|
Transfers of your data to other countries
Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States. For example, we may store your data on a server in the United States because that is where a particular database is hosted; and that data may be “transferred” again when one of our marketers accesses that data from Hong Kong to send you a product sample. We perform such transfers, both between Charlie Banana entities and between Charlie Banana and our service providers, using contractual protections that EU regulators have pre-approved to ensure your data is protected (known as model contract clauses). If you would like a copy of a transfer agreement, contact us at email@example.com. We may also for certain vendors, e.g., online platform service providers, rely on these vendors’ participation in the U.S./EU Privacy Shield Framework.
Site and App ContentPlugins.
Our websites may allow you to log in using your account with another company such as, for example, “Login with Facebook.” When you do this, we will have access only to the information that you have given us consent to receive from your account settings in the other company’s account you’re using to log in with.User content
Charlie Banana sites may include links to other sites, which we do not control. Those sites will be governed by their own privacy policies and terms, not ours.
Children’s PrivacyChildren’s online privacy laws
We follow all applicable data protection laws when collecting personal information online from children. For example, in the EU we do not collect personal information from children under 16 years of age unless we get consent from a parent. Similarly, in the U.S., we obtain verified parental consent when collecting personal information from children younger than 13.
California Consumer Privacy Rights
For more information about the categories of personal information we collect, business and commercial purposes for the collection of the personal information and categories of third parties with whom we share the personal information, please see the disclosures above. As a California resident, you may have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
- The categories and specific pieces of personal information we have collected about you;
- The categories of sources from which we collected the personal information;
- The business or commercial purpose for which we collected or sold the personal information;
- The categories of third parties with whom we shared the personal information; and
- The categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
In addition, you have the right to request that we delete certain personal information we have collected from you. To submit a request for general disclosure, access all the information we have about you or to ask to delete your data you can contact us at firstname.lastname@example.org . To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or considering your deletion request. Upon receipt of your request, we will send you a verification form by email or postal mail. To complete your request, please respond to the verification form when you receive it. To verify your identity, we may require you to provide any of the following information: Name, email address, postal address, or date of birth. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Please understand that Charlie Banana cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
Finally, you also have the right to opt out of the sale of your personal information. To exercise that right, please complete the process bycontacting us at email@example.com.
Under the CCPA, you may designate an authorized agent to make a request on your behalf but the agent will need to complete the verification process, including the submission of proof that it has been designated to act on your behalf. For access and deletion requests made by an authorized agent on your behalf, we also may require you to verify your own identity directly with us (as described above). We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise your rights under the CCPA.California notice for minors.
We may offer interactive services which allow teens under the age of 18 to upload their own content (e.g., videos, comments, status updates, or pictures). This content can be removed or deleted any time by following the instructions on our sites. If you have questions about how to do this,firstname.lastname@example.org. Be aware that such posts may have been copied, forwarded, or posted elsewhere by others and we are not responsible for any such actions. You will, in such cases, have to contact other site owners to request removal of your content.
Please contact us directly at email@example.com with any questions or concerns you may have about your privacy and our data protection practices or if you are a consumer with a disability and need a copy of this notice in an alternative format.