NEWBORN CARE, LLC  ̶  PRIVACY POLICY

1.PERSONAL INFORMATION
Privacy is very important to all of us at Newborn Care LLC (“Company”). We have established this privacy policy (“Privacy Policy”) to explain to you how your personal information is protected, collected and used. Personal information is information about you that is personally identifiable, such as your name, address, phone number, and email address, that is not otherwise publicly available (“Personal Information”). The content and material on this website (the “Site”) offers information regarding newborn care strategies through various training tools and aims to meet the increasing demands from families, individuals, and nanny agencies around the world for highly qualified, trained caregivers.  The privacy constraints and practices of this Privacy Policy apply to our Site and the services available under this Site.
By visiting this Site, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access this Site. From time to time, Company may modify this Privacy Policy and post such modifications here on this Site. Your use of this Site after any such modification constitutes your acceptance of the modified Privacy Policy. By submitting Personal Information to us through this Site, you expressly consent to our use and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Company Terms of Use, available at https://newborncare.thinkific.com/pages/terms.


2.INFORMATION COLLECTION & USE
To access services offered by Company via the Site, you will be required to create an account, including an account name and a password, and you will be required to input certain Personal Information, including your email address.  Company collects Personal Information from you through the Site to allow us to provide access to services that most likely meet your needs and preferences. We only collect Personal Information about you that we consider necessary for achieving this purpose.
In general, you can browse the Site and “opt-out” from providing us with any Personal Information.  Once you agree to provide us with Personal Information, you are no longer anonymous to us. If you choose to use our services through this Site, we may require you to provide contact and identity information and other Personal Information as indicated on the forms throughout the Site. Where possible, we indicate which fields are required and which are optional. You always have the option to not provide information by choosing not to use or purchase a particular service.
Whether now or at some later date, and under limited circumstances we may require you enter financial information, including credit card information, to verify the accuracy of your name, address and other information, as well as to bill you for your use of fee based services and products.  You will never be billed or asked for financial information for services that are NOT fee based.
We may track certain information based upon your behavior on the Site. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand our customers. This information may include, but may not be limited to, the URL that you just came from, which URL you go to next, your computer browser information, and your IP address.
If you choose to post messages on this Site or leave feedback for other customers, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect and retain such information in a file specific to you.


3.USE OF YOUR PERSONAL INFORMATION
We use your Personal Information, including your email address, to facilitate your registration and the subscription by you of our services upon your request and purchase. We use your Personal Information, and other information we obtain from your current and past activities on the Site to: resolve disputes; troubleshoot problems; collect subscription fees owed; measure consumer interest in our products and services; inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms of Use Agreement; and as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems or resolve disputes. We may compare and review your Personal Information for errors, omissions and for accuracy.
You agree that we may use your Personal Information, including your email address, to improve our marketing and promotional efforts, to analyze site usage, to improve our content and product offerings, and to customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site and our products.


4.COMMUNICATIONS FROM THE SITE
We may occasionally send you information on products, services, special deals, and promotions. Out of respect for your privacy, we provide you a way to unsubscribe from each of these communications.  If you no longer wish to receive our promotional communications, you may opt-out of receiving them by following the instructions included in each such communication or by contacting us.
You will be notified when your Personal Information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if access to our services and products is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account and subscription for our services.


5.INFORMATION SHARING AND DISCLOSURE
As a matter of policy, we do not sell, rent or share any of your Personal Information, including your email address, to third parties for their marketing purposes without your explicit consent. However, the following describes some of the ways that your Personal Information may be disclosed in the normal scope of business to provide our services and products to customers:
•External Service Providers: There may be separate services offered by third parties that we refer to as external service providers that may be complementary to your use of the Site. If you choose to use these separate services or products, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy. We do not disclose your Personal Information, including your email address, to external service providers unless you provide your explicit consent. With your consent we may provide some of your Personal Information to the external service provider offering such services, for your convenience. To prevent our disclosure of your Personal Information to an external service provider, you can decline such consent or simply not use their services or products. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services.
•Internal Service Providers: We may use third parties that we refer to as internal service providers to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you and therefore we may provide some of your Personal Information, including your email address, directly to these internal service providers. These internal service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced Company related operation, unless you have explicitly agreed or given your prior permission to them for additional uses. If you provide additional information to an internal service provider directly, then their use of your Personal Information is governed by their applicable privacy policy.
•Legal Requests: Company cooperates with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights, to help protect you, other users, and Company from bad actors. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address, username history, and fraud complaints without a subpoena. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss, or report suspected illegal activity.
Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information, including your email address, to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from the Site. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should neither rely upon nor expect, that your Personal Information or private communications will always remain private.


