Être LLC, a Delaware public benefit limited liability company (“Être,” “we,” “us,” or “our”), has adopted this privacy policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy applies to any and all information you submit to us in connection with your access to and/or use of our website, https://www.etregirls.com/ (the “Website”), and if applicable, as a founder of your local chapter of, or participant in, our mentorship “club-in-a-box”, Club Être (“Club Être”). This Privacy Policy describes the types of information we collect from you through the Website and/or via Club Être, how we use and process that information, and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.  Please read this Privacy Policy carefully prior to your use of the Website or participation in Club Être.  If you do not agree to this Privacy Policy, do not use the Website or participate in Club Être. Seriously.

By accessing and using the Website or participating in Club Être, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use and disclosure practices described herein.  This Privacy Policy is governed by the Website Terms of Use, which includes all disclaimers of warranties and limitations of liabilities.  Capitalized terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Use.

The Website is meant for general audiences; however, we desire and strive to comply with the requirements of the Children’s Online Privacy Protection Act (“COPPA”), which was established by Congress to protect the online privacy of children under the age of thirteen (13) (i.e., twelve (12) years old or younger) (“Children,” and each, a “Child”), and we therefore do not knowingly collect information from Children without the prior consent of their respective parent or legal guardian. Additionally, in accordance with COPPA, we have adopted the Children’s Privacy Policy set forth towards the end of this Privacy Policy. The Children’s Privacy Policy describes when and what information we collect from Children, how we use it, and with whom we share it. We also describe in the Children’s Privacy Policy our method for obtaining verifiable parental consent from parents or legal guardians of Children as required under the law (“Parental Consent”). If you are a Child (meaning you are twelve (12) years old or younger) or are a parent/legal guardian of a Child, the terms of this general Privacy Policy will apply to you; provided, in the event of any conflict between the terms of this general Privacy Policy and the terms of the Children’s Privacy Policy, the terms of the Children’s Privacy Policy will take precedence.

For more information about COPPA and a Child’s right to online privacy, please visit the Children’s Privacy section of the FTC’s website at www.ftc.gov. We legit care about your privacy.

Information We Collect and Receive

In order for us to (i) provide you with the services and functionalities offered via the Website and/or enable you to participate in Club Être, (ii) engage in troubleshooting activities, and (iii) improve upon the Website’s performance, safety and security, we may collect and process some or all of the following types of information about you:

• Personal Information.  Information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, information you provide us in connection with a User Request, Verification/Consent Information you provide us, and certain other identifiable information you provide us in connection with other Être Communications with us, such as your name, age, date of birth, gender, email address, telephone number, and/or photograph (“Personal Information”);

• Usage Information.  Information that is not Personal Information, but that relates to your usage of the Website, or that is necessary for the proper functioning or improvement of the Website, including:  (i) times and dates and the extent of your usage of the Website; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) usage history such as areas and pages within the Website that you access or use and/or which buttons in the Website you click on; (v) search terms you type in on the Website; (vi) the URL or advertisement that may have referred you to the Website; (vii) the search terms you entered into a search engine or app store that may have led you to the Website; (viii) the mobile platform or service provider you use, and (ix) other device and Website access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers.

• Être Communications.  Information you voluntarily send to us via certain Être Communications, such as when you request support, send us comments or questions, report a problem to us, tell us something cool, or otherwise communicate in connection with your participation in Club Être.

• Third Party Information.  Information about you that we may receive from third parties.  For example, we may supplement certain information that we collect from you with outside records, or third parties may provide us with information about you in connection with a co-marketing agreement.  

While certain types of information described above, such as Usage Information and Third Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Website, as described above.  If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information.  We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

European Union Users

European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas.  Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“GDPR”), which are summarized below.

• Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address in connection with a User Request to receive Être Communications or to contact you regarding your creating a local chapter of, and/or participating in, Club Être.

• Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website and/or Club Être services, such as fulfilling any future services or transactions that may arise in connection therewith.

• Legal Obligations:  Sometimes the law requires us to collect and use your Personal Information.

• Legitimate Interests: This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests.  For example, we (i) use identity, device, and location information to prevent abuse of the Website and to keep the Website secure, (ii) may also send you promotional communications about our Website and services subject to your right to opt-out, and (iii) analyze how you interact with our Website so we can understand better what elements do or do not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.

