SUPER SMALLS PRIVACY POLICY
 
Last Updated: March 20, 2023
 
Introduction
Super Smalls Inc. (“Super Smalls,” “Company,” “we” or “us”) is committed to protecting your privacy. The following policy (“Privacy Policy”) describes our practices for collecting, using, maintaining, and disclosing information that we collect from you or that you provide to us when you visit our website, https://supersmalls.com/ (our “Site”), or use any other products and services made available by us (collectively with the Site, the “Services”).

We ask that you read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. The use of information collected through our Services will be limited to the purposes described under this Privacy Policy and our Terms of Service (or other relevant customer contracts). By accessing or using the Services, you agree to this Privacy Policy. Please be aware that if you are using the Services on behalf of an entity, you are agreeing to this Privacy Policy for that entity and are representing to us that you have the authority to do so (in which case “you” will refer to that entity). If you do not agree with our policies and practices, your choice is not to use the Services.

This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and indicate at the top of this page the date the policy was last revised. We will also notify you of any material changes either through a pop-up notice, email or through other reasonable means. Any such changes are effective immediately when we post them, and apply to all access to and use of the Services thereafter. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new policy.

Information We Collect and How We Collect Information
This policy sets out what personal data we might collect, how we process and protect that data and the lawful grounds for that processing.  In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to grow and improve our Services, provided those interests are not outweighed by your rights and interests (“Legitimate Interests”), (ii) is necessary to perform a contract with you (“Contract”), or (iii) we have a legal obligation to carry out the processing (“Legal Obligation”).  Where processing is based on your consent (“Consent”), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent. 

Information You Provide
We may collect information you provide directly via the Services. We may ask you to provide some or all of the following types of information when you use our Services, submit comments and other content, order products, or directly contact us with questions or feedback:

  • Your name
  • Your telephone number
  • Your billing and shipping address
  • Your email address

The information you provide may include Personal Information.  “Personal Information” is information that identifies you personally (whether one its own or in combination with other information).

If you purchase our products, you may be required to provide financial information, such as your credit card or bank account number, to a third-party payment processor such as ShopPay, AmazonPay, PayPal, Google Pay and Afterpay.  We do not collect or store any financial information that you provide to such third-party payment processors and we are not responsible for the collection or storage of such information by third parties.  We will, however, have access to certain information associated with your account should you purchase the Services, including the amount and date of the purchase.

Information We Automatically Collect
We may also collect certain information automatically when you visit the Services, including:

  • Your browser type and operating system
  • Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area
  • Geolocation information
  • Websites or search terms that referred you to the Site
  • Pages you view and links you click on within the Services
  • Information collected through cookies, web beacons, and other technologies
  • Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded

We collect the above information in a variety of ways, including by “pixel tags,” “log files,” “web beacons,” “cookies” and other technologies to automatically collect information.   

  • Cookies are small bits of information that are stored by your computer’s browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services. For more information about cookies, and how to disable cookies, visit HTTP://WWW.ALLABOUTCOOKIES.ORG.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

Third-Party Information Collection
We may allow third parties to place and read their own cookies, web beacons, and other technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information (i) that helps us with traffic measurement, research, and analytics, and (ii) that provides content, advertising or other functionalities on behalf of Super Smalls.

The information collected and stored by third parties remains subject to their policies and practices. We do not control these third parties’ tracking technologies or how they may be used.

We currently use the services of the following third-party vendors, who may collect your information.  You can click on the hyperlinks below to view their privacy policies.

