WagWiggles Privacy Policy

1. INFORMATION WE COLLECT

Information You Provide to Us

We collect your personal information when you provide it to us, such as by purchasing a WagWiggles subscription from us; using or registering for our Services; leaving reviews, ratings, or comments about our products or posts; or when you contact or communicate with us. The personal information we collect directly from you may include your name, online usernames or account identifiers, postal address, shipping address, zip code, email address, payment information, telephone number, and information about your orders, purchases, shipments, and subscription status. We also collect certain categories of personal information from you in connection with specific interactions you have with us. For example:

• When you make a purchase, use the Services, create an account, or rate/review our products. If you purchase a WagWiggles subscription, we collect your name, email address, postal address, shipping address, zip code, telephone number, and applicable payment information that you provide to facilitate the transaction, or that we need to fulfill your purchase. We also collect information about your orders, purchases, shipments, and subscription status in order to provide you the Services. If you choose to create an account on our Site, rate/review/comment on products we offer, or comment on our blog posts, we will collect information such as your name, online usernames or other account identifiers, email address, postal address, shipping address, zip code, telephone number, payment information, and information about your orders, purchases, shipments, and subscription status. We may collect information from your government identification in the event you would like to return or exchange a purchase made with us, in order to prevent fraudulent activity. In addition, we collect information that you enter into our Site about your pet, such as your pet’s name, date of birth, gender, size, breed, photo, medical information, and other health-related information for your pet.
• When you interact with us online, over social media, or in public. If you interact with us online, or on social media platforms such as Facebook, Twitter, Instagram, or YouTube, we may collect your name, online usernames or other account identifiers, email address, and/or any media (such as photos) that you choose to share with us on those platforms. Our customer satisfaction surveys or product review tools may enable you to review our products online or using your mobile device. If you opt to participate in such features, we will collect your review in the format you submit it to us, as well as personal information such as your email address that correlates with your review. From time to time, we may facilitate online or publicly posted petitions, or engage in similar advocacy activities, intended to influence government officials, news publications, or other advocacy targets on topics that may be important to our customers. If you choose to sign such an online petition or similar advocacy form, we will collect the personal information you provide at that time, such as your name, email address, postal address, telephone number, and overall information about your participation in the petition.
• When you contact us. If you contact us via email, through a web form on the Site, via social media, on a recorded customer service telephone number, or if you choose to participate in a survey, contest, or promotion with us or our service providers, we may collect your email address, online usernames or other identifiers, telephone number, location, a recording of your call, and other personal information you provide to us.

Automatically Collected Information

Like many businesses, we and our service providers collect certain information about you through automated means when we interact with you.

• Automated data collection technologies we use. We and our service providers may use common technologies such as cookies, web or hardware beacons, pixel tags, log files, social media widgets, session replay software, or other tools that automatically collect and store data about your use of the Site and our online interactions with you. Other technologies used by WagWiggles include clear GIFs and IP address logging. Clear GIFs are also known as web bugs, beacons or tags, are small graphic images placed on a web page, web-based document, or in an email. Clear GIFs are invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the web page, document or email. We may use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page. We may correlate this information to a user to personalize user experience and for statistical analysis of user experiences on our web pages.
• Information these technologies automatically collect. These types of technologies collect, for example, your browser type and settings; device attributes such as type and model; operating system; software and hardware information; IP address; mobile device identifiers; unique device and online identifiers; geolocation, GPS location, or other location information as described more fully below; Internet Service Provider or mobile carrier; entry/exit URL; language settings; and time zone. We also automatically collect information about your use of the Site, including the date and time you visit; the areas or pages that you visit; the amount of time you spend viewing or using the Site; the number of times you return to the Site; clickstream or usage data from our Site and advertisements; other sites or mobile applications that you may visit; and your interactions with promotional or transactional emails, advertisements, and texts from us or our service providers.
• Location information. If you are accessing the Site, we may detect your general location so that we can automatically help you find Services in your general area. Depending on browser type and configuration, your browser may inform you that the Site would like to collect your specific location and request your permission to do so. If you do not allow it, or your browser does not permit it, only your general location information is then collected and may be stored locally on your device. If you access the Services on your mobile device, we may, depending on your application and operating system settings, directly collect precise geographic location information and sensor data via GPS, cellular network information, and other location-based features. Depending on your mobile device's operating system, we may receive the latitude and longitude of your mobile device, as well as date and time. You can turn off direct location collection through your device settings.
• Information you integrate from other online platforms. When using the Site, you may be given the option to sign into or connect to your social networking or other online accounts, such as Facebook, Twitter, your email provider, your mobile device provider, or similar online platforms you participate in. If you choose to integrate your use of our Services with any such external platforms, we and those platforms may automatically collect, receive, and use personal information about you based on your registration and settings with those services. Such information may include your name, usernames or similar unique identifiers, postal address, email address, pet information, photographs you send us, location, and social media or account profile information. Some online platforms may combine information they collect from your interaction with the Services, with information they collect from other sources. Please see below under “External Content, Links, and Plug-Ins” for more information. It is your choice whether to sign into or connect your other online accounts with your use of our Services. Your use of any external platforms is subject to those parties’ privacy policies.

