Last Modified: 6/2/2023
2. THE DATA WE COLLECT ABOUT YOU
We collect several different types of Personal Data from you depending on how you interact with our Services. Depending on how you interact with our Site and use our Services, the Personal Data we collect may vary. Most of the information we collect is given to us by you directly when you use our Services. Occasionally, we collect information from your device which helps us better provide our services to you.
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
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.
3. HOW WE COLLECT YOUR PERSONAL DATA
Data We Collect From Third Parties
We may receive Personal Data about you from various third parties, as follows:
4. HOW WE SHARE YOUR PERSONAL DATA.
From time to time, we may share your Personal Data with others, including in the following circumstances.
Experience Providers. We share Personal Data with the providers of our experiences, including travel and destination providers, travel agents, cruise lines, resorts, and other similar partners. We do this to provide your and other individuals’ information to the relevant parties in your registry, and in connection with your destination and experience choices.
Public Disclosures on Celebration Wishes. Some of your Personal Data will be shared with the general public, including the information posted on your registry website. When information is made publicly available it may be accessed by anyone with access to the platform to which the information is posted. It may also be indexed by third-party search engines, and be imported, exported, distributed, aggregated, and redistributed by others without our knowledge.
With our Affiliates and Partners. When participating in events or activities that we offer along with our partners and/or affiliates, you may be asked to share Personal Data with those affiliates and/or partners. In such a situation, if you consent to such disclosure, the information we obtain from you may be shared with our affiliates participating in such event or activity. In some instances, we may act as joint Data Controllers of your Personal Data, depending on the circumstances. For example, when one of our affiliates creates a private label registry, we may share information that we collect through the Site with them in order to facilitate the provision of Services, provide them with relevant information regarding your use of our Services.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Sale of Our Business. If we sell, merge, or transfer any part of our business, your Personal Data would be transferred along with the other business assets as permitted by law. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Data may be shared with other third parties.
5. HOW WE USE YOUR PERSONAL DATA.
We will only use your Personal Data when allowed by law. Generally, we will use your Personal Data: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and (c) where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your Personal Data
Below is a chart of some of the common ways in which we process your Personal Data. We have 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(varies depending on circumstances)||Lawful basis for processing including basis of legitimate interest|
|To register you as a user of our Services.||Profile Data||Our legitimate interests in website security and customer service.|
|Creating a Couple’s Registry||Identity DataContact DataFinancial DataTransaction DataUsage Data||Performance of a contract with you.|
|Providing Gifts to a Couple||Contact DataTransaction DataFinancial Data||Performance of a contract with you.Legitimate Interests (to learn how our users use our Services, to improve our Services, to 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).||Technical DataTransaction DataUsage DataProfile Data||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 reorganization or group restructuring exercise)|
|To provide you with information and marketing communications about our products and services.||Marketing and Communications Data||ConsentLegitimate Interests (in marketing goods or services in which you may have a personal interest based on our ongoing business relationship).|
|To provide you with third party offers that may be relevant to you.||Marketing and Communications Data||Consent|
|To respond to customer service requests including order status and chat communications.||Identity DataContact DataUsage DataTransaction Data||Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)Consent|
6. MARKETING AND ADVERTISING PRACTICES
Interest Based Advertising. Celebration Wishes uses advertising to help fund our Services and we utilize advertising technology providers to help deliver relevant advertising to you. Celebration Wishes and the technology provider may collect, receive, or use your Personal Data in connection with your use of the Services in order to provide interest-based advertising to you. In such cases the advertiser is acting as a Data Controller of the data for its own purposes.
Most of the third-party advertising and data companies we work with subscribe to the Digital Advertising Alliance Principles and/or are members of the Network Advertising Initiative (“NAI”). To learn more about the information collection practices of NAI members and your related opt-out choices, please visit the NAI’s website here. For more on EU online choices, please visit the EU online choices website here. You can opt out of interest-based advertising from Google by visiting the About Google Ads page or opt out of the DoubleClick cookie by installing the DoubleClick opt out extension. For information about how Google uses data from DoubleClick for Publishers, click here.
Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertisers include the following:
Mobile App Advertising and Tracking. Celebration Wishes, our authorized Service Providers and/or other third-party partners (listed above) involved in the delivery of advertising you receive through our app may collect information about your mobile device, including your mobile device's advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. We and our partners use this information to enable interest-based advertising you receive through our Services and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device's advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions. Visit the privacy settings for your mobile device for more information.
In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.
7. THIRD PARTY LINKS
8. DATA SECURITY
The security of your data is important to use, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. 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. We strive to use commercially acceptable means to protect your Personal Data, but we cannot guarantee its absolute security. 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. Please note that despite our best efforts, no one can guarantee the security of Personal Data. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of Personal Data at any time.
9. DATA RETENTION
We will retain your Personal Data only for so long as necessary to fulfil the purposes for which we collected it, including for the purposes of performing a contract with you, complying with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolving disputes, and enforcing our legal agreements and policies. 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 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.
10. INTERNATIONAL DATA TRANSFERS
Celebration Wishes has its headquarters in the United States, and the information we collect will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Where we transfer EU data subject’s Personal Data to third parties outside of the European Economic Area (EEA), we rely on appropriate suitable safeguards or specific derogations recognized under data protections law, including the GDPR. The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA whenever appropriate.
11. CHILDREN'S PRIVACY
We are committed to complying with the laws protecting the privacy of children, including the United States’ Children’s Online Privacy Protection Act (COPPA). Our Services are not directed to children under the age of 16. We do not knowingly collect Personal Data from children under the age of 16. If we receive Personal Data that we discover was provided by a child under the age of 16, we will promptly destroy such information. If you would like to learn more about COPPA, please visit the Federal Trade Commission home page at ftc.gov.
12. EUROPEAN UNION DATA SUBJECT RIGHTS
EU Data Subjects have certain rights with respect to Personal Data that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
To file a request or take action on one of your rights, please contact us at the contact details provided. 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.
We may need to request specific information from you to help us confirm your identity and verify 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 with no right to receive it. We may also contact you for further information in relation to your request to speed up our response. 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.
2. U.S. State-Specific Privacy Rights
Residents of certain U.S. States have the rights indicated below as of the date in which the applicable laws granting such rights are effective, which are as follows:
California: January 1, 2023
Virginia: January 1, 2023
Colorado: July 1, 2023
Connecticut: July 1, 2023
Utah: December 31, 2023
|Access/Know||Request confirmation from us as to whether your Personal Data is being processed by us and, if so, access to such Personal Data.||X||X||X||X||X|
|Deletion||Request that your Personal Data be deleted (subject to some limitations)||X||X||X||X||X|
|Portability||Request that we provide a copy of the Personal Data that you have provided to us in a usable/readable format||X||X||X||X||X|
|Rectification/Correction||Request that we correct any inaccurate Personal Data relating to you (subject to limitations)||X||X||X||X|
|Restriction on Sharing for Cross-Context Behavioral or Targeted Advertising (called “sharing” under California law)||Request that we stop sharing of your Personal Data for purposes cross-contextual behavioral of targeted advertising purposes||X||X||X|
|Sales of Personal Data||Request that we stop selling Personal Data about you to third parties||X||X||X|
|Restriction on Automated Decision-Making or Profiling||Request that we stop using automated decision-making technology to evaluate you, create a profile of you, and make predictions about your future behavior.||X||X||X|
|Limiting the Use and Disclosure of Sensitive Personal Data||Request that we limit our use and disclosure of your “sensitive personal information,” as that term is defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA), to the extent required by law.||X|
|Right to Appeal||Appeal the denial of a privacy rights request under the relevant law||X||X||X|
We do not engage in automated decision making/profiling so no action is required to exercise this right under state law.
You may make a request at any time to exercise your privacy rights under applicable law by using our Privacy Portal/WebForm. We will respond to your request in the time permitted by law (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within the time permitted by law. If we decline to act regarding your request, we will inform you of our decision and the reason for it.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You may submit a request using by emailing us at firstname.lastname@example.org.
14. HOW TO CONTACT US
Celebration Wishes Inc, 627 8th Avenue San Diego, CA 92101
Phone: (800) 801-3493 Fax: (858) 433-0500