Privacy Policy 

Last revised and effective as of: September 18, 2024 

Mamava, Inc. respects your privacy. Mamava, Inc. (“Mamava”, “we”, “us”, “our”, or the “Company”) offers a website located at www.mamava.com (together with any subdomains thereof, the “Website”) and IOS and Android mobile applications that electronically connect with Mamava Spaces (the “Applications” and together with the “Website, the “Services”) that help users locate and use public spaces to pump and breastfeed (“Public Spaces”), as well as Mamava lactation suites that include Mamava Pods and spaces secured by the Mamava VaRoom door lock system (collectively, “Mamava Spaces”). Public Spaces and Mamava Spaces shall be referred to collectively herein as “Spaces”. This Mamava Privacy Policy (this “Privacy Policy”) applies to users of the Services. As used herein, “you” and “your” mean a user of the Services.

As used in this Privacy Policy: (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means the UK GDPR and the UK’s Data Protection Act 2018 (“UK DPA 2018”); (c) “UK GDPR” means the UK equivalent of the GDPR, as defined in section 3(10) (and as supplemented by section 205(4)) of the UK DPA 2018; and (d) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable. 

This Privacy Policy describes:

• the information that Mamava collects from users of the Services;

• how that information is used and disclosed by Mamava; and

• the rights and options available to users.

This Privacy Policy is incorporated as part of the Mamava End User License Agreement located at http://www.mamava.com/user-agreement (the “Terms of Use” or the “Terms”).

The Services are not intended for use by persons under the age of 13. If you are under 13, you may not download the Applications, nor access the Website. We do not collect information from any person we actually know is under the age of 13. 

If an organization with which you are associated (an “Organization”) signs up to use our services, we may receive information about you in connection with our provision of such services to your Organization. To the extent we process that information solely in order to provide such services to your Organization, we will act as a processor on behalf of your Organization in respect of that information, which means: we will handle that information solely at the direction of your Organization; your Organization’s privacy policy (and not this Privacy Policy) will apply to the processing of that information; and your Organization (and not us) is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your information for any other lawful business purpose of ours, this Privacy Policy will apply to the processing of such information.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within Mamava or among our affiliates within the United States or internationally.

In this Privacy Policy, the term “personal information” means any information relating to an identified or identifiable natural person. Such personal information amounts to ‘personal data’ for the purposes of and as defined in the European Data Protection Laws (as defined below and to the extent applicable).

1. Contact Mamava

If you have any questions or comments regarding this Privacy Policy please contact Mamava at [email protected] or by physical mail at:

Attn: Privacy 

Mamava, Inc.

180 Battery Street #210

Burlington, Vermont, 05401 

If you have questions regarding your personal information held by Mamava, please visit https://www.mamava.com/personal-data-request and fill out the form on the page.

2. What we are collecting

The categories of information collected by Mamava may include all or just some of the following, depending on how you choose to use the Services. 

We will collect personal information that you submit to us. This may include your name, email address, address, phone number, title, company name, Google or Apple account information (if you use the Google or Apple login feature), breastfeeding status, sex, survey responses, including details regarding your breastfeeding experience, products you purchase, and other information you choose to share with us. Additionally, to the extent you make a purchase via the Services, our outside contractor that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly. In order to access certain features of the Services (including the Applications), you may need to create a user account with Mamava using the Google or Apple login feature or using an email address and user created password that will be linked to your account. Your password will be stored in an encrypted fashion with our authentication contractor; Mamava will not have access to your unencrypted password. Through your account you will create a user profile. Your profile is required to include your first and last name. Your profile may include additional information, which you may voluntarily provide, and which is not visible to other users, including pictures of you or your child. 

Further information may be collected when Mamava exchanges communications with you, for example, if you submit a request or contact Mamava’s support team. We may also receive information about you from third-party sources, including lead generation services.

When you use the Services (including Mamava Spaces that are equipped with a “smart” lock or Pod Control Device), Mamava may collect usage information, including the location of the Spaces accessed by you, whether you are using our Applications, user ID (if using our Applications) or guest status, number of uses by Space, the start/end time of your usage, the length of your usage, and Spaces you have reserved and reservation start time. If you are using our Applications, this usage information may be stored in an identifiable manner with your profile and email. 

For users of our Applications, we may also collect: 

• information you submit in connection with Public Areas (including likes and comments on other posts); 

• your geolocation (if you choose to share it), nearby Spaces, and most recent location;

• favorite lactation Spaces;

• information you provide in a review of Spaces you have used such as date of review, rating, and any comments you provide; 

• information you share in connection with issues that you report to us through the Applications, such as type of issue, Space location, description of issue, and email address;

• photos of Spaces; 

• and information regarding lactation locations that you would like to see added to our Applications as Spaces including location, type of location, amenities, nearby landmarks, and photos of the proposed lactation space. 

