Privacy

Privacy, Data Protection and Cookies Policy

Version published on February 27, 2017

Registration as a User. Pursuant to the provisions established in Spanish Organic Law 15/1999, of December 13, on Personal Data Protection (“LOPD“) and Royal Decree 1720/2007, of December 21, approving the developmental regulation of the LOPD (“RLOPD“), the data provided voluntarily by the User to register on the Platform shall be incorporated in a file belonging to the company EARLY START, S.L. (“Early Start”), which is duly recorded in the Registry of the Spanish Data Protection Agency, for maintenance, general administration management, compliance, development and oversight purposes concerning the business relationship between Early Start and the User and to respond to any complaint or suggestion by the User.

Not providing these data may make it impossible for Early Start to provide the Services or offer the Platform’s contents and may also interrupt the provision of the Services, as well as access to the Platform.

Furthermore, collecting and processing the Users’ personal data fundamentally aims to maintain the commercial relationship as well as to manage, administer, and provide the necessary Service previously requested by the User. Furthermore, Early Start requests from the parents (users) minimal personal data (baby’s date of birth and name, without surnames), for the exclusive purposes of being able to effectively provide the service.

The User ensures and, if appropriate, guarantees that all the data provided during the registration and the contents in the User’s account are true, precise, complete and that they belong to the User. Furthermore, Early Start reserves the right to exclude any User who has provided false data or data from third parties without their consent from accessing the Platform and the Services which require personal data.

User access credentials. The access credentials, login, password and/or any other type of keyword, are personal and non-transferable and are assigned, if appropriate, by Early Start to the User, based on the personal and particular conditions of each User. The User agrees to make diligent and legal use of the cited credentials, as well as not to provide, inform or make them available to third parties. The User agrees to immediately inform Early Start (at the address customer@babywisetunes.com) of the loss or theft of the cited credentials as well as any risk of access to the credentials by a third party, assuming all liability for the improper, illegal or fraudulent use of the credentials. In any case, Early Start is exonerated from any type of liability which may be incurred due to the damages and harms caused or suffered due to fraudulent use or lack of diligence in the care and custody of the credentials, or due to any use contradicting the provisions established in the Privacy and Data Protection Policy.

Promotional offers, quality control studies and statistics. In the event that the User marks the corresponding box to receive commercial information in the Registration section, the User authorizes the receipt of information and advertising about products and/or services from Early Start. The User also authorizes Early Start to perform quality control studies and questionnaires, even after the commercial relationship is finalized in the future, by any means, including email or similar options. The User’s data may also be reported in order to comply with the existing legal obligations. If the User provides personal data from a third party (father/mother, baby, third party receiving a gift code) to Early Start for any reason, the User must previously have informed the party and requested their consent of the measures expressed herein.

The recorded data may be used for statistical purposes, to send scientific information of interest for the User, to manage incidents or to carry out (anonymized) market studies, as well as for the express purposes for which the data has been collected. Likewise, the data will be used to analyze profiles in order to provide better service to our Users. In any case, the User may configure their privacy settings through their Account at any time.

Furthermore, pursuant to article 20 and subsequent of Spanish Law 34/2002, of July 11, on Information Society Services and Electronic Commerce, Early Start shall not send commercial messages by email to the User unless the company has prior express authorization from the User. In any case, the User may request to cancel the receipt of commercial information through the User attention channels at any time or by writing to the email address customer@babywisetunes.com.

Furthermore, if the User wishes to revoke the consent given to receive advertising or promotional information through their User account, email address or other equivalent means of electronic communications at any moment in the future, the User will only need to notify this to Early Start by sending a message to the email address designated for these purposes.

Rights to access, rectify, cancel and object. The User may exercise the rights to access, rectify, cancel and object by addressing a written statement accompanied by a copy of an official identifying document to the address indicated below. The User is required to communicate in writing any modification that may occur in the data provided, so that Early Start can comply with its obligation to keep the data up to date.