Social Media Plug-ins

We may implement the use of certain social media plug-ins (e.g., Facebook, Twitter, YouTube) to allow you to communicate with such services and interact (e.g., “like” or “comment”) with various Website Content.  The social media plug-in, if and when implemented, will enable a direct communication between your end user device and the servers of the applicable social media provider, allowing the applicable social media provider to communicate with you and collect information about you browsing our Website. This processing is based on Article 6, Section 1(f) of GDPR and represents our legitimate interest to improve your Website user experience and to optimize those services and functionalities offered via the Website.  If you decide to use a social media plug-in that we implement on the Website, we may transfer your Personal Information whether or not you have a registered user account with the applicable social media provider. Please note that we are not responsible for the content and the data collection on respective third-party websites or apps and that we neither control the extent of Personal Information collected by the respective plug-in provider nor do we know the processing’s purpose or the period your Personal Information will be retained. For further information as to how and for what purpose certain social network providers process your data, please see the relevant privacy policies of three main social network providers (although note this list is not exhaustive), and their notification when you connect to the social network in question.

• Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA
  https://de-de.facebook.com/policy.php

• Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA
  https://twitter.com/privacy

• YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA
  https://policies.google.com/privacy?hl=en

Cookies and Other Tracking Technologies

We may use cookies, for example, to keep track of your preferences and Account profile information, or to engage in certain retargeting activities that we feel will better enhance your User experience and the efficiency and effectiveness of the Platform and certain services and functionalities offered thereon. Cookies are also used to collect general usage and volume statistical information that does not include Personal Information.  We may also use another company or third party service to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about Users of the Platform.  

These are not the cookies in your pantry. Cookies are small pieces of information that are stored as text files by your Internet browser on your computer's hard drive. Most Internet browsers are initially set to accept cookies. You can set your browser to refuse cookies from websites or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Platform, or certain offerings on the Platform may not function as intended or as well.  Also, some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. If you block cookies, certain features on the Platform may not work. If you block or reject cookies, not all of the tracking described herein will stop.  Please note that certain options you select are browser- and device-specific.

A more detailed list of the cookies we currently, or in the future may, use and how we use, or may use, them are as follows:

• Security: We secure the Website with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Use, such as unauthorized access or activity.

• Localization: We use some cookies to help us provide localized experiences, such as displaying the Website in the local language.

• Website Features and Services: Certain cookies provide greater functionality to the Website and help us deliver our products and services.

• Performance: We use performance cookies to help us route traffic between servers and understand how the Website is performing so we can provide users with the best experience possible.

• Analytics and Research: We use certain cookies and other technologies also help us to understand, improve, and research features and content on the Website, such as by using Google Analytics, which you can opt out of at {https://tools.google.com/dlpage/gaoptout}.

• Marketing and Online Behavioral Advertising: We may use cookies to help us deliver targeted advertisements through web browsers and on social media platforms based on your activity on the Platform and to track the performance of those ads.  In some cases, our partners may also use cookies to provide us with information about your interactions with their services, as applicable.  Those third-party cookies would be subject to such third-party service’s privacy policies.  The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. Visit {http://optout.aboutads.info/} to opt out of having your online behavior collected for advertising purposes.

Web Beacons

Our Website may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Website is used.

We use third parties to gather information about how you and others use the Website.  For example, we will know how many users access a specific page and which Website Content they clicked on. We use this aggregated information to understand and optimize how the Website is used.

Limiting or Blocking Cookies and Our Do Not Track Policy

Your browser may give you the ability to control cookies, which may depend on the type of cookie, and browsers can be set to reject browser cookies. However, blocking or deleting cookies may prevent you from using most of the Website.

Some browsers have settings may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. These features are not all uniform and there is no consensus among industry participants as to what “Do Not Track” means in this context.  If you block cookies, certain features on the Website may not work.  If you block or reject cookies, not all of the tracking described here will stop.  Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.  Note that certain options you select are browser- and device-specific.