We may collect from you, or you may make available to us, some special categories of personal data. By agreeing to this Privacy Policy, you explicitly consent to the processing of any such special categories of personal data. “Special categories of personal data” consist of personal data for the purposes of and as defined in the European Data Protection Laws, which is to be treated with particular sensitivity, and includes data concerning health.

If you choose to access certain portions of the Services using the Google or Apple login feature, you may be providing us with access to all information, attributes, and data in your Google or Apple profile. We may freely store and use such information in accordance with this Privacy Policy. Such information may be stored by us and may be used in connection with providing the Services or to contact you.

Mamava collects so-called “metadata” about the use of the Services. For example, Mamava may record the frequency and scope of your use of the Services, products you view, the duration of your sessions, information about the device on which you have installed the Application, system and application software, peripherals, technical data and related information, the web pages that you visit via the Application, information that you read, content that you use or create, advertisements that you view or click on, your communications with other users and third parties, the Internet protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the computer system that you are using to log-in. In addition, Mamava may also collect demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the date and time of your visit, domain names, and statistical data involving the use of the Services. 

3. How we will use your information

Mamava (or its third-party service providers or contractors (each a “contractor”)) may use information collected from or provided by you for the following purposes:

• to provide you with the Services. For example, Mamava may use your location information and/or search query history to assist you in locating Spaces.

• to provide you with support and handle requests and complaints.

• to send you updates, notices, announcements, and additional information related to the Services.

• if you opt to receive push notifications through the Applications, to facilitate your use of the Services and/or to send you surveys. 

• to help us improve the Service, understand its users and their preferences, and to market our products and services.

• to create aggregated, pseudonymous or anonymous data (where such data does not enable the identification of a specific user). See “How does Mamava use aggregated information” below.

• to conduct surveys and questionnaires.

• to enforce the Terms of Use or another contract.

• to contact you when Mamava believes it to be necessary.

• to comply with any applicable law and assist law enforcement agencies under any applicable law, when Mamava has a good faith belief that Mamava’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures.

• to prevent fraud, misappropriation, infringement, identity theft, and other illegal activities or misuse of the Services.

• to handle breakdowns and malfunctions.

• to take any action in any case of dispute, or legal proceeding of any kind.

• for purposes provided under this Privacy Policy and the Terms of Use.

• evaluate your eligibility for certain types of offers, products or services that may be of interest to you, and analyze advertising effectiveness.

• answer your questions and respond to your requests.

• perform analytics and conduct customer research.

• communicate and provide additional information that may be of interest to you about Mamava.

• send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information.

• Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by Mamava or Mamava’s business partners.

• to facilitate connections between users of the Services.

• to analyze trends, to monitor the use of the Services, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Services and evaluating the Services in general.

• to process your transactions and fulfill orders placed through the Services.

Pursuant to the European Data Protection Laws, legal bases for our processing your personal information may include (without limitation): 

(a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;

(b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Services or otherwise);

(c) where it is necessary for us to comply with a legal obligation to which we are subject; and/or

(d) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing, improving, or marketing the Services and your interests or fundamental rights and freedoms do not override those legitimate interests.

In connection with the Services, you may have an opportunity to upload content to the Services that feature community areas and other public forums, including without limitation the Words of Support area of the Application, where Services users can share information and post questions for others to answer (collectively, the “Public Areas”). However, any content that you submit for posting to these Public Areas may be viewed by all users of the Services and by Mamava and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner inconsistent with this Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

We at Mamava take great measures to provide you with the best experience you can have while using the Services. However, Mamava has no control over the conduct of any user or third party (including, without limitation, third-party websites), and disclaims any and all liability in relation thereto. Users are advised to carefully and thoroughly consider whether or not to make information public, and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, and Bing. If you mistakenly post information in a Public Area, you can send us an email to request that we remove it by contacting us at [email protected]. You should understand that in some cases, we may not be able to remove your information.

The user has the sole and ultimate responsibility regarding compliance with all laws, regulation or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.

4. Accessing the Services

In order to access certain features of the Services, you will need to provide your name and email address and password (which is stored in an encrypted fashion) to create an account.

Your log-in details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your details to someone else. You must maintain your log-in details in absolute confidentiality and avoid disclosing them to others. Make sure that you change your password frequently (e.g., at least once every six months).

