The Little Leaders Company, LLC
Privacy Policy
(This Privacy Policy has been updated and is effective as of January 16, 2019.)
This is the privacy policy (the “Privacy Policy”) for those web sites (each a “Site” and together the “Sites”) to which this Privacy Policy is linked and identified as such web site’s privacy policy and which are operated by the Little Leaders Company, LLC (“Little Leaders,” “we,” “us” or “our”) on its own behalf or on behalf of its Affiliates. The web site that you are visiting now and to which this Privacy Policy applies may be referred to herein as “this Site” or “the Site.” The Privacy Policy governs how Little Leaders uses, collects and discloses the information gathered from or provided by users of this Site located in the United States, Mexico and Canada. “Affiliates” shall be those entities that control, are controlled by or are under common control with, Little Leaders.
This Privacy Policy should be read in conjunction with this Site’s Terms of Use , which is incorporated herein by reference. Capitalized terms used and not otherwise defined in this Privacy Policy shall have the meaning given to them in the Terms of Use.
1. Use by Users Outside the United States
This Site is intended for use only by users located in the United States, Canada and Mexico. If you are located outside of the United States (other than for users located in Canada and Mexico) you are consenting to the transfer and/or transmission of your information into the United States and to the collection, use and disclosure of your information in accordance with this Privacy Policy. You are also acknowledging that the laws of the jurisdiction in which the information is kept will determine the protections afforded to your personal information, and that such protections may not be as strict as your home jurisdiction. Little Leaders stores and processes the personal information it gathers through your use of the Site in the United States. If you are located within the European Union and you submit any information deemed Personal Data under the General Data Protection Regulation (“GDPR”) your submission is voluntary, with your express consent to use Personal Data for the purpose submitted, at your own risk, and subject to the laws of the United States.
If you are located in Canada, then the terms of this Privacy Policy, as amended and supplemented by the Canadian Privacy Policy Statement, govern your use of this Site.
If you are located in Mexico, then the terms of the Privacy Policy, as amended and supplemented by the Mexico Privacy Notice, govern your use of this Site.
2. Agreement and your consent.
Please read this Privacy Policy carefully; it creates legal obligations. By using the Site, you are acknowledging that you have read and understand this Privacy Policy, you are agreeing to be legally bound by it, and you are consenting to the use, collection and disclosure of your information as provided in this Privacy Policy.
If you do not agree with all of the terms of this Privacy Policy, you should not use the Site.
3. Scope of Policy
This Privacy Policy applies only to information we gather from you or that you provide to us online while visiting or using the Site. It does not apply to information gathered from or provided by you to us through other sites, offline, through other business arrangements with you, or through other means.
4. The Information We Collect
The Site offers business information about Little Leaders and its Affiliates.
The type of information we collect from users of the Site includes information by which an individual may be identified (“personal information”) such as their first and last name, email address, address, and telephone number. We also collect business information from users, and information by which users cannot be individually identified, such as information about a user’s computer, Internet connection and Site usage.
We collect this information when you directly provide it to us, such as if you request information through the Site, register on the Site, sign up for a service through the Site, provide us with suggestions through the Site, post User Posted Content to the Site, or if you send us information via email through the Site. We will do our best to clearly identify when information is being collected and the purpose for which it is being collected. When appropriate we may ask you for your affirmative consent to provide us with personal information. However, we do not guarantee that affirmative consent will be requested from each user of the Site. IF YOU DO NOT WANT US TO COLLECT PERSONAL INFORMATION FROM YOU, DO NOT PROVIDE IT TO US.
We also collect information automatically as users navigate through the Site, including about a user’s browsing actions and patterns, including as follows:
We record general statistical and tracking information, such as the date and time the Site is accessed, the places visited on the Site, and the time spent using the Site.
We receive and record information about a user’s computer and its systems and in our server logs from a user’s browser, including an IP address (the Internet address of a computer), identification of the computer and its systems, the type and version of the web browser, referrer addresses and other server log information.
We use cookies and other tracking mechanisms to recognize when users return to the Site. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to a user’s browser from a site’s computers and stored on a user’s computer’s hard drive. With respect to most computer systems, you may set your browser so that it does not accept cookies. If you do disable the use of cookies, you may not be able to use or experience all of the features of our Site.
Cookies used by this Site do not collect Personal Data (as defined under the GDPR), but if you have any concerns whatsoever over our use of Cookies, do not use the Site, or be sure to set your browser so that it does not accept cookies.
We also may, but are not obligated to, monitor your use of the Site.
