Privacy Policy
Last updated 1st June 2022
This Privacy Policy is issued on behalf of Little Wriggler (together “Little Wriggler”, “us”, “we” or “our”). We are the data controller of any personal information we collect about you/your child and we are responsible for the www.Little Wriggler.com website, all our associated brands’ websites or apps and any other websites or apps owned and operated by Little Wriggler from time to time (together the “Websites”).
We take your/your child’s privacy seriously and are committed to protecting personal data. This Privacy Policy sets out how we process your (and, where relevant your child’s) personal data when accessing our Websites, signing up to newsletters, purchasing products, taking part in competitions or otherwise engaging with us.
Introduction
This Privacy Policy explains who we are, why and how we process personal data collected through your/your child’s use of our Websites or otherwise through your interaction with Little Wriggler, what rights you/your child have and how to get in touch with us if you need to. For ease of reference, we have divided this Privacy Policy into the following sections:
Introduction
Children
What information can we collect?
How is your/your child’s personal information collected?
How and why do we use and share your/your child’s personal information?
For how long do we keep your/your child’s personal information?
Security
International data transfers
Your/your child’s rights
Contact details
It is important that you read this Privacy Policy together with any other privacy notices that we may provide on our Websites at or around the time that we collect or process personal data about you/your child.
We will update this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we may decide it is appropriate to let users of our Websites know. However, it is overall your responsibility to check this Privacy Policy before each use of our Websites – for ease of reference the top of this Privacy Policy indicates the date on which it was last updated.
Children
Please note that, unless otherwise explained, we do not knowingly collect personal data about children. We anticipate only collecting data from parents and guardians.
None of our Websites are designed for children. If we believe a child is using one of our Websites we will not process any personal information of that child without the verifiable consent of the parent or guardian. If, as a parent or guardian, you believe we have collected personal data about your child, you may contact us to review the data and request that we cease processing data about your child.
What personal data do we collect?
What is personal data?
Where this Privacy Policy refers to ‘personal data’ it is referring to data about you/your child from which you/your child could be identified. The types of personal data we collect from you/your child may include:
Basic details like your/your child’s name, date of birth and gender.
Contact details like your/your child’s e-mail address, phone number, delivery address and shipping address if you are purchasing products or services from us. If you are a business contact, we may collect your name, email address, telephone number, job title and mailing address/place of work.
Financial data like your payment card details.
Transaction data like details about payments you have made to us and the products or services you have purchased.
Technical data about your/your child’s browsing actions and interactions with our Websites. We may collect this information by using cookies and other similar technologies. At the time of the last update of this privacy policy Little Wriggler does not currently collect this kind of technical data.
Usage data about how you/your child use our Websites. At the time of the last update of this privacy policy Little Wriggler does not currently collect this kind of technical data.
Marketing and communications data which includes your/your child’s preferences in receiving marketing and newsletters from us and third parties.
Social media data like posts, comments, photos or videos uploaded onto our social media pages managed by us.
How do we collect your/your child’s personal data?
Direct interactions
When you/your child use and interact with our Websites, you/your child may provide us with certain personal data, such as when requesting newsletters be sent to you, buying products, contacting us, taking part in online surveys, entering competitions or reporting a problem with a Website. When you/your child do these things we may collect, store and use the personal data that you/your child disclose to us, in accordance with this Privacy Policy.
Automated technologies or interactions
We may also collect information about you/your child when you/your child visit and interact with our Websites through the use of technologies such as cookies. At the time of the last update of this privacy policy Little Wriggler does not currently collect this kind of technical data. The following are examples of information we may collect:
information about your/your child’s device, browser or operating system;
your/your child’s IP address;
information about links that you/your child click and pages you/your child view on our Website;
length of visits to certain pages;
subjects you/your child viewed or searched for;
page response times;
records of download errors and/or broken links;
page interaction information (such as details of your/your child’s scrolling, clicks, and mouse-overs);
methods used to browse away from the page; and
the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).
Information we collect from other sources
From time to time we may also obtain personal data from other sources, for example your username, location and IP address whenever you/ your children view one of our YouTube videos whilst logged into your YouTube or Google account. At the time of the last update of this privacy policy Little Wriggler does not currently collect this kind of data.
How and why do we use and share your/your child’s personal data?