  • Google Analytics (website analytics): https://policies.google.com/technologies/partner-sites
  • Shopify (e-commerce): https://www.shopify.com/legal/privacy
  • Klaviyo (sign up forms): https://www.klaviyo.com/privacy
  • Conjured Referals (refer-a-friend): https://conjured.co/referrals-privacy
  • Zestard (gift wrap): https://www.zestard.com/privacy-policy/
  • Secomapp (e-commerce): https://www.secomapp.com/privacy-policy/
  • Simplistic (e-commerce): https://simplistic.com/pages/privacy-policy

How We Use Your Information
We acquire, hold, use, and process information that we collect about you or that you provide to us, including Personal Information, for numerous business purposes, including:

  • Fulfilling requests and orders placed through the Site or offline, including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations
  • Screening our orders for potential fraud or risk
  • Communicating with you directly about the Services or an order or inquiry you have made
  • Allowing you to register for events
  • Generally managing individual information and accounts
  • Measuring usage of the Services, analyzing the effectiveness of our Services, conducting research, surveys and improving and enhancing functionality of the Services
  • Providing support for the Services and respond to requests and inquiries
  • Marketing and advertising the Services to you, including by sending you, directly or in partnership with other parties, promotional e-mail and/or text messages and by displaying our advertisements on other websites that you visit or use
  • Offering you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you
  • Sharing content with people whose email addresses you provide to us (such email addresses are not otherwise used by Super Smalls or any other third parties for any other purpose)
Choices About How We Collect, Use and Disclose Your Information

We strive to provide you with choices regarding our collection, use and disclosure of the information you provide to us. The mechanisms listed below aim to provide you with control over such collection, use and disclosure:

  • Marketing Communications. If you do not want us to send you marketing or promotional communications, you can opt-out by clicking the “unsubscribe” link in any such promotional emails, checking the relevant box located on the form on which we collect your data, by texting “STOP” to 1-833-257-0582 or emailing us at hello@supersmalls.com.  If you unsubscribe from our marketing communications we may continue to contact you regarding our Site and Services and to respond to your requests.
  • You can disable cookies at any time through the settings in your web browser. However, if you choose to disable cookies, your experience of our Site and use of the Services may be limited.
  • Google Analytics. You can opt out of tracking by Google Analytics by using Google’s Ads Settings or going to https://tools.google.com/dlpage/gaoptout/. You may also opt out of Google marketing products, but please note that this does not opt you out of being served generic ads.
  • Third-Party Advertising. If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web advertisements, you may visit the following websites: http://www.networkadvertising.org/choices/or http://www.aboutads.info/choices/. These opt-out tools are provided by third parties. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

As described above, we use Personal Information to provide customers and potential customers with targeted advertisements or marketing communications we believe may be of interest to them. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at HTTP://WWW.NETWORKADVERTISING.ORG/UNDERSTANDING-ONLINE-ADVERTISING/HOW-DOES-IT-WORK. You can opt out of targeted advertising by using the links below:

  • Facebook: HTTPS://WWW.FACEBOOK.COM/SETTINGS/?TAB=ADS
  • Google: HTTPS://WWW.GOOGLE.COM/SETTINGS/ADS/ANONYMOUS
  • Bing: HTTPS://ADVERTISE.BINGADS.MICROSOFT.COM/EN-US/RESOURCES/POLICIES/PERSONALIZED-ADS
  • Pinterest: HTTPS://HELP.PINTEREST.COM/EN/ARTICLES/WHAT-ARE-PROMOTED-PINS

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: HTTP://OPTOUT.ABOUTADS.INFO/.

Disclosure of Your Information

We want you to understand when and with whom we may share the information we collect.  Information submitted by you will be transmitted to and shared with third parties, including third parties who may be located in other countries, in order to provide the Services (including but not limited to transaction processing and fraud prevention). We also may disclose information that we collect through the Services with third parties as follows:

  • Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host the Services, manage databases, host a store or other e-commerce platform, perform analyses, or conduct surveys.
  • Other Parties When Required By Law or as Necessary to Protect the Services. We may disclose your information to third parties in order to protect the legal rights, safety, and security of Super Smalls and the users of our Services; enforce our Terms of Service; prevent fraud; and comply with or respond to law enforcement or a legal process or a request for cooperation by a government or other entity, whether or not legally required.
  • In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
  • Other Parties With Your Consent. We may share information about you with other third parties when you consent to such sharing.
  • Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

You will be notified via email and/or a notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Social Networking Services
The Services may allow you to post information to various third-party services or platforms, such as social networking services like Instagram, Twitter and Facebook.  You acknowledge that if you choose to use this feature, your friends, followers and subscribers on these third-party services or platforms will be able to view such activity.  If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.  The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.