6.LOG FILES
As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information. We track trends in users’ usage and volume statistics to create a more efficient and usable site and offerings, and to determine areas of the site or our services that could be improved to enhance the user and customer experience. Log files are used on the Site, and in any link to the Site from an email.


7.COOKIES AND RELATED TECHNOLOGIES
When you use this Site, we collect certain information by automated or electronic means, using technologies such as cookies, browser analysis tools, and web server logs. As you use this Site, or our applications, your browser and other electronic devices communicate with servers operated by us and our services providers to coordinate and record the interactivity and fill your requests for services and information.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to this Site by your computers or mobile devices. These servers are operated and the cookies managed by us or our service providers.
For example, when you visit this Site, Company and our service providers may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return, and track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account and preferences.
Some cookies are temporary, whereas others may be configured to last longer.  “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided, and storing your preferences.


8.MANAGE YOUR SECURITY SETTINGS
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third party advertising companies online at www.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/.
You may manage how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
9.OTHER PRIVACY RELATED TO MOBILE APPLICATIONS
Your access to our services through a mobile device may result in additional information being collected by Company.  Registration may be required to utilize certain features of a mobile application.  When you register with us and use the application, you may provide some or all of the following: (a) your name, email address, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; and (d) information you enter into our system when using the application, such as contact or credit card information. We may also use the information you provided to us to contact you from time to time to provide you with important information, required notices and marketing promotions.
This application does collect precise information about the location of your device. In order to allow the application to collect real-time location information you must select to permit location functionality when prompted by the application and also enable the GPS services on your mobile device. We use your location information to provide requested location services such as advertising or offers from local businesses and their locations.  You can stop all collection of information by the application by uninstalling the application from your mobile device. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
You can also withdraw your consent to receive “push” notifications and/or to the collection of your physical location information at any time by disabling or changing the related functionality or setting as provided in your mobile device.


10.LINKS TO OTHER SITES
This Site may contain links to other sites that are not owned or controlled by Company.  Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies only to information collected by this Site.


11.COMMENTS OR DISCUSSION FORUMS
If you use a forum or comment section on the Site, you should be aware that any personally identifiable information that you submit, including your name and email address, can be read, collected, or used by other users of the Site, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit on this Site.


12.ACCESSING AND CORRECTING PERSONALLY IDENTIFIABLE INFORMATION
If you want to update or delete your contact information, terminate your subscription, or have other questions or requests, please contact us at [email protected] While we are ready to assist you in managing your subscription, and closing your account, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases for financial reporting and compliance reasons.


13. SECURITY
We follow generally accepted industry standards to protect Personal Information, including your email address, submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.


14.Secure Credit Card Transactions
You can use your credit card securely on this Site. We have partnered with Stripe to offer safe and secure credit card and electronic check transactions to you.


15.NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE THE UNITED STATES OF AMERICA
The Company is headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored.


16.CHANGES IN THIS PRIVACY STATEMENT

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently.


17.SAFE HARBOR COMPLIANCE
Company complies with the United States/European Union Safe Harbor Framework and the United States/Swiss Safe Harbor Framework of the United States Department of Commerce (collectively, “”).  The Safe Harbor Framework governs the collection, the use, and the retention of Personal Information from European Union member states and Switzerland.  


18.DIGITAL MILLENNIUM COPYRIGHT ACT (“DMCA”) NOTICE
In the event materials are made available to Company by third parties not within our control, we are under no obligation to, and do not, scan such content for the inclusion of illegal or impermissible content. However, we respect the copyright interests of others. It is our policy not to permit materials known by us to infringe another party’s copyright to remain on the Site.  If you believe any materials on the Site infringe a copyright, you should provide us with written notice that at a minimum contains:
i.A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
ii.Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works are covered by a single notification, a representative list of such works;
iii.Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;
iv.Information reasonably sufficient to permit us to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted;
v.A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
vi.A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.


All DMCA notices should be sent to our designated agent as follows:
Garland Brown
Weiss Brown
6263 North Scottsdale Road, Suite 340
Scottsdale, AZ 85250

It is our policy to terminate relationships regarding content with third parties who repeatedly infringe the copyrights of others.

Updated 2018.10.03