Information Collected from Other Sources

We also acquire personal information from other sources who have the right to provide such information to us. For example, we may acquire address information from these sources to validate or update your postal address or to prevent fraud; demographic and lifestyle information to help us analyze our business’ performance or improve the Services; and information about your online and offline transactions and purchases to help us analyze or improve the Services. We receive personal information, such as your name and email address, from our business partners when you participate in joint marketing promotions, events, transactions, or similar interactions with third parties with whom we share a joint venture or similar business relationship. The categories of sources that provide us personal information include consumers themselves; data analytics providers; advertising networks; social networks; data brokers; operating systems and platforms; co-branded ventures; and our affiliated and related entities. We use collected information consistent with this Privacy Policy and for the purposes described below.

2. HOW WE USE YOUR INFORMATION

We may collect, use, retain, share, and store personal information collected from or about you for any of the following purposes:

• To provide and improve the Services. We use your personal information – such as your address and transaction details – to fulfill, validate, manage, deliver, and/or track your orders and transactions; process payments; process and verify returns and refunds; and to provide and improve our customer service. We also may use personal information to analyze and improve the performance, usage and operations of our Services using internal or external software and tools; to better understand who is using the Services and how; and to develop new products or services.
• To communicate with you. For example, we use your personal information – such as your email address, telephone number, online usernames, and other contact information – to respond to your inquiries; to provide you with information about your account, purchases, transactions, the Services, and your subscription; to conduct surveys, sweepstakes, contests, focus groups, or promotions; to engage with you over Site features such as product ratings/reviews/comments; to provide you offers by email or across other websites, mobile applications, social media, and online services as appropriate; and to otherwise communicate with you as needed or permitted to run our business.
• To provide you personalized advertising, marketing, advocacy options, and other information we think may be of interest to you. For example, we use your personal information – such as your IP address and device identifiers – to help us or our service providers deliver interest-based advertising and content that is tailored to your individual interests. This includes advertising networks and our data analytics service providers who facilitate customized advertising and marketing services. We, or our service providers, partners, or affiliates, may provide this content via email or across other websites, mobile applications, social media, or online services, as appropriate. We also may use your online identifiers to enhance and personalize your online and in-store shopping experiences with our affiliated retail businesses, and to recognize or welcome you to the Site. If you choose to participate in a publicly posted or online petition (or similar advocacy activities), we may use your personal information for petitioning, advocating to, or influencing government officials, news publications, legislators, and other advocacy targets, as well as marketing to and contacting you regarding similar subjects we think may be of interest to you. Please visit “Your Choices” below for further information on how to opt out of certain interest-based advertising, including information about Do-Not-Track options and how to disable cookies.
• To perform business reporting, analysis, and research. For example, we use information about your transaction history with us, your general location, and information about your use of the Services to engage in reporting, analytics, and research that helps us operate or improve our business. This includes metrics measuring the performance of our marketing efforts and advertisements that you may see or receive. We and our service providers also may combine, supplement, and update the personal information we collect from and about you, with information collected offline, across other computers or devices that you may use, and from external sources. We also use your information to better understand who is using the Services; to develop new products or services; and to help us analyze and improve the performance, usage and operations of our Services overall. We use external software providers and tools to help us perform these analytics.
• To prevent fraud, comply with applicable law, protect our business, and other purposes. For example, we may use your name, contact information, and other personal information to protect the security or integrity of the Services and our business; to prevent fraudulent activity; to assist law enforcement; and/or to comply with our legal or regulatory obligations. We may also use and share aggregated or de-identified personal information for any purpose.

