Privacy Policy
TERRACYCLE, INC.
Privacy Policy
Last Updated: June 6, 2023
This “Privacy Policy” describes the privacy practices of TerraCycle, Inc. (together with our affiliates, “TerraCycle”, “Company” “we”, or “us”) for the “Tiniest Biome” program, brought to you by TerraCycle Discovery (the “Program”). More information about TerraCycle, our recycling solutions, and our global subsidiaries can be found here.
This Privacy Policy describes how we collect, use, disclose, and otherwise process personal information in connection with the Program and explains the rights and choices available to individuals with respect to their information. As described in greater detail below, we collect your name, address, child’s name, and child’s diaper sample as part of the Program. We do not collect any sensitive personal information or use any personal information we collect from you outside the scope of the Program. More information about the Program can be found here. This Privacy Policy is subject to the Terms and Conditions that govern the Program and applies regardless of the means used to access or provide information in connection with the Program.
Individuals who are California residents should be sure to read the important information provided below in Notice to Californian residents – your California privacy rights.
1. Personal Information We Collect
2. Changes to your Personal Information
3. Cookies and Similar Technologies
4. How We Use Your Personal Information
5. How We Share your Personal Information
6. Your Choices
7. Security
8. Children
9. Other Important Privacy Information
10. Changes to this Privacy Policy
11. Contact Us
2. Personal Information We Collect
We collect 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 (“personal information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal information. To the extent this data is stored or associated with personal information, it will be treated as personal information; otherwise, the data is not subject to this Privacy Policy.
Category | Details | Purposes for Which Such Information Was Collected in the Preceding 12 Months or Will be Used | Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12 Months or will be Collected | Categories of Third Parties With Whom the Program Shares or Sells Personal Information |
Identifiers such as a name, Internet Protocol address, email address or other similar identifiers | When you register for the Program, we collect your name, address, your child’s name(s), child’s birthdate, and the username and password you use to create an account with us. We also assign a unique identification code that is associated with your sample. | We collect this information to administer the Program. | Directly from you. | We only share personal information with our trusted service providers and partners in a manner consistent with this Privacy Policy. |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | None | None | None | None |
Biometric information | When you register for the program, we ask you to provide details about your child, such as age, weight, and height. | We collect this information to determine your child’s growth compared to other children their age. | Directly from you. | None |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. | We may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our website. | We use the automatically collected information for troubleshooting and testing purposes, to better understand user interaction with our website. | Automatically or indirectly from you. | Analytics providers and social networks. |
Precise geolocation data | None | None | None | None |
Professional, education or employment-related information | None | None | None | None |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | None | None | None | None |
We collect the following sensitive data: child’s personal information in accordance with applicable laws. You have the right to limit the use of such sensitive data by sending your request using the following link: https://tiniestbiome.com/cpra
2. Changes to your Personal Information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your account or contacting our customer support indicated below.
3. Cookies and Similar Technologies
What are cookies?
We may collect information using “cookies” or similar technologies (altogether, “Cookies”). Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.
We use two broad categories of Cookies: (1) first party Cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our website; and (2) third party Cookies, which are served by service providers on our website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
For details on the Cookies we use and how to disable them, please see our Cookies Policy.
4. How We Use Your Personal Information
To administer the Program
We use your personal information to operate, maintain, and administer the Program, and to communicate with you regarding your participation in the Program.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
To create anonymous data and develop aggregate statistics and analytics
We may create anonymous data and/or develop aggregate statistics and analytics using your child’s sample and information derived from it. Aggregate statistics and analytics will be used to discover factors which may have an influence on the abundance and composition of gut microbes in children. We convert personal information into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention, and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Program; (b) protect our rights, privacy, safety, or property, and/or that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
Use for new purposes
We may use your personal information for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis and collect your consent for the new purpose as is lawfully necessary.
5. How We Share your Personal Information
Affiliates
We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.
Service Providers
We may employ third-party companies and individuals to administer and provide the Program on our behalf (such as customer support, hosting and storage, analytics, email delivery, marketing/advertising, and database management services). These third parties may use your information only as directed by Company and in a manner consistent with this Privacy Policy and are prohibited from using or processing or disclosing your information for any other purpose.