At no time do we have access to any personal financial information such as credit card numbers, bank accounts, etc. All payments on the Site are consummated directly with Stripe or PayPal. Little Leaders has no formal business relationship with Stripe or PayPal. At no time does any Little Leaders employee or employees of our affiliates have access to the login information for members of the Site.
5. Our Use and Disclosure of this Information
This Site is for use within the United States, Canada and Mexico. If you are accessing the Site from the European Union, this Site is not intended for your use. We may use the information that we collect about you or that you provide to us as set forth above, including your personal information, as follows:
For any Little Leaders and/or its Affiliates’ business purpose;
To provide you with the information, products and services that you request from us;
To fulfill any other purpose for which you provide the information to us;
To notify you about changes in the Site, its governing documents, or any products or services we offer through the Site;
To allow you to participate in interactive sections of the Site;
To inform you about our and/or our Affiliates’ programs, goods and services and/or those of third parties in which we determine you may be interested;
To communicate with you about your use of the Site and regarding Little Leaders and its Affiliates’ business;
For any other purpose to which you consent;
In any other way we may describe when you provide the information; and
To aggregate user information.
We may also use and disclose to others the information we gather from you, including your personal information, as follows:
To fulfill the purpose for which you provide the information, for any other purpose disclosed when you provide the information, and for any purpose to which you consent.
We may disclose your information to Affiliates of Little Leaders and allow them to use and disclose your information for any Little Leaders and/or its Affiliates’ business purpose.
We may employ other companies, services providers and our own Affiliates to perform functions on Little Leaders’ behalf, such as maintaining the Site, providing services related to the Site, collecting information, responding to and sending electronic mail, fulfilling orders for products, services or information, or other functions necessary to our business, and we may disclose your information to these companies so that they can perform their functions for us.
We may use and disclose your information as we view necessary or prudent to protect our and our Affiliates’ safety, rights and/or property and that of others and other users, to enforce and/or to report abuse or violation of the Site’s governing documents, and in connection with our obligations under the U.S. Digital Millennium Copyright Act (“DMCA”).
We may use and disclose your information to carry out our obligations and enforce our rights arising from any contracts entered into between you and us and/or our Affiliates.
We may use and disclose your information to the extent we believe we are required to do so by law, including to comply with any court order, law or legal process, and to respond to any government or regulatory request;
We may transfer and disclose your information in connection with a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the assets of Little Leaders and/or one of its Affiliates, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the information held by Little Leaders and/or the Affiliate is among the assets transferred.
We will dispose of your personal information when it is no longer useful for the purposes for which it was provided to us by you.
Except as provided in this Privacy Policy, we will not disclose your personal information to unaffiliated third parties without your express consent.
We may compile statistical and aggregated information about users of the Site and their use of the Site, and we may use, disclose and transfer this information, as well as any information that does not identify an individual, and any Suggestions you provide, for any purpose without restriction.
6. Security
We have put in place security systems designed to prevent unauthorized disclosure of information you provide to us. These systems are structured to deter and prevent hackers and others from accessing this information. Due to the nature of Internet communications and evolving technologies, however, we cannot provide, and we hereby disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
With respect to some services we provide customers, we may expressly agree at the time such services are requested to provide different, specific and higher levels of security and data segregation. In addition, in particular circumstances, when you submit certain information to us through this Site, we may agree in connection with such information to provide additional protections to, and restrictions upon our use of, your personal information.
7. Relationship to Other Contracts
The terms of this Privacy Policy do not affect or amend the terms of any specific contracts you have entered or may enter into with Little Leaders or its Affiliates, and your and Little Leaders’ (or its Affiliates’) respective obligations thereunder, except as otherwise expressly set forth in such contract.
8. Children
The Site is not directed to or intended to be used by persons under the age of 18, and Little Leaders does not knowingly collect personal information from persons under the age of 18. If we learn that a person under 18 has provided us with personal information through this Site, we will delete this information from our databases.
9. Update Your Personal Information.
By agreeing to this Privacy Policy, you are agreeing to keep your contact information or other personal information we maintain up to date. If your contact information or other personal information that you have provided to us through the Site needs to be updated, please promptly contact us at admin@golittleleaders.com and provide sufficient information so that we can properly update your information.
10. Changes to this Privacy Policy.
From time to time, Little Leaders may change its Privacy Policy. We will post a notice of such changes for thirty days after the date of such change, which notice will be accessible from the Privacy Policy link on our Site or may appear on the home page of the Site. Your use of the Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed, and to its application to all information gathered before and after its effective date.