EARLY START, S.L. (B-55281596)

Address:

Av. Lluís Pericot 88 3-2

17003-Girona

Spain

Email address: customer@babywisetunes.com

Furthermore, Early Start agrees to observe the obligation to use the data submitted by the User only to be able to provide the service and for the legally established cases. Early Start must maintain due confidentiality and safeguard the data by adopting the necessary measures to prevent their destruction, loss, processing or unauthorized access, taking into account the state of the technology at all times.

Data transfer to third parties. No personal data is collected through the Platform without the User’s consent, nor shall personal data be transferred to third parties. Without prejudice to the above, Early Start may provide data to third parties for the sole purpose for which the data were requested from the User, with the User’s express authorization. In any case, the personal data provided by the User can be notified to the cited third parties only to fulfill the previously indicated purposes, complying with the provisions established in the current legislation on data protection, and collecting the consent of interested parties in all cases when necessary. The User’s authorization to process and transfer their personal data may be revoked, without retroactive effects in the terms established in the applicable legislation. Such revocation shall involve canceling the access to the Platform, as well as the Services offered therein.

Personal data protection and privacy. Early Start agrees to make its best efforts to protect the User’s personal data from unauthorized accesses on the Internet and has established the best technical means within its power to prevent the unauthorized access, loss, improper use, alteration and theft of the data that the User provides to Early Start while registering or accessing the Platform, without prejudice to the fact that the safety measures on the Internet are not impregnable.

The User has a profile which can be configured on their account. The User may also decide the level of public access information that they want to provide through the Platform to guarantee the their privacy. The User can control their connections, eliminate the contents which no longer interest them, restrict with whom they share their connections or restrict the sending of commercial notifications. To do so the User must access their privacy configuration.

Links. Concerning the links with other websites or platforms which are not managed by Early Start and which may appear on the Platform for informative purposes, Early Start does not exercise any control over the links, and is not liable for the information which is accessed. Unless Early Start previously authorized it in writing, no link, hyperlink, frame or similar link may be inserted on the Platform. Furthermore, in the case that the Platform offers links to other websites, although the company attempts to ensure that these third-party websites comply with appropriate standards, Early Start cannot guarantee compliance with the data protection regulation or with the regulation concerning the Law on Information Society Services and Electronic Commerce.

Early Start is not liable in any case for damages or claims from third parties arising from the User’s access to these links or from the products or services that the User contracts through these websites.

Blogs/Forums. The User may access the blogs or forums created by Early Start or that Early Start allows, if appropriate, which are hosted on the Platform. The blog’s author is responsible for the publications and articles (posts). The User is responsible for their own comments. Those comments that violate the minimum rules of respect to third parties, good customs, morality, public order or the law are prohibited. In these cases, Early Starts reserves the right to demand that the comments be removed (or if technically possible, to remove the content immediately). Early Start may proceed to block the User permanently.

The User may publish comments, images, photos or other types of supported multimedia content, if appropriate, on the Platform. The User, in all cases, must be the owner these contents and/or hold the copyrights or intellectual property rights or have the consent of the third parties affected. In any case, the User is solely responsible for publishing any data or image of their underage child/children, holding Early Start blameless.

All the information which the User provides on the blogs must be truthful. In any case, the User is solely responsible for false or inaccurate statements that they make or for the harms that they cause to the Platform or to third parties due to the information that they provide on the Platform.

Modification. Early Start reserves the right to modify this Privacy, Data Protection and Cookies Policy to adapt it, among others, to new legislation, jurisprudence or interpretations from the Spanish Data Protection Agency or from other relevant official organizations in the matter. In this case, Early Start shall announce these changes on the Platform and shall ask the User to accept these changes, when necessary.

For any question, please contact Early Start through our Website, our App or the following address:

EARLY START, S.L. (B-55281596)

Address:

Av. Lluís Pericot 88 3-2

17003-Girona

Spain

Email address: customer@babywisetunes.com