Third-Party Payment Processing
For online payments, we use the payment services of Authorize.net (https://www.authorize.net/). The personal information collected is encrypted. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://usa.visa.com/legal/privacy-policy.html.
Professional Advisors
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
Company may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the Terms and Conditions that govern the Program; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business Transfers
Company may sell, transfer, or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
Third-Party/Organizations
We may disclose your personal information:
- To third parties when you have requested such disclosure.
- To our partners in compliance with applicable laws. These partners may use your information only as directed by Company and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
- Anonymous data and/or aggregate statistics and analytics associated with your child’s sample may be shared with Kimberly-Clark Corporation or its affiliates, who are not involved in the sample analysis process.
Data Retention
Retention of personal information
We will retain your personal information for no longer than is necessary for the purposes stated in this privacy policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The personal information storage period may vary with scenario, product, and service. The standards we use to determine the retention period are as follows: the time required to retain personal information to fulfil business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the website; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc.
6. Your Choices
Access, update, correct or delete your information
If you have an account with us, you may review, update, correct or delete your personal information by logging into your account. You may also contact us at privacy@terracycle.com or 1-866-967-6766 to accomplish the foregoing or if you have additional requests or questions.
Right to correction
You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
Marketing communications
You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at privacy@terracycle.com or 1-866-967-6766. You may continue to receive service-related and other non-marketing emails.
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Program to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Program and may need to close your account. We will tell you what information you must provide to receive the Program by designating it as required in the Program or through other appropriate means.
7. Security
The security of your personal information is important to us. We take a number of organizational, technical, and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.
These include but are not limited to:
- Forcing APIs (REST and Pub/Sub) to operate over encrypted ports (HTTPS and TLS).
- Data encryption between services within the cloud-based systems used by TerraCycle.
- File encryption over file servers.
- Highly restricted access to Production Environments.
- Regular penetration tests
However, no security safeguards are 100% secure, and we cannot guarantee the security of your information. We will comply with applicable laws and regulations requiring that we notify you in the event your personal information is compromised as a result of a breach of our security measures.
8. Children
Although the Program involves analyzing samples from your baby, and we may ask that you provide certain information about your baby during the registration process, the Program is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@terracycle.com or 1-866-967-6766. If we learn that we have collected personal information from a child under age 16, will delete such information from our files as soon as reasonably practicable.
9. Other Important Privacy Information
Third-party sites and services
The Program may contain links to other websites and services. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
We may share your personal information with third parties (and in some cases, affiliates) for their direct marketing purposes. Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to request certain information regarding such disclosures within the immediately preceding calendar year. To make such a request, email us at privacy@terracycle.com. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
The California Privacy Rights Act (“CPRA”), or such other data privacy laws in your jurisdiction that apply to the Program, provides you with specific rights regarding your personal information. This section describes your rights under the CPRA and other applicable laws and explains how to exercise those rights.
Access, data portability, deletion rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You also have the right to request that we delete some or all of your personal information.
If requested as described below, we will disclose to you
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share the personal information
- The specific pieces of personal information we collected about you (also called a data portability request)
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased, and
- Disclosure for a business purpose, identifying the personal information categories that each category of recipient obtained.
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by contacting us at privacy@terracycle.com or 1-866-967-6766. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
- 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates personal information associated with this specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make a request.
Non-discrimination
We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
- Deny you goods and services
- Charge you different prices or rates for goods or services
- Provide you a different level or quality of goods or services
- Suggest that you may receive a difference price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Sharing personal information and right to opt out of the sale of personal information
California residents have the right to direct us to not sell their personal information at any time (called the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://tiniestbiome.com/cpra.
10. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make changes to this Privacy Policy, we will post them on the website and update the Last Updated date above. If we make material changes to this Privacy Policy, we will post a notice on our website. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes to the Program (or as otherwise indicated at the time of posting). In all cases, your continued use of the Program after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
11. Contact Us
If you have any questions or concerns at all about our Privacy Policy, please feel free to contact us at privacy@terracycle.com or 1-866-967-6766, or write to us at:
TERRACYCLE, Inc.
121 New York Avenue, Trenton, NJ 08638, USA