5. Sharing information with others

Mamava (or Mamava’s contractors, on Mamava’s behalf) may share your personal information as required or permitted by law:

• if Mamava reasonably believes that you have breached the Terms of Use, or abused your rights to use the Services, or performed any act or omission that Mamava reasonably believes to be violating any applicable law, rules, or regulations. Mamava may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing.

• if Mamava is required, or reasonably believes that it is required by law to share or disclose your information including to meet national security or law enforcement requirements, or other valid legal process.

• in any case of dispute, or legal proceeding of any kind between you and Mamava, or between you and other users with respect to, or in relation with the Services.

• in any case where Mamava reasonably believes that sharing information is necessary to prevent imminent physical damage or damage to property, or to protect our business interests or the rights of others.

• if Mamava organizes the operation of the Services within a different framework, or through another legal structure or entity, if Mamava is acquired by, or merged into or with another entity, in connection with a strategic investment by a third party in Mamava, or if Mamava enters bankruptcy.

• for facilitating the Services, including to collect, hold and manage your personal information through cloud-based or hosting services or a third party or a party affiliated or connected to Mamava, for the Payment Services Provider to conduct credit card processing and fraud screening, and to our commercial partners for order fulfilment purposes.

• to business customers who use our Services, such as the entity that owns a Mamava Space, we may disclose aggregated usage reports, which, in certain circumstances, may contain data that is indirectly identifiable.

• at your direction, to other independent businesses, such as virtual lactation consultants, so that you may take advantage of their offerings.

• to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Mamava may also share personal information with companies or organizations connected or affiliated with Mamava, such as subsidiaries, sister-companies and parent companies. Personal information may also be shared with Mamava’s other partners and service providers to process it for us, based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

Mamava may share personal information with Mamava’s contractors to provide services for Mamava (we use reasonable efforts to ensure that these contractors are capable of protecting the security of your personal information).

In addition to the above, when users use our Services, third parties (including without limitation third-party advertisers and commercial partners) may directly collect information about our users’ online activities over time and across different websites. Mamava may disclose cookies, pixel tags, web beacons, device data, or other metadata:

• with business partners for their own analysis and research.

• to facilitate targeted content and ads.

• with third-party ad-servers to place our ads and/or ads of our merchants or business partners on the Website and on third-party sites, and to analyze the effectiveness of those ads.

Please note in particular that the Services use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

6. International Transfers

Personal information collected on the Services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Services may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. Without limitation of the foregoing, you hereby expressly grant consent to Mamava to: (a) process and disclose such information (including special categories of personal data) in accordance with this Privacy Policy; (b) transfer such information (including special categories of personal data) throughout the world, including to the United States or other countries that do not ensure adequate protection for personal data (as defined in the European Data Protection Laws) (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information (including special categories of personal data) to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by applicable law: whenever we transfer your personal data to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the UK Information Commissioner’s Office (accessible at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/), as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction. 

7. Controlling your personal information (User Rights)

We generally use your personal information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. 

You generally must “opt in” and give us permission to use your personal information for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting [email protected].

Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to: 

Request access to your personal information (commonly known as a ‘subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it; 

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate personal information we hold about you corrected; 

Request erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personal information in certain circumstances; 

Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground; 

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it; 

Request the transfer of your personal information to another party; and

Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your personal information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country. 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact [email protected].

Such updates, corrections, changes, and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

To delete your account and your personal information yourself, go to the profile screen on the Mamava mobile app and tap “delete account” and confirm the delete. If you would like us to delete your Account, please contact us at [email protected].

You should be aware that it may not be technologically possible to remove each and every record of the personal information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

8. How does Mamava use aggregated information?

Mamava may use anonymous, pseudonymous, statistical, or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial, and statistical purposes.

Mamava may also use anonymous, statistical, or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to the Services’ providers, partners, and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems.

9. Cookies and Action Tags

Mamava may use cookies on the Services. Cookies are packets of information sent by a website’s servers to your web browser and then sent back by the browser each time it accesses the website’s servers.

Mamava may use cookies for various purposes, such as to save you the need to re-enter your login information each time you log-in, to facilitate the use of the Website and the Applications, to collect statistical information, to verify information, to customize the Website and the Applications to your personal preferences, and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your mobile device or your computer, as applicable. If you wish to block the cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website or Applications, or certain features thereof.

Action tags, also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Services, including advertisements, or email sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Services and measure the effectiveness of our advertising and marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete. Information collected from some cookies placed on the website is used to deliver advertisements to Mamava Website visitors when such visitors are visiting other sites, including Facebook and LinkedIn.