Lawful basis for processing your/your child’s information
We will only use your/your child’s personal data when the law allows us to. Most commonly we will use personal data in the following circumstances:
Where you/your child have asked us to do so, or consented to us doing so;
Where we need to do so in order to perform a contract we have entered into with you/your child;
Where it is necessary for our legitimate interests (or those of a third party) and your/your child’s fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
Here are some examples about how we may use the information we collect about you/your child and the lawful basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your/your child’s personal data for more than one lawful ground depending on the specific purpose for which we are using your/your child’s data.
Activity
Examples of the types of personal data we may collect
Lawful basis for processing
To manage our relationship with you including notifying you of any changes to the Website or services provided on the Website or dealing with any enquiries made by you.
Basic, Contact and Marketing and communications data.
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated, manage the operation of the Website and study how users use our products & services)
To send you email newsletters, news, information about giveaways and to keep you up-to-date about our products and services which we think will interest you.
Marketing and communications data
Necessary for our legitimate interests (to develop our business/brand and improve our marketing strategy)
To allow you to attend an event or so that you can enter a competition or prize draw.
Basic, Contact and Marketing and communications data and social media data.
Necessary for our legitimate interests (to develop our business/brand and improve our marketing strategy)
To administer and protect our business and the Website (including fraud prevention and detection, troubleshooting, data analysis and system testing.)
Basic, Contact, Usage and Technical data.
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant Website content and advertisements to you.
Basic, Contact, Marketing and communications and Technical data.
Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, services, marketing, customer relationships and experiences
Technical and Usage Data.
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Where you are a business contact:
· to enter into a business relationship with you. For example, to licence our brand and contact you about this where necessary
· to manage our ongoing business relationship with you
Contact details and marketing and communications data
Necessary for our legitimate interests in entering into commercial relations with your business.
To enable us to comply with any legal or regulatory requirements and otherwise any relevant regulator or competent authority.
Any personal data
To comply with our legal obligations.
Marketing
Where you have given your consent, or where we have an alternative lawful basis you/your child may receive marketing communications from us.
You can unsubscribe (or ‘opt out’) from marketing emails at any time by clicking on the unsubscribe link at the bottom of any marketing email. You/your child may also contact us directly if you/your child do not wish to receive any marketing materials from us.
Sharing your/your child’s personal data
Depending on how and why you/your child provide us with your/your child’s personal data we may share it in the following ways where appropriate:
with any organisation within the Little Wriggler business;
with selected third parties who we sub-contract to provide various services and/or aspects of our Websites’ functionality;
with analytics and search engine providers that assist us in the improvement and optimisation of our Website as described above;
if we were to sell or buy any business or assets, in which case we might disclose your/your child’s personal data to the prospective seller or buyer of such business or assets as part of that sale;
if Little Wriggler or substantially all of its assets are acquired by a third party, in which case personal data held by us about you/your child will be one of the transferred assets;
if we are under a duty to disclose or share your/your child’s personal data in order to comply with any legal obligation, or if we are asked to provide your/your child’s details to a lawful authority in order to aid in a criminal or legal investigation; and
in order to enforce or apply our terms and conditions (including our Website terms of use); or to protect the rights, property, or safety of our business, our customers, our staff or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction where appropriate.
Service Providers
Where we use third party service providers, our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we endeavour to ensure that they protect this data and do not use it for any other purpose. We take these relationships seriously and aim to ensure that all of our data processors sign contracts with us that clearly set out their commitment to complying with data protection laws and assisting us to help you/your child exercise applicable data subject rights.
Links to third party sites
Where we provide links to third party websites, plug-ins and applications that are not affiliated with us, such sites are out of our control and are not covered by this Privacy Policy. If you/your child access third party sites using the links provided, the operators of these sites may collect personal data from you/your child that could be used by them, in accordance with their own privacy policies. Please check these policies before you/your child submit any personal data to those websites.
For how long do we keep your/your child’s personal data?
We will hold your/your child’s personal information on our systems only for as long as required to provide you/your child with the services you/your child have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your/your child’s personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you/your child.
In some circumstances you/your child can ask us to delete your/your child’s data: see ‘Your/your child’s rights’ below for further information.
In some circumstances we may anonymise your/your child’s personal data (so that it can no longer be associated with you/your child) for research, demographic, analytical or statistical purposes in which case we may use this information indefinitely.
Security
Little Wriggler takes the protection of personal data seriously. We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure data storage and passwords. In circumstances where we have given you/your child a password that enables you/your child to access certain parts of our Website, you/your child are responsible for keeping this password confidential. We ask you/your child not to share a password with anyone.
In addition, we limit access to your/your child’s personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your/your child’s personal data in accordance with our instructions.