Links to Third-Party Sites and Services
The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by Super Smalls.  Such links do not constitute an endorsement by Super Smalls of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

Do Not Track Signals
Third parties may keep track of your browsing activities across third party websites. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know we respond to “Do Not Track” browser signals. Certain web browsers enable users to activate a “Do Not Track” signal but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.

Data Retention
We strive to keep your information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements. If you close your account, we will retain certain data for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Services or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

You acknowledge that Super Smalls may establish general practices and limits concerning use of the Services, including the maximum storage space that will be allotted on Super Smalls’ servers on your behalf. You further acknowledge that Super Smalls reserves the right to change these general practices and limits at any time, in its sole discretion. We will endeavor to give you notice of any such change where required by applicable law. 

Accessing and Correcting Your Information
If you wish to access, update, correct or delete any Personal Information in our possession that you have previously submitted via the Services, you may log into your account and make updates. If you wish to make changes not available through your account settings, please contact us at hello@supersmalls.com.

Security
We take reasonable steps to protect the Personal Information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In the event that personal information is compromised as a breach of security, Super Smalls will promptly notify our customers in compliance with applicable law.


Children Under the Age of 13
Our Services are intended for users who are 13 years of age and older. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 13, please contact us at hello@supersmalls.com.

Transfer of Information to the United States and Other Countries
Super Smalls is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your Personal Information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own. 


Additional Disclosures for Individuals in California
The California Consumer Privacy Act (“CCPA”) requires us to explain some information using certain definitions and categories. If you reside in California, this section applies to you and describes our data practices today and in the preceding 12 months.

Additional Disclosures

The chart below summarizes the personal information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. For more information about the specific data points we collect and the sources of such collection, please see the Information We Collect and How We Collect Information section above. 

We collect Personal Information for the business and commercial purposes described in the Information We Collect and How We Collect Information section above. 

Category of Personal Information

Categories of Recipients

Identifiers

  • Contact data
  • Device data

 

  • Affiliates
  • Service providers
  • Customers
  • Linked third-party services
  • Professional advisors
  • Authorities and others
  • Business transferees
  • With your consent

Inferences

May be derived from: 

  • Contact data
  • Communications
  • Transactional data
  • Marketing data
  • Promotional information
  • Device data
  • Online activity data

 

  • Affiliates
  • Service providers
  • Customers
  • Linked third-party services
  • Professional advisors
  • Authorities and others
  • Business transferees
  • With your consent

Internet or other electronic network activity information

  • Marketing data
  • Device data
  • Online activity data
  • Location data

 

  • Affiliates
  • Service providers
  • Customers
  • Linked third-party services
  • Professional advisors
  • Authorities and others
  • Business transferees
  • With your consent 

Geolocation data

  • Location data

 

  • Affiliates
  • Service providers
  • Customers
  • Linked third-party services
  • Professional advisors
  • Authorities and others
  • Business transferees
  • With your consent

 

We do not use or disclose sensitive Personal Information for the purpose of inferring characteristics about you.

We do not knowingly sell or share Personal Information about consumers under the age of 16.

Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at hello@supersmalls.com.
 
Additional Disclosures for Individuals in Europe
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing
When we process your Personal Information as described above, we do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
  • When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
  • When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your Personal Information, you may withdraw such consent at any time.

Data Subject Requests
Please see the Choices About How We Collect, Use and Disclose Your Information section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please contact us at hello@supersmalls.com.

If you have a concern about our processing of Personal Information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Contact Information
If you have any questions about this Privacy Policy, please contact us at hello@supersmalls.com.