For the avoidance of doubt, the Services use third-party service platforms (including to help analyze how users use the Services). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

Here are links to the main third-party platforms we use:

https://www.google.com/policies/privacy/

https://legal.hubspot.com/cookie-policy

https://www.linkedin.com/legal/cookie-policy

https://www.facebook.com/privacy/policies/cookies/

https://privacy.microsoft.com/en-us/privacystatement

https://www.cloudflare.com/cookie-policy/

https://www.shopify.com/legal/cookies

When you visit a third-party website from the Application or the Website, such third-party may use cookies on your computer or mobile device. The third party’s use of cookies is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those third parties you should visit their services, or contact them directly.

10. Advertising campaigns

Mamava may permit, solicit or contract certain other companies to conduct advertising campaigns via the Services.

Note that information collected from cookies and other similar technologies (which may include device identifiers) may be used to send you online advertising for the Services. In particular, information collected from cookies (including cookies placed by third-party vendors, such as Google and its partners) and other similar technologies (which may include device identifiers) may be used to deliver advertisements to Website visitors when such visitors are visiting other websites, including Facebook, LinkedIn, and YouTube. These third-party vendors may use cookies and/or device identifiers to serve ads based on your past visits to the Website. You may opt out of a third-party vendor’s use of cookies and/or device identifiers for personalized advertising by visiting https://thenai.org/opt-out/. 

11. Information Security

Mamava takes the security of your personal information seriously. Mamava implements commercially reasonable systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss, or unauthorized access or use. However, these measures are unable to provide absolute assurance. Therefore, while Mamava takes steps designed to protect your personal information, Mamava cannot guarantee and you cannot reasonably expect that Mamava’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and/or misuse. Without limitation of the foregoing, given the risks around cyber security and hacking, you should not voluntarily provide profile information that you would not want publicly available. By voluntarily uploading any profile information, you expressly assume the risk that this could become publicly available other than as a result of Mamava’s intentional disclosure. 

12. Retention

We will retain your personal information for as long as reasonably necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. 

To determine the appropriate retention period for personal information, we consider multiple factors, including without limitation, the amount, nature, and sensitivity of that personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

13. Do Not Track

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided above.

14. Links to other Websites

1. Our Services may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or service other than the Services. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Services.

   15. Changes to this Privacy Policy

2. We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personal information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Services.

16. Privacy Notice for California Residents

This Section 16 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA. This Section 16 shall apply to you only if you are a California resident. 

As used in this Section 16, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to a third party for monetary or other valuable consideration. 

“Selling” does not include (i) disclosing consumer information to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Mamava, provided that information is used or shared consistent with the CCPA.

As used in this Section 16, “share” (including any grammatically inflected forms thereof) means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions with a third party for cross-context behavioral advertising for our benefit in which no money is exchanged.

“Sharing” does not include (i) disclosing consumer information to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Mamava, provided that information is used or shared consistently with the CCPA.

16.1 Consumer Information Collected: We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents or households (“consumer information”). Consumer information does not include deidentified or aggregated information, publicly available information or lawfully obtained, truthful information that is a matter of public concern, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. For purposes of this Section 16.1, “publicly available information” means information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media, or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience. 

For purposes hereof, “sensitive consumer information” means: (1) consumer information that reveals (A) your social security, driver’s license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation; (D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages, unless we are the intended recipient of the communication; (F) your genetic data; and (2)(A) consumer information consisting of biometric information processed for the purpose of uniquely identifying you; (B) consumer information collected and analyzed concerning your health; or (C) consumer information collected and analyzed concerning your sex life or sexual orientation. We use or disclose your sensitive consumer information, provided that we only use or disclose your sensitive consumer information for the purposes specified in Section 7027(m) of the CCPA regulations, and we only collect or process sensitive consumer information without the purpose of inferring characteristics about you.

To the extent we consider Deidentified Data outside the scope of the CCPA because it is not identifiable, then, to the extent required by the CCPA, Mamava hereby publicly commits to process Deidentified Data in its possession only in a de-identified fashion and not attempt to re-identify such Deidentified Data. “Deidentified Data” means data that cannot reasonably be used to infer information about, and that cannot reasonably be linked to, an identified California resident or an identifiable California resident, or to a device linked to such California resident.

In particular, with respect to the Services, we have collected the following categories of consumer information from California residents or households within the last twelve (12) months and, in connection therewith, we may collect the following categories of consumer information from California residents or households:

16.2 Purposes for Collection of Consumer Information; Categories of Sources: We collect consumer information for the business or commercial purposes described in the tables above and in the manner described in Sections 2, 3, and 9 of this Privacy Policy with respect to personal information. Regarding the categories of sources from which consumer information is collected, we collect consumer information from the categories of sources described in the tables above and in the manner described in Sections 2, 3, and 9 of this Privacy Policy.