Despite these precautions, and although we will do our best to protect your personal data, Little Wriggler cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of an actual or suspected data breach, we have put in place procedures to deal with this and will notify you and any applicable regulator of a breach where required to do so.
International data transfers
Please note that as your/your child’s personal data is shared within the Little Wriggler group of businesses, this will involve transferring it outside of the European Economic Area (EEA) and/or the United Kingdom (UK), including between the EEA and the UK. Some of our external service providers may be also based outside of the EEA and/or the UK. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your/your child’s request for information and the provision of services.
Where we transfer your/your child’s data to a service provider that is outside of the EEA or the UK (as relevant) we seek to ensure that appropriate safeguards are in place to make sure that your/your child’s personal data is held securely and that your/your child’s rights as a data subject are upheld. Transfers of personal data are made:
to a country recognised by the appropriate body as providing an adequate level of protection; or
to a country which does not offer adequate protection but whose transfer has been governed by approved standard contractual clauses or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
Your/your child’s rights
As a data subject you/your child have a number of rights in relation to your/your child’s personal data. Below, we have described the various rights that you/your child have, as well as how you/your child can exercise them. These rights can be exercised at any time by contacting us – see the “Contact Details” section below.
Right of Access
You/your child may, at any time, request access to the personal data that we hold which relates to you/your child (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you/your child to receive a copy of the personal data that we hold about you/your child. It is not a right to request personal data about other people, or a right to request specific documents from us that do not relate to your/your child’s personal data.
Your/your child’s right to rectification and erasure
You/your child may, at any time, request that we correct personal data that we hold about you/your child which you/your child believe is incorrect or inaccurate. You/your child may also ask us to erase personal data if you/your child do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you/your child to verify any new data that you/your child provide to us and may take our own steps to check that the new data you/your child have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you/your child ask us to erase we will tell you/your child what that reason is at the time we respond to the request.
Your/your child’s right to restrict processing
Where we process your/your child’s personal data on the basis of a legitimate interest, you/your child are entitled to ask us to stop processing it if you/your child feel that our continuing to do so impacts on your/your child’s fundamental rights and freedoms or if you/your child feel that those legitimate interests are not valid.
You/your child may also ask us to stop processing your/your child’s personal data: (a) if you/your child dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you/your child do not want us to erase it; (c) where we no longer need to process your/your child’s personal data (and would otherwise dispose of it) but you/your child wish for us to continue storing it in order to enable you/your child to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you/your child ask us to stop processing, we will explain that reason, either at the time we first respond to the request or after we have had the opportunity to consider and investigate it.
Your/your child’s right to portability
Under certain circumstances, where you/your child wish to transfer certain personal data that we hold about you/your child, which is processed by automated means, to a third party, you/your child may write to us and ask us to provide it to you/your child in a commonly used machine-readable format.
Your/your child’s right to object to processing
You/your child may object to processing of your/your child’s personal data where we rely on legitimate interest for processing that personal data. We will comply with your/your child’s request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your/your child’s personal data to establish, exercise or defend a legal claim.
Your/your child’s right to withdraw consent
Where our processing of your/your child’s data is on the basis of consent, you can withdraw this consent at any time. This would not affect the lawfulness of the processing based on consent prior to the withdrawal.
Your/your child’s right to object to automated decision making and profiling
You/your child have the right to be informed about the existence of any automated decision making and profiling of your/your child’s personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you/your child.
Right to Opt Out of Sale of Personal Data
A consumer has the right to request disclosure of personal data about him or her sold by Little Wriggler and opt out of the sale of that consumer’s personal data by Wriggler by contacting us using the contact details set out below.
Exercising your/your child’s rights
When you/your child write to us making a request to exercise your/your child’s rights, we may ask for copies of relevant ID documents to help us to verify identity.
It will help us to process your/your child’s request if you/your child clearly state which right you/your child wish to exercise, what personal data it is that is of particular concern to you/your child and, where relevant, why it is that you/your child are exercising it. The clearer and more specific the request, the faster and more efficiently we can deal with that request. If insufficient information is provided then there may be a delay in actioning the request until additional information is provided (and where this is the case we will tell you/your child).
Please note that all the rights mentioned in this section are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.
Contact Details
If you/your child have any queries regarding this Privacy Policy or if you/your child wish to exercise any of your/your child’s rights set out above, please contact us by emailing littlewriggler17@gmail.com and marking it for the attention of our Data Protection Officer.
Whilst we would prefer that you direct any complaints or queries you/your child have to us first, you/your child may also lodge a complaint to the supervisory authority applicable in your country about the way we process your/your child’s personal data.