3. INFORMATION WE SHARE

We do not sell personal information. We may share or disclose the personal information we collect from or about you when (i) we notify you or obtain your consent; (ii) when our service providers need such information in order to provide a business service to us; or (iii) or in any of the following situations:

• Affiliates: We share your personal information with WagWiggles affiliates, business units, parents, and/or subsidiaries for business, operational, promotional, marketing, or other purposes consistent with this Privacy Policy.
• Service providers: We share your personal information with service providers we use to provide business, professional, or technical support functions for us; that help us operate our business; and that perform other activities in support of the Services or our business. For example, we share your personal information with service providers who assist us with shipping your order; processing and responding to your inquiries; advertising and marketing the Services; or processing your payments. This includes advertising networks and data analytics service providers we use for marketing and advertising the Services. Our service providers are authorized to use your personal information only as instructed by us and for the business services they are providing to us.
• Third parties: We may also provide personal information to business partners or other third parties with whom we may jointly offer products or services. In such cases, the business partner or third party’s name will appear with ours or one of our brands, and the third party’s use of your personal information will be governed by their privacy policies. For example, if you participate in a publicly posted or online petition we are involved with, we may share the personal information you provide at the time of your participation with advocacy targets, such as government officials, news publications, legislators, and others, to market to you or contact you regarding subjects we think may be of interest to you. We may also share aggregated or de-identified information with third parties without restriction.
• Co-branded relationships: Certain areas of our Services may be provided to you in association with third parties, such as advertisers or financial institutions that provide or facilitate our Services, the Program, or related offerings. We may share personal information with these third parties if you participate in a co-branded, co-sponsored, or jointly presented promotion, contest, survey, voting feature, or service. By participating in these co-branded Services, your personal information may be shared with these third parties in accordance with their privacy policies.
• Surveys, sweepstakes, contests, focus groups, and promotions: If you choose to enter into or participate in one of our surveys, sweepstakes, contests, focus groups, or other promotions, we may disclose your personal information to third parties or the public in connection with the administration of these items, as required by law, as permitted by the official rules, or otherwise in accordance with this Privacy Policy.
• Sales or transfers of businesses or assets: We may sell or purchase assets during the normal course of our business. If another entity acquires WagWiggles and/or of any of our affiliates, personal information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.
• Legal matters; compliance with the law: We may disclose personal information collected from or about you to the government, insurance providers, or to other third parties to comply with applicable law; regulations; governmental and quasi-governmental requests and investigations; court orders; subpoenas or other legal process; or to defend ourselves in legal matters. We may share your personal information with fraud prevention service providers in connection with suspected illegal activity associated with the Site or our business; to protect against harm to the Services, to us, or to others; to detect security incidents; or to defend ourselves in legal matters.

4. YOUR CHOICES

Cookies, Personalized Advertising and Do-Not-Track Settings

Certain parts of our Site use cookies and other tracking mechanisms. We use cookies and other technologies to deliver more relevant advertising, link data collected across other devices that you may use, collect demographic information, personalize your experience on our site and monitor advertisements and other activities. Cookies are small files downloaded to your computer to track movements within websites. We may link cookie information to personal information. Cookies link to information regarding what items you have selected for purchase at our store or pages you have viewed. This information is used to keep track of your shopping cart and make sure you do not see the same ad repeatedly. We also use cookies to deliver content specific to your interest and to monitor website usage. Our Site may use an outside ad company to display ads, which may contain cookies. Our third party and service provider partners may collect cookies received with banner ads, and WagWiggles does not have access to this information. Most browsers are automatically set to accept cookies whenever you visit a website. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings.

To learn more about the use of cookies and other technologies used to deliver more relevant advertising, and to know your choices with respect to collection and use of the data by these external tools and participating companies, please visit the Digital Advertising Alliance’s opt-out pages at https://youradchoices.com and https://optout.aboutads.info/. You can also download the free AppChoices app from the Digital Advertising Alliance to control how much information about your interests is used for in-app advertising on your mobile device by participating companies. For more information, please visit https://youradchoices.com/control. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. You can also refer to your browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable cookies, and options for controlling your tracking preferences. You must separately opt out in each browser on each device. Please note, if you choose to opt out of personalized advertising, you will still continue to receive generic advertising. We may not respond to Do-Not-Track requests or headers from some or all browsers.