16.3 Disclosures of Consumer Information for a Business or Commercial Purpose: Mamava may disclose your consumer information described in the tables above to a third party for a business or commercial purpose, as described in the tables above and in Sections 5 and 9 of this Privacy Policy with respect to personal information. In the preceding twelve (12) months, Mamava has disclosed each of the categories of consumer information described in the tables above for a business or commercial purpose to the categories of third parties described in the tables above.

16.4 Sharing and Sales of Consumer Information: In the preceding twelve (12) months, Mamava has not shared or sold, nor does it or will it share or sell, consumer information.

16.5 California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their consumer information. This Section 16.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

16.5.1 Access to Specific Information and Data Portability Rights: You may have the right to request that Mamava disclose certain information to you about our collection and use of your consumer information over the past twelve (12) months or such other period required by the CCPA. Once we receive and confirm your verifiable consumer request (in the manner described in Section 16.6 below), to the extent required by the CCPA, we will disclose to you:

16.5.1.1 The categories of consumer information we collected about you.

16.5.1.2 The categories of sources for the consumer information we collected about you.

16.5.1.3 Our business or commercial purpose for collecting that consumer information.

16.5.1.4 The categories of third parties to whom we disclose that consumer information.

16.5.1.5 The specific pieces of consumer information we collected about you (also called a data portability request).

16.5.1.6 If we disclosed your consumer information for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the categories of recipients to whom such consumer information was disclosed and the consumer information categories that each category of recipient obtained.

16.5.2 Deletion Request Rights: You have the right to request that Mamava delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you or your authorized agent (in each case if you are a California resident) in the manner described in Section 16.6 below (“verifiable consumer request”), we will delete (and notify our service providers and/or contractors to delete, unless this proves impossible or involves disproportionate effort) your consumer information from our records, unless an exception applies or retention of your consumer information is otherwise permitted by the CCPA. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) and/or contractor(s) to:

16.5.2.1 Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

16.5.2.2 Help to ensure security and integrity to the extent the use of your consumer information is reasonably necessary and proportionate for those purposes.

16.5.2.3 Debug to identify and repair errors that impair existing intended functionality.

16.5.2.4 Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.

16.5.2.5Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

16.5.2.6 Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete the research, if you have provided informed consent.

16.5.2.7 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.

16.5.2.8 Comply with a legal obligation.

16.5.3 Correction Request Rights: You have the right to request that we correct inaccurate consumer information about you that we maintain, taking into account the nature of the consumer information and the purposes of the processing of the consumer information. If we receive a verifiable consumer request from you to correct inaccurate consumer information, we will use commercially reasonable efforts to correct such inaccurate consumer information as directed by you, pursuant to Section 1798.130 of the CCPA and regulations adopted pursuant to the CCPA. 

16.6 Exercising Access, Data Portability, Correction, and Deletion Rights: 

16.6.1 To exercise the access, data portability, correction, and deletion rights described in Section 16.5 above, please submit a verifiable consumer request to us by either: (1) calling us at  (866) 929-9290; (2) visiting https://www.mamava.com/personal-data-request; or (3) contacting us in accordance with Section 1. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. Someone legally authorized to act on your behalf (such as an authorized agent) may make a verifiable consumer request on your behalf, provided that you have duly authorized that person or entity to make such a verifiable consumer request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a twelve (12) month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized agent; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided for the purposes of verification of a consumer request to verify the requestor's identity or authority to make the request. We use the following process to verify consumer requests: In the event you make a request under this Section, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to you by email or otherwise to ask you questions pertaining to the information we have about you. 

16.6.2 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

16.7 Non-Discrimination

16.7.1 We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

16.7.1.1 Denying you goods or services;

16.7.1.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

16.7.1.3 Providing you a different level or quality of goods or services;

16.7.1.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or

16.7.1.5 Retaliating against an employee, applicant for employment, or independent contractor, as defined in subparagraph (A) of paragraph (2) of subdivision (m) of Section 1798.145 of the CCPA for exercising their rights under the CCPA.

16.8 Consumer Information Retention. We will only retain your consumer information (including sensitive consumer information) for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. To determine the appropriate retention period for consumer information, we consider the amount, nature, and sensitivity of that consumer information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your consumer information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

16.9 Contact. If you have any questions or concerns relating to this Privacy Policy and/or our consumer information practices, please contact us in accordance with Section 1.