#The EU-US Privacy Shield has been held to be an invalid way of transferring EU personal data to the US. Please note that Little Ones is currently reviewing its processing activities with suppliers who relied on the EU-US Privacy Shield for international transfers. It will update this policy about that as applicable in due course#
This website is not intended for children and we do not knowingly collect data relating to identifiable children. We recommend that you anonymise any data about your children which you might provide to us as part of using our online services or purchasing our products. Where you wish to post photographs or videos of your children on our online applications or social media channels we may seek your consent on behalf of your child before you do so.
Full name of legal entity: Little Ones 2015 Limited
Postal address: Private Bag 93504, Takapuna, Auckland, New Zealand 0740
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the relevant regulator in your jurisdiction which is subject to the GDPR. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or any other regulator so please contact us in the first instance.
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.
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, or as applicable and as provided by you, your children, which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you or your children (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). This is with the potential exception of any applicable health related data which you may decide is relevant to provide us when purchasing our products or in comments posted on our site or via our forum or social media feeds. To confirm, we do not require nor request any such health data from you and you therefore choose to provide that to us and which we then process to perform the contract between us, for our mutual legitimate interests or some other lawful basis as may be set out below. We do not 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.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Marketing and Communications and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below Technical Data from the following parties:
Contact, Financial and Transaction Data from independent providers of technical, payment and delivery services such as PayPal and Stripe, which might be based both inside and outside the EU..
Identity and Contact Data from data brokers or aggregators [such as Mailshark based outside the EU]..
Identity and Contact Data from publicly available sources such as social media accounts through which you choose to engage with us..
Comments Data is collected internally at Little Ones, if at all.
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:
Please see the additional explanation of LAWFUL BASIS at the Glossary in section 10 to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||a) Identity|
|Performance of a contract with you|
|To process and deliver your order including:|
1. Mange transactions and which may involve you providing data about your children
2. Send out your purchased product
3. Collect and recover money owed to us
e) Marketing & Communications
|a) Performance of a contract with you|
b) Necessary for our legitimate interests (to recover debts due to us)
c) Your consent on behalf of your child where you provide their personal data
|To manage our relationship with you which will include:|
b) Asking you to leave a review or take a survey or responding to your comments on such reviews and surveys
c) Engaging with you on our social media channels and other online applications and forum and which may involve you providing data about your children, including image data
d) contacting individuals at our relevant service providers in the EEA to perform services and discuss services
e) discussions with individuals at our business to business contacts and internal discussions about their performance
d) Marketing & Communications
e) Comments data
|a) Performance of a contract with you (or your business if you are an individual at our EEA service providers)|
b) Necessary to comply with a legal obligation
c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and to enable proper use by us and you of our social media and online applications, to develop them and grow our business and to respond to reviews (negative or positive) in the interests of our business and customers and to enable discussion within the business about the performance of our service providers)
d) Your consent on behalf of your child where you provide their personal data
|To enable you to partake in a prize draw, competition or complete a survey||a) Identity|
e) Marketing & Communications
|a) Performance of a contract with you|
b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a) Identity|
|a) Performance of a contract with you (as an e-commerce business, a working website is necessary to perform our services and provide our products)|
b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
c) Necessary to comply with a legal obligation (to protect user data)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||a) Identity|
f) Marketing & Communications
|a) Consent (if you have agreed previously or recently to receive our direct marketing material)|
b) Necessary for our legitimate interests (to develop our products/services and grow our business)
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 and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at email@example.com.
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.
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 firstname.lastname@example.org.
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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
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 (save where it is required by law or regulation) and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Little Ones Group and which is based in New Zealand, with operations also in Australia and the UK. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In general, much of the basic information about our data subjects (including Contact, Identity, Financial and Transaction Data) is retained for legal purposes for six years after they cease being website users, customers or other business contacts of the company. However, details of retention periods for different aspects of your personal data are available on request from email@example.com
In some circumstances you can ask us to delete your data: please see your legal rights at section 9 below for further information.
In some circumstances we might anonymise 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us firstname.lastname@example.org
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 could 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
We try to respond to all legitimate requests within one month. Occasionally it could 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.
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 at email@example.com
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in Little Ones’ Group from time to time (if any), those who provide IT and system administration services and our outsourced self-employed facilitators who deal with our customers and their queries on our online applications and such facilitators are based in the UK, New Zealand and Australia.
External Third Parties