How We Use the Information We Collect

We use the information we collect for the following purposes:

• To identify you and potentially improve and/or customize the Website;

• To protect our Website and improve security;

• To enable us to provide you with our Website and Club Être, and to improve and promote our Website, Club Être, and other awesome services;

• To address inquiries and respond to customer service requests, questions and comments;

• To send you requested service and other Website and Club Être information;

• To provide contact information to the current leadership or any coordinators of the local Club Être in which you have expressed interest in participating (“Local Être Leadership”);

• To send you newsletters and/or contact you with offers, promotions and other product specials;

• To engage in Être Communications with you;

• To create a more personalized user experience and customize certain Website Content you see on the Website;

• To track and analyze use of the Website and our services, such as to identify trends, conduct data analysis, and determine the effectiveness of our marketing and promotion and other service offerings;

• To improve your user experience and increase the efficiency and effectiveness of the Website and Club Être services and functionality offerings

• To maintain security and to enforce our Terms of Use and applicable law; and

• To solicit feedback, reviews, and other information regarding your experience with the Website and/or Club Être, including, without limitation, with respect to certain features and functionalities that you would like to see on the Website and/or for Club Être, or that we have recently rolled out;

• To test new features, service offerings and functionalities on the Website;

• For other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection.

We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.

How We Share the Information We Collect

We may share aggregated usage information and may otherwise disclose non-Personal Information that we collect to third parties.  However, absent your prior consent, we will share your Personal Information with third parties only (i) to the extent you have granted us written permission to do so in each instance (such as sharing your name and email address with Local Être Leadership, or sharing your name and other requested information to a company sponsoring a “lunch and learn” event) or (ii) in the ways that are expressly described in this Privacy Policy, including as set forth below.  We never sell your Personal Information to third parties.  

• We may use third parties to outsource one or more aspects of our business and/or Website and/or Club Être operations (such as email or customer service functions, data processing, web analytics, maintenance, online advertising, and security execution and clearing services), in which case, we may provide your Personal Information to such third parties in connection with the performance of such activities.  Such third parties will only use your Personal Information to the extent necessary to perform their functions and will be contractually bound to process your Personal Information only on our behalf and in compliance with our requests.

• We also work with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide them with information regarding traffic on the Website, including pages viewed, content interacted with, and actions taken by users when visiting the Website; to serve advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Website and the effectiveness of our advertisements and other marketing campaigns.  Our service providers may collect certain information about your visits to, and activity on, the Website as well as other websites or services, they may set and access their own tracking technologies on your device (including Cookies and Web Beacons), and they may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Website or other online websites and services. We may also share certain non-Personal Information with these parties, in connection with the services they provide to us.

• In the event that we undergo re-organization, are sold to or merged with a third party, or sell all or substantially all of our assets, any Personal Information we hold about you may be transferred to that re-organized entity or third party in compliance with applicable law.

• In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.

• We will also share your information with any member, subsidiary, parent or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimization of the Website, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.

• In addition to the foregoing, we also reserve the right, and you hereby authorize us, to share or disclose (including, without limitation, to law enforcement agencies, public authorities, governmental departments, or other similar organizations) information we collect, including your Personal Information, and any other information, records or electronic communications of any kind, when we determine (in our sole discretion), that the disclosure of such information is necessary to identify, contact, or bring legal action against you if: 

• you are or may be violating the Terms of Use or this Privacy Policy; 

• you are interfering with our or any third party’s rights or property; 

• you are violating any applicable law, rule or regulation; 

• necessary or required by any applicable law, rule or regulation, including a subpoena or similar legal process or request/order; 

• necessary or required for purposes of public importance, to protect our rights, protect your safety or the safety of others, investigate security, technical issues or fraud, or respond to a government request; and/or 

• requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency. 

Email Notifications and Opt-Out

We want to communicate with you only if you want to hear from us, such as in response to a User Request or when you subscribe to engage in Être Communications with us.  We will also send you service-related announcements when and as necessary. We try to keep emails to a minimum and give you the ability to opt out of any Être Communications we send.

