Effective Date: March 21, 2022

Welcome! Thank you for visiting our website and/or mobile applications (the “Platform”). We hope you choose to be part of our community at Nibbles PBC (“Nibbles”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Privacy Policy, or our practices with regards to your personal information, please contact us at privacy@nibbles.com.

When you use our Platform, and more generally, use any of our services or resources (collectively, the “Services”, which includes our provision of the Platform), you may provide us with your personal information. In this Privacy Policy, we seek to clearly explain to you what personal information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

This Privacy Policy applies to all personal information collected through our Services (which, as described above, includes the Platform), as well as any related services, sales, marketing or events.

Please read this Privacy Policy carefully as it will help you understand what we do with personal information that we collect.

PERSONAL INFORMATION WE COLLECT

We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our products and Services, when you visit the Platform or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal information you provide to us

We collect personal information that you provide to us in connection with your use of the Services, such as your email address and postal address if you register for an account. That may include transactional information that we collect from you to fulfill any transactional requests made through the Platform. We may use this personal information to communicate with you, screen for potential risk or fraud, personalize your experience on the Platform, assist with obtaining pet healthcare plan and/or insurance coverages (including by sharing such information with underwriters at your direction for that purpose) and support you with claims processing or other policy administration matters, and, when in line with the preferences you have shared with us, provide you with information or advertising relating to the Services.

All personal information that you provide to us must be true, complete and accurate, and you must promptly notify us of any changes to such personal information.

Information we collect automatically

We may automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. We may collect such automatically generated or collected information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, mobile SDKs, location-identifying technologies and similar technology (“tracking technologies”), and we may use third-party partners or services to assist with this effort. Information we collect automatically about you or your device may be combined with other personal information we collect directly.

While such automatically generated or collected information is primarily needed to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes, we, or the third-party partners we use, may also use information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Platform; (b) provide custom, personalized content and information to you; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of the Platform; (e) perform analytics and detect usage patterns on the Platform; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise plan for and enhance the Platform and for other internal purposes.

DISCLOSURE OF PERSONAL INFORMATION

We may process or share your personal information that we hold based on or more of the following legal bases:

• Consent. We may process your personal information if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests. We may process your personal information when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations. We may disclose your personal information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests. We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process or share your personal information in the following situations:

• Business Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our organization to another party.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us, if any.
• Business Partners. We may share your personal information with our business partners to offer you certain products, services or promotions.
• Other Users. When you share personal information or otherwise interact with public areas of the Platform, such personal information may be viewed by all users and may be publicly made available outside the Platform in perpetuity. Similarly, other users may be able to view descriptions of your activity, communicate with you within the Platform, and view your profile depending upon the functionality of the Platform and how you choose to arrange your settings for the Platform.

INTERNATIONAL TRANSFERS

Our servers are located in the United States of America. If you are accessing the Platform from outside of the United States of America, please be aware that your personal information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see the section headed “DISCLOSURE OF PERSONAL INFORMATION” above), in the United States of America and other countries.

If you are a resident of a country other than the United States of America, including countries within the European Economic Area, then we may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

RETENTION OF PERSONAL INFORMATION

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than necessary.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

SECURITY

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your personal information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information. Although we will do our best to protect your personal information, transmission of personal information to and from the Platform is at your own risk. You should only access the Platform within a secure environment.

MINORS

We do not knowingly solicit personal information from or market to children under 18 years of age. By using the Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the corresponding account and take reasonable measures to promptly delete such data from our records. If you become aware of any personal information we may have collected from users under age 18, please contact us at privacy@nibbles.com.

THIRD PARTY WEBSITES

The Platform may contain links to third party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Platform, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot protect the safety and privacy of information that you provide to a third party outside of the Platform. Before visiting and providing any information to any third party websites or applications, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Platform.

YOUR PRIVACY RIGHTS

In some regions, you have certain rights under applicable data protection laws. These may include the right (a) to request access and obtain a copy of your personal information, (b) to request rectification or erasure of your personal information; (c) to restrict the processing of your personal information; and (d) if applicable, to data portability with respect to your personal information. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact information provided below. We will consider and act upon any verifiable request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions, requests or comments about your privacy rights, please email us at privacy@nibbles.com.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account; or
• Email us at help@nibbles.com

Upon your request to terminate your account, we will deactivate or delete your account and personal information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of the Platform. To opt-out of interest-based advertising by advertisers on the Platform visit http://www.aboutads.info/choices/.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list, however, we may still communicate with you, for example to send you Service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

• Note your preferences when you register an account with the Platform; or
• Email us at privacy@nibbles.com

DO-NOT-TRACK

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents applies solely to the personal information of individuals who reside in the State of California. We have provided this Privacy Notice for California Residents to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Your rights and choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and how you may exercise those rights.

• Access to Specific Information; Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: (a) the categories of personal information we collected about you; (b) the categories of sources for the personal information we collected about you; (c) our business or commercial purpose for collecting or selling that personal information; (d) the categories of third parties with whom we share that personal information, if any; (e) the specific pieces of personal information we collected about you (also called a data portability request); (f) if we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
• Deletion Request Rights. 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, we will delete (and direct our service providers, if any, to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (e) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (f) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (g) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) comply with a legal obligation; or (i) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Exercising Your Rights. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by email at privacy@nibbles.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable consumer request must: (a) provide sufficient information that allows us to reasonably verify that you are the individual about whom we collected personal information or that you are an authorized representative of that individual; and (b) describe your request with sufficient detail to allows us to properly understand, evaluate and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

• Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. 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.
• Non-Discrimination. We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Contact information

If you have any questions or comments about this Privacy Notice for California Residents, the ways in which we collect and use your information described in this Privacy Notice for California Residents, your choices and rights regarding such use or wish to exercise your rights under California law, please do not hesitate to contact us at privacy@nibbles.com

MODIFICATIONS

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Effective Date” and the updated version will be effective as of that date. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your personal information. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Services after the date such revised Privacy Policy is posted.

REVIEWING, UPDATING OR DELETING YOUR PERSONAL INFORMATION

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by contacting us as indicated in the section headed “HOW TO CONTACT US” below. We will respond to your request within 30 days.

HOW TO CONTACT US

If you have questions, requests or comments about this Privacy Policy please contact us at:

Nibbles PBC
750 N Saint Paul St Ste 250
#28647
Dallas, Texas 75201-3206
email: privacy@nibbles.com