11. Contact Us
Questions, comments or requests related to your use of the Site, regarding this Privacy Policy, and Little Leaders’ information handling policies and procedures should be submitted to Little Leaders’ communications department by mail or e-mail as follows:
By mail: The Little Leaders Company, LLC, Attn: Communications, 2501 Brockman Boulevard, Ann Arbor, Michigan 48104
By e-mail: admin@golittleleaders.com
CANADA PRIVACY STATEMENT
(This Policy Statement was last updated January 16, 2019)
If you are Canadian, this privacy statement may apply to you.
The Little Leaders Company, LLC (“Little Leaders”) recognizes the importance of protecting personal information in a manner consistent with the laws of the countries in which it does business. This Policy Statement (the “Statement”) sets forth the particular privacy principles that Little Leaders follows with respect to the personal information that it collects from Canadians. This Statement operates in conjunction with the Little Leaders Privacy Policy, available herein. To the extent that this Statement and the Little Leaders Privacy Policy are inconsistent, this Statement will govern the collection, use and disclosure of personal information collected from Canadians.
1. SCOPE
This Statement applies to all personal information received by Little Leaders from Canada, in any format, including electronic, paper or verbal.
2. DEFINITIONS
For purposes of this Statement only, the following definitions shall apply:
“Agent” means any party that collects or uses personal information under the instructions of, and solely for, Little Leaders, or as to which Little Leaders discloses personal information for use on Little Leaders’ behalf.
“Little Leaders” means the Little Leaders Company, LLC.
“Personal information” means any personally identifiable information. Personal information does not include information that is anonymized.
3. PRIVACY PRINCIPLES
CONSENT, COLLECTION AND USE
Little Leaders identifies the purposes for collecting personal information at or before the time it is collected and informs individuals of the choice and means, if any, Little Leaders offers individuals for limiting the collection, use or disclosure of their personal information. Little Leaders will provide individuals with reasonable mechanisms to exercise these choices.
Little Leaders will not collect, use or disclose your personal information without your informed consent, unless required or permitted to do so by law, or unless otherwise noted in this Statement.
Little Leaders will only use and/or disclose personal information in accordance with the purpose for which it was collected, unless subsequently consented to, or when required or permitted by law.
If Little Leaders receives personal information from its subsidiaries, affiliates or other entities in Canada, it will use and disclose such information in accordance with the consent received by such entities at the time of collection and the choices made by the individuals to whom such personal information relates.
ONWARD TRANSFERS
Little Leaders will obtain assurances from its Agents and any third party to whom Little Leaders discloses personal information that such Agent and/or third party will safeguard personal information consistently with this Statement. Little Leaders will enter into a contract with such Agent and/or third party prior to affecting a transfer of personal information, which contract will provide at least the same level of protection as is required by this Statement and by applicable privacy legislation. Where Little Leaders has knowledge that an Agent and/or third party is using or disclosing personal information in a manner contrary to this Statement, Little Leaders will take reasonable steps to prevent or stop the use or disclosure of the personal information and/or to obtain the Agent’s and/or third party’s deletion, destruction, anonymization or return of the personal information.
SECURITY
Little Leaders will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, use, disclosure, alteration and destruction.
DATA INTEGRITY
Little Leaders will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Little Leaders will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. Except as otherwise permitted or required by law, personal information is retained for so long as is reasonably necessary to fulfill the purposes for which it was collected, at which point it is deleted, destroyed, returned or otherwise anonymized.
ACCESS
Upon request, Little Leaders will grant individuals reasonable access to personal information that it holds about them. In addition, Little Leaders will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting Little Leaders as provided below.
ENFORCEMENT
Little Leaders will conduct compliance audits of its relevant privacy practices to verify adherence to this Statement. Little Leaders will use contractual or other means to ensure that its Agents provide a comparable level of protection over your personal information while the information is being processed by such parties.
Only employees whose duties require access to personal information are granted such access, and only to the extent necessary. Employees are accountable for ensuring this Statement is followed at all times. Any employee that Little Leaders determines intentionally violates this Statement will be subject to disciplinary action up to and including termination of employment.
4. RELATIONSHIP TO OTHER CONTRACTS
The terms of this Privacy Statement do not affect or amend the terms of any specific contract(s) you have entered or may enter into with Little Leaders or its Affiliates, and your and Little Leaders’ (or its Affiliates’) respective obligations thereunder, except as otherwise expressly set forth in such contract(s).
5. GOVERNING LAW AND DISPUTE RESOLUTION
This Statement, and the handling of personal information under this Statement, is governed solely by the laws of the Province of Ontario, Canada and the federal laws of Canada applicable therein, to the exclusion of any rules of private international law or conflict of laws which would lead to the application of any other laws.