We maintain a strict no-spam policy.  For all Être Communications, we will not use false or misleading subjects or email addresses, we will identify the message as an advertisement (if applicable) in a reasonable way, we will include the physical address of our business, we will monitor our third-party email marketing services for compliance, we will honor opt-out/unsubscribe requests quickly, and we will allow users to unsubscribe by using the link at the bottom of each email. If you are having problems unsubscribing, please contact us at privacy@etregirls.com by forwarding the email communication and including the word “Unsubscribe” in the subject line and we will use reasonable efforts to remove you within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.

Links to Third Party Websites and Services

The Website and certain Être Communications you receive from us may include links to Third Party Content with privacy practices may differ from Être’s privacy practices as described in this Privacy Policy. Être does not endorse any Third Party Content and/or the products or services they offer.  When you click, engage with, provide information to, or otherwise use a link to, any Third Party Content, the privacy policy and data processing disclosures for such Third Party Content shall govern and you do so at your own risk. We encourage you to carefully read the privacy policies of all Third Party Content, as it may differ substantially from that of this privacy statement. Être makes no representations or warranties with respect to, nor is Être responsible for any Third Party Content privacy policies.

Data Storage and Retention

Information collected by us may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using the Website, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent.  However, we will endeavor to take reasonable measures to keep up an adequate level of data protection also when sharing your Personal Information with such countries.

We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you.  We strive to keep our processing activities with respect to your Personal Information as limited as possible.  We will retain the information we collect from or about you only as long as necessary to provide you with the Website or our services, which includes for the duration of, but could extend beyond, your active participation in Club Être, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect Être’s legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.  By using the Website and/or participating in Club Être, and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties.  This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Website/participation in Club Être.

Cross-Border Data Transfers

Être is based in the United States so your information will be collected and processed in the United States, which has its own laws governing data protection and access to it, including by the government. If you reside outside of the United States, be advised that the rules that protect your Personal Information under United States federal, state, and local law may differ from those of your home country.

Your Rights Regarding Your Information

In certain circumstances you have the right to access the Personal Information that we hold about you and to correct, update, or request deletion your Personal Information.  Prior to the fulfilment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request.  Even after you request we delete your Personal Information, we may retain certain information as required by law or as necessary for our legitimate business purposes.

More specifically, you have the following rights:

• The right to require free of charge (i) confirmation of whether we process your Personal Information and (ii) access to a copy of the Personal Information retained;

• The right to request proper rectification, removal or restriction of your Personal Information;

• Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);

• Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;

• The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and

• The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis herein. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.

Security

The security of your information is extra important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Although we will do our best to protect your Personal Information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Website or in connection with Être Communications; any transmission is at your own risk.

We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such information confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete and absolute security of any Information collected, stored or used by us cannot therefore be guaranteed.  In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.  If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately.

If you have any questions about security on our Platform, you can contact us at info@etregirls.com. 

California Users

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for those third parties’ direct marketing purposes. As explained elsewhere in this Privacy Policy, we will not sell or transfer your Personal Information to any third-party companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Privacy Policy and our privacy commitments to our customers and Website users should not hesitate to contact us at info@etregirls.com.

Sweepstakes, Contests and Promotions

Winner, winner. We may offer sweepstakes, contests, and other promotions through the Website (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.

Updates to this Privacy Policy

We may change the terms of this Privacy Policy, including the Children’s Privacy Policy described below, at any time in our sole discretion. Whenever we make a material change, we will post such change on the Website or send you an email. The effective date of the most recent version of this Privacy Policy will appear at the top of this page. New versions of this Privacy Policy will never apply retroactively.  We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.  Once a change becomes effective, your continued use of the Website and/or participation in Club Être shall automatically constitute your acceptance of such changes.

Contact

Questions or comments about this Privacy Policy should be sent by email to info@etregirls.com.

* * *

CHILDREN’S PRIVACY POLICY

The privacy of Children is of the utmost importance to Être. Since Être may collect information from Children (i.e., persons under the age of thirteen (13)) in connection with Être Communications, we are committed to complying with COPPA. We have adopted this Children’s Privacy Policy in order to describe what Personal Information we collect from Children and how we use that information. We only collect Children’s Personal Information after obtaining Parental Consent except in certain limited circumstances as permitted by law. We also describe in this Children’s Privacy Policy how we obtain Parental Consent, and generally describe the rights of parents/legal guardians with respect to their Children’s information. Please note that this Children’s Privacy Policy is a part of Être’s general Privacy Policy and incorporates all of its terms; provided, in the event of any conflict between the terms of this general Privacy Policy and the terms of the Children’s Privacy Policy, the terms of the Children’s Privacy Policy will take precedence.  Capitalized terms used in this Children’s Privacy Policy but not otherwise defined shall have the respective meanings assigned to such terms in the general Privacy Policy and/or Terms of Use, as applicable.