Changing Your Preferences

• Email Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may (i) click the unsubscribe link in the footer of any of our promotional emails; or (ii) contact us using one of the methods in the “Contact Us” section below.
• Third-Party Analytics. Our Site may use services operated by third parties, such as Google Analytics, which use cookies and similar technologies to collect and analyze information to understand the use of our Site and report on activities and trends. This service may also collect information regarding your use of other websites, applications, and online resources. You can learn about Googles practices at https://policies.google.com/technologies/partner-sites, and remove Google Analytics from your browser by installing the Google Analytics browser add-on available at https://tools.google.com/dlpage/gaoptout.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable.

5. YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act

If you are a California resident, you may exercise certain rights under the California Consumer Privacy Act (“CCPA”) related to your personal information. The CCPA defines personal information as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Categories of Personal Information Collected and Disclosed

The personal information we collect, and sources for that information, are described above under “Information We Collect.” It includes the following categories:

• Personal identifiers, such as name, contact information, email address, IP address, gender, device identifiers, information from your government identification if provided to process a return or exchange, photos you send us through social media, and other unique or online identifiers;
• Customer records, such as payment information and other financial account information you provide us to pay for a purchase;
• Usage data, such as internet and electronic activity information regarding your interactions with our Site and advertisements;
• Geolocation data as described above;
• Audio, video, and electronic data such as call recordings created when you call our customer service telephone numbers;
• Commercial and transactional information, such as products and services purchased; purchasing history/tendencies; and
• Profiles and inferences drawn from the information above.

We do not sell personal information. We may disclose or make available certain categories of personal information to others in order to improve and measure our advertising campaigns; to receive certain benefits or services; and to reach users with more relevant ads and content through third-party tags on our Site. We do this in order to achieve the business purposes described above in the sections titled, “How We Use Your Information” and “Information We Share.” We disclose these categories of personal information to the following types of recipients in order to fulfill our business purposes:

• Personal identifiers: Affiliates; financial service providers; marketing providers; data analytics providers; IT, cloud, information security and similar providers; and legal/risk service providers.
• Customer records: Affiliates; financial service providers; marketing providers; IT, cloud, information security and similar providers; and legal/risk service providers.
• Usage data: Affiliates; marketing partners; data analytics providers; IT, cloud, information security and similar service providers.
• Geolocation data: Affiliates; marketing partners; data analytics providers; IT, cloud, information security and similar service providers.
• Geolocation data: Affiliates; marketing partners; data analytics providers; IT, cloud, information security and similar service providers.
• Commercial and transactional information: Affiliates; financial service providers; marketing providers; data analytics providers; IT, cloud, information security and similar service providers; and legal/risk partners.
• Profiles and inferences: Affiliates; financial service providers; marketing providers; IT, cloud, information security and similar service providers; and legal/risk partners.

We retain personal information as necessary to provide the Services to you, and for reasons such as dispute resolution, compliance with laws, fraud prevention, troubleshooting, and enforcement of our Terms of Use and other agreements.

Submit a CCPA Rights Request

If you are a California resident, the CCPA gives you the right to request that we disclose the personal information we have collected about you, the categories of sources from which your personal information was collected, our purpose for collection, and the categories of personal information we disclose and to whom. California residents also have the right to request that we delete their personal information, subject to certain exceptions. You may make CCPA requests or exercise these rights at no charge up to twice every 12 months.

If you are a California resident and wish to exercise your rights under the CCPA, you may submit a request via our web form, by calling at (+91) 123 1234567, or by email at info@wagwiggles.com.

In order to protect our customers’ personal information, and as required under the CCPA, we will verify your identity by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request, or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requester. You may submit a request on your own behalf, or you may designate an authorized agent to make a request on your behalf. Authorized agents may be required to provide proof of their authorization, and we may also require that the relevant individual directly verify their identity and the authority of the authorized agent.

The CCPA grants California residents the right not to receive discriminatory treatment for exercising their privacy rights. We respect your privacy rights and we do not discriminate against individuals for exercising their rights. We may offer social media influencers or other customers who are California residents special promotions or financial incentives in exchange for the collection of certain personal information, including but not limited to social media posts, testimonials, referrals, or pictures. Participants may provide us with personal information, such as name, email address, and online username to participate in these promotions. There is no obligation to participate in these promotions and participants may opt out of these promotions at any time.

