Privacy Policy

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Introduction
Kitty’s Co. (“Kitty’s Co.”, “we”, “us”) is committed to protecting privacy and personal information. We make www.kittys.co (the “Website”) and our online targeted advertising services available to online vendors (“Vendors”, “Clients”), as further described in our Terms of Service (the “Services”). In order to provide Services, we must collect certain personal information from our Clients’ Customers (“Customers”). This Privacy Policy describes how we collect, store, use and distribute personal information about our Clients’ Customers collected through our Clients’ use of our Services.

By using our Website or our Services, you consent to the use of Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, Personal Information will not be used for any other purpose without a Customer’s consent. Subject to the terms of the Services we provide and the disclosures we make to Vendors in connections with such Services, we do not actively collect Personal Information for the purpose of sales or marketing in any way that specifically identifies the individual. Customers may withdraw their consent to our processing of their Personal Information at any time. However, withdrawing consent may result in the inability to continue using our Clients’ websites or online sales venues. Vendors may also withdraw their consent to our collection of their Customers’ personal information at any time, however, this may affection a Vendor’s ability to continue using the Services. It is a condition of receiving our Services that Vendors disclose to Customers in their own privacy policies their use of cookies and tracking pixels, and Vendors are responsible for obtaining consent from Customers so that we may collect any such Personal Information.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Kitty’s Co. collects and processes your personal data through your use of this website (which includes the domain https://www.kittys.co/ and all related subdomains), including any data you may provide through this website when you [sign up to our newsletter, purchase a product or service or take part in a competition].

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER
9441999 Canada Inc. (Trading Name “Kitty’s Co.”) is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

CONTACT DETAILS
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our company details are:
Full name of legal entity: 9441999 Canada Inc.
Registered Company Address: 2506-224 King St W, Toronto ON, M5H0A6, Canada.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, job title and company
Contact Data includes billing address, delivery address, email address and telephone numbers
Transaction Data includes details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes downloads, purchases or requests made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for or use our products or services;
- subscribe to our service or publications;
- request marketing or content to be sent to you;
- attend one of our events or meet us at an event hosted by a third party
- correspond with our Sales or Customer Success teams
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google.
Identity and Contact Data from data brokers or aggregators such as Zoominfo.

HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground, we are relying on to process your personal data.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside the Kitty’s Co. for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see refer to our Cookie Policy.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

Companies that we work with or partner with to deliver our content, services or events to you, such as ticketing companies, payment service providers, events companies, delivery companies and catering companies.
Professional services and technology providers such as marketing agencies, advertising partners, website and landing page hosts and marketing and sales technology companies, such as CRM or Marketing Automation tools, who help us run our business.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud
Companies approved by you, such as social media sites (if you choose to link your accounts to us)

We may provide third parties with aggregated but anonymized information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

Our servers are also located in the United States, and accordingly Customer Personal Information may be available to Canadian and United States governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

From time to time, we may employ third parties to help us improve the Services. These third parties may have limited access to databases of Customer information solely for the purpose of helping us to improve the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

IMPORTANT EXCEPTIONS

We may disclose Personal Information to third parties without consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Customers, our Clients, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The security of our Clients’ Customers’ Personal Information is important to us. We use commercially reasonable efforts to store and maintain Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us, including the use of firewalls and data encryption. We have implemented procedures designed to limit the dissemination of Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We will keep Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

COLLECTION OF INFORMATION

We aim to collect, use and disclose only such information as is required to enable us to provide the Services to our Clients (including providing information to our Clients about online behaviors) to respond to Customer inquiries about our Services or provide feedback, and for service improvement. We will maintain the confidentiality of any personal information we collect in connection with the Services, and only use and disclose Customer personal information for the purposes for which we have collected it, and to the particular Vendor who has purchased our Services (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through our Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance (such as a telephone book); or (b) Non-Personal Information (as defined in the Glossary).

USE OF INFORMATION

We collect, use and disclose information for the following purposes:

Services: In order to provide the Services to our Clients, we track our Clients’ Customer’s online behavior. For example, we collect information about the products Customers or potential customers view, the time of day a purchase is made, the value of the purchase, the products that are purchased, IP address, and location information associated with that IP address. We also track any purchases that are made as a result of a Customer clicking on a targeted advertisement that We serve to that Customer via their Facebook account. We track which Customers come to a Vendor’s website from a targeted ad on Facebook by tracking the URL. We will provide this information to the Vendors subscribing to our Services, as well as to create targeted advertising campaigns on behalf of Vendors, which we serve to Customers via their Facebook accounts.

Statistics: We also collect statistics on behalf of our Clients about the use of their website. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to third parties.
System Logs & Cookies: We provide the Services to our Clients through the use of cookies and tracking pixels. Our Clients place the tracking pixels and/or cookies on their website, to track Customer actions on their website. A cookie is a feature of your web browser that consists of a text file that is placed on your computer by a web server and a tracking pixel is a piece of code that tracks user behavior on a website. We use cookies and tracking pixels to help compile aggregate statistics about usage of our Clients’ websites, such as how many users visit our Clients’ websites, what products are viewed, what products are purchased, whether the Customer came to the website as a result of clicking on one of our targeted Facebook advertisements, how long users spend viewing our Clients’ websites, time and value of purchases, product purchases and what pages are viewed most often. We provide this information to our Clients. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of our Clients’ websites.
Advertisements: In addition to providing tracking services, we use the information we collect to serve targeted advertising to Customers on behalf of our Clients. We serve such advertisements via a Customer’s Facebook account using the Facebook Marketing API. These third party web advertisers may set cookies. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you. The Privacy Policy applies to cookies placed on your computer by us, but does not cover the use of cookies by any third-party web advertisers. For the privacy practices of such third-party web advertisers, you should consult the applicable privacy policy for the relevant third-party web advertiser(s).

If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled ‘Amendments of this Policy’.

YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are outlined in the Glossary below.

If you wish to exercise any of the rights set out in the Glossary, please contact us.

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
Lawful basis. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

AMENDMENTS

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page at www.kittys.co. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about any individual. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.

ACCESS & ACCURACY

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another individual. In such circumstances we will provide reasons for the denial upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personal Information is personally identifiable information, such as your name, address, e-mail address, credit card information, birth date and gender. At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or be able to access and use the Website at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website. We collect Personal Information about our Clients’ Customers when they use our Clients’ websites, as well as information we collect from our partners.

Non-Personal Information is information of an anonymous nature, such as an Internet Protocol Address (IP Address) if it has been stripped of personal information, the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the website. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website is not considered Personal Information. Similarly, business contact information such as the name, title, business address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.

Although the use of certain Non-Personal Information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information for the sake of transparency with respect to the operation of the Website. Such Non-Personal Information is collected or derived by us in the course of operating this Website. For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you choose to visit the Website.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions if you find any errors in our information about you, please contact us at: privacy@kittys.co.

Last update February 24th 2021.

Kitty's Co.

Privacy Policy

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