As a parent/legal guardian, you always have the right to revoke your Parental Consent to our collection and use of your Child’s Personal Information at any time. You may also access, review, alter or delete your Child’s Personal Information by contacting us at info@etregirls.com.  We reserve the right to make reasonable efforts to verify that you are the parent/legal guardian of the applicable Child before taking any action in connection with such request. We will only store Children’s Personal Information as long as reasonably necessary to fulfill the purpose for which we collected that information in the first place (i.e., to engage in Être Communications to which the Child opted-in to with her Parental Consent).

Information We Collect from Children and Why

Prior to obtaining Parental Consent (the process for which is further described below), we only collect from Children, if necessary, Child Verification/Consent Information (i.e., first name and last name initial, age-verification information (i.e., date of birth), and parent/legal guardian’s email address). We only collect this information in order to establish whether we are required to obtain Parental Consent, and to obtain such Parental Consent. After we obtain Parental Consent, we may collect certain Child Personal Information in order to engage in Être Communications and enable such Children to participate in Club Être.

We also may collect non-Personal Information from Children. Whenever we tie non-Personal Information to a Child’s Personal Information, we will treat it as Personal Information. We also use cookies that do not identify Children for analytical purposes as detailed further in the Privacy Policy. 

Être currently does not have any interactive user areas or features that allow Children to make their Personal Information publicly available (e.g., blogs or public forums). If we ever decide to include features that will allow this type of disclosure, we will update this Children’s Privacy Policy, notify parents/legal guardians, and obtain Parental Consent before allowing a Child to access such features.

We only collect and use information, whether personally identifiable or not, from Children that is reasonably necessary for us to make the Être’s services (including Club Être) available, for the internal operations of the service, and to evaluate and improve our services.

To Whom We Disclose Children’s Information

We only provide Children’s Personal Information to our trusted service providers who have agreed to maintain the confidentiality of that information, and who assist us with the internal operations of the Être, and as otherwise expressly stated in the general Privacy Policy.  We never sell any Child’s Personal Information to any third party, and we do not use it for behavioral advertising purposes. However, we may offer contextual advertising on Être.

How We Obtain Consent from Parents and Legal Guardians

We will obtain Parental Consent prior to collecting any Personal Information from a Child (except in certain limited circumstances, as allowed by COPPA). We currently do this using the “email plus” method, as follows: First, from each Child who provides a User Request and/or wishes to engage in Être Communications with us, or to participate in Club Être, we will collect Child Verification/Consent Information. Second, we will send an email to the parent/legal guardian’s email address containing a notice of the information we wish to collect and how we would like to use it, along with a link to provide Parental Consent. If the parent/legal guardian either affirmatively declines Parental Consent or fails to respond to our request for Parental Consent within seven (7) days of when we send the email, we will automatically delete all of the information provided by the Child. Third, if the parent/legal guardian does grant Parental Consent to the Child’s Subscription, we will send the parent/legal guardian a confirmation email with information on how he or she can revoke their Parental Consent.

Note to Parents or Legal Guardians of Children Ages 13 and Older

Être recommends that parents/legal guardians take an active role in their children’s use of the Internet. If your child is thirteen (13) years old or older, but younger than the age of majority under applicable law of the jurisdiction of your primary residence (typically eighteen (18) years old), and is using the Website or previously registered to receive Être Communications, that child represented and warranted in the Terms of Use that they had their parent/legal guardian’s permission to do so. If that was not the case, please instruct your child not to access or use the Website and email us at info@etregirls.com requesting that we no longer send your child Être Communications and delete her Personal Information for our records.  We will contact you are promptly as practicable to take the appropriate steps necessary to complete this request.

Last Updated: 2020