2020 CCPA Requests - Reporting Metrics

This section of our Privacy Policy was added in June 2021, pursuant to California Code of Regulations, 11 CCR § 999.317(g); no other changes were made to the Policy at that time. As described above, WagWiggles is a member of the Petco family of businesses. The metrics below include data for the entire Petco family of businesses. Between January 1, 2020 and December 31, 2020, we received 399 requests under the CCPA from both California and non-California residents:

Type of Request	Number of Requests Received	Number of Requests Complied with in Full or Part	Number of Requests Denied
Requests to Know/Access	57	8	49
Requests to Delete	342	71	271
Requests to Opt-Out of Sale	N/A	N/A	N/A

The mean number of days for processing requests to know/access, and requests to delete, are 6.28 and 5.27, respectively. As disclosed herein, because we do not sell personal information, we do not receive or maintain statistics regarding requests to opt-out of sales.

California’s ‘Shine the Light’ Law

Under California’s “Shine the Light” law, a California resident with whom we have an established relationship has the right to request information about our disclosure of personal information to affiliated companies or third parties for their direct marketing purposes, within the immediately preceding calendar year, subject to certain exceptions. To exercise this right, please contact us by writing to us at WagWiggles, c/o Petco Animal Supplies Stores, Inc., 10850 Via Frontera, San Diego, CA 92127, Attn: Privacy Team: Shine the Light.

6. NEVADA RESIDENTS

Nevada residents have the right to request that we do not sell certain personal information to select third parties for monetary consideration, even if their personal information is not currently being sold. If you are a Nevada resident and wish to exercise this right, please email info@wagwiggles.com.

7. HOW TO CORRECT OR UPDATE YOUR PERSONAL INFORMATION

You may correct or update certain personal information that we collect from you by editing your information and preferences on the "My Account" page of our Site, or using one of the methods listed in the “Contact Us” section below.

8. DATA SECURITY

We value your privacy and the security of your personal information. We have taken certain physical, administrative, and technical steps designed to safeguard the personal information we collect from and about our customers. However, please be aware that despite these measures, no e-commerce platform, website, application, or system is 100% secure. You should take reasonable steps to protect your personal information against unauthorized access to your password, phone, and computer by, for example, signing off after using a shared computer; choosing a unique password for each account that nobody else knows or can easily guess; and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

9. TRANSFER OF DATA FROM OUTSIDE THE UNITED STATES

WagWiggles is located in the United States, and therefore collects, processes, and stores your information in the United States. If you use any of our Services from outside of the United States, personal information that we collect from or about you will be transferred to and stored on servers inside the United States. Your use of the Services or provision of information to us constitutes your consent to the collection, transfer, use, processing, sharing, and storage of your information in the United States.

10. CHILDREN

WagWiggles’s Services are directed at a general audience and are not targeted to children. We do not knowingly collect personal information from children. If we learn that we have collected personal information from an individual under age 13, we will use reasonable efforts to promptly remove such information. If you believe that we may have information from a child, please contact info@wagwiggles.com. We do not knowingly sell or otherwise disclose the personal information of minors under the age of 16.

11. EXTERNAL CONTENT, LINKS, AND PLUG-INS

The Site may have links to external websites or applications, which may have privacy policies that differ from our own. We are not responsible for the practices of such third parties. The Site may also offer you the ability to interact with social plug-ins from external social media sites, which may allow us and/or the social media site to receive personal information from or about you. In some cases, we may know that you clicked on a social media plug-in, such as a Facebook “Like” or Twitter “Follow” button, or receive other information from the social media sites. Similarly, if you have previously provided personal information to an external party operating a plug-in on the Site, then such external party may recognize you on our platform. Your use of social network plug-ins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies carefully to understand their policies and your options. As with linked sites, we have no control over the information that is collected, stored, or used by social network plug-ins, and are not responsible for the practices of such sites.

12. PUBLIC FORUMS

Any personal information you choose to disclose on public blogs, discussion or message boards, in chat rooms, interactive forums, product rating or reviews sites, on other external websites that we may link to, or on other public areas on the Site, becomes public information. Please exercise caution when disclosing personal or other information in public areas. We are not responsible for the personal information you choose to post in a public forum. To request removal of your personal information from our Site, you may contact us using one of the methods listed in the “Contact Us” section below.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time. When we do, we will post the changes on the Site. Please visit this page periodically so that you will be apprised of any such changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.

14. CONTACT US

If you have any questions or comments regarding this Privacy Policy or any of the practices described herein, you can contact us by:

• Emailing info@wagwiggles.com
• Calling Petco Customer Service at (877) 738-6742; or
• Writing to us at WagWiggles, NEED ADDRESS, Attn: Privacy Team.