Little Leaders is based in the state of Michigan in the United States. As a result, personal information may be processed, used, stored or accessed in the United States and may be subject to laws of that jurisdiction. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. In particular, information that is processed, used, stored or accessed in the United States may be subject to the Patriot Act and applicable anti-terrorism legislation, together with other legislation applicable within the United States.
Any questions or concerns regarding the use or disclosure of personal information should be directed to Little Leaders at the address given below. Little Leaders will investigate and attempt to resolve complaints and disputes regarding collection, use and disclosure of personal information in accordance with the principles contained in this Statement.
Any claim or cause of action you may have arising from, connected with, or relating to this Statement or to Little Leaders’ handling of your personal information, or any related matters must be commenced within six (6) months after the claim or cause of action arises, after which time the claim or cause of action is forever barred, regardless of any statute or law to the contrary.
6. CONTACT INFORMATION
Questions, comments or requests related to your use of the Site, regarding this Statement, and Little Leaders’ information handling policies and procedures should be submitted to Little Leaders’ communications department by mail or e-mail as follows:
By mail: Little Leaders Company, LLC, Attn: Communications, 2501 Brockman Boulevard, Ann Arbor, Michigan 48104
By e-mail: admin@golittleleaders.com
7. CHANGES TO THIS STATEMENT
Any changes to this Statement and to Little Leaders’ information handling practices will be acknowledged in this Statement in a timely manner. Little Leaders may add, modify or remove portions of this Statement when it feels that it is appropriate to do so. For substantive changes, Little Leaders will make reasonable efforts to give notice of any changes to this Statement. Little Leaders may provide notifications of substantive changes prominently on its website and/or send an email or other form of communication notifying individuals of substantive changes to the Statement. Substantive changes to the Statement will be binding thirty (30) days after such changes have been introduced and for which notification of such substantive changes has been made. The date when this Statement was most recently amended is noted at the top of this Statement.
MEXICO – PRIVACY NOTICE
(This Policy Notice was last updated on January 16, 2019)
The Little Leaders Company, LLC. (“Little Leaders”) recognizes the importance of protecting personal data in accordance with the laws of Mexico. This Privacy Notice sets forth how we collect, use and process personal data in numeric, alphabetical, graphic, photographic, acoustic or any other form concerning an identified or identifiable individual (“Personal Data”). The items contained in this Privacy Notice are required by the Mexican Federal Law on the Protection of Personal Data Held by Private Parties (“Data Protection Law”), its regulation and other applicable provisions.
Little Leaders is considered the “Data Controller” pursuant to the Data Protection Law.
We will not collect financial, property or sensitive data from you without your express consent. Sensitive data is information related with state of health, medical history, impairments, medical requirements, allergies, results of psychometric tests, gender, marital status, bank accounts, records and affiliations.
When express consent is required, we will provide you with a simple and free-of-charge means of providing express consent.
If you have a legal relationship with Little Leaders, your express consent is not required for processing financial, property or other Persona Data as strictly required by for the relationship.
We will not use your Personal Data for any purpose not described in our Privacy Policy.
You may revoke your express consent for the use of your Personal Data at any time by contacting us at admin@golittleleaders.com and providing sufficient information so that we can comply with your request. In any case, said application must clearly detail the data or purposes for which your consent is revoked.
Your use of this Site provides consent (tacit or express) for the collection of Personal Data through the technology means discussed in the Privacy Policy. If you do not consent to collection of Personal Data through your use of the Site, DO NOT USE THE SITE.
The Personal Data collected is minimally necessary to provide you with useful information through access to the Site.
Your Personal Data may be transferred to third parties or outside of Mexico to offer you goods or services in accordance with your use of the Site.
Your consent is not necessary when transfers are done to Little Leaders´ Affiliates, when transfers are necessary to comply with the obligations derived from the relationship with Little Leaders.
This Privacy Notice does not apply to corporations or individuals accessing the Site as businessmen and woman and professionals.
If Personal Data is collected by technology means (as described in the Privacy Policy) it is presumed to comply with the Quality Principle of the Data Protection Law, until such time as you declare and prove otherwise.
We will retain your Personal Data only as long as necessary to facilitate your use of the Site or services related to the Site.
Questions, comments or requests related to your use of the Site, regarding this Privacy Notice, and Little Leaders’ information handling policies and procedures should be submitted to Little Leaders’ communications department by mail or e-mail as follows:
By mail: Little Leaders Company, LLC, Attn: Communications, 2501 Brockman Boulevard, Ann Arbor, Michigan 48104
By e-mail: admin@golittleleaders.com