Updated:  January 1, 2022 

This Privacy Policy (this “Privacy Policy”) explains how the Simms/Mann Institute for Education and Community Development, Inc. and Simms Mann Institute Products LLC (collectively, with all of their subsidiaries and affiliates, “Institute,” “we” or “our”), treats information about you that Institute collects and receives through your use of https://www.CuddleBright.com/ (the “Site”) and the services, including our products, content and content offerings, we may provide to you (together with the Site, referred to in this policy collectively as the “Products and “Services” respectively).  By using the Site or Services, you agree to the terms of this Privacy Policy and our Terms of Use (“Terms of Use”).

We reserve the right to modify this Privacy Policy from time to time and will mark new versions with a corresponding effective date.  We recommend you visit the Site to review any changes in our practices.  Your continued use of the Site or Services constitutes your agreement to our then-current Privacy Policy. 

The Site may contain links to other websites.  These websites may have privacy policies different than this Privacy Policy.  The Site may also contain certain social media icons or widgets. Although you can view the material we have linked to, you may have to create an individual account or register to use these third-party social media sites to use interactive features.  Any interaction on social media websites is governed by the terms of use and privacy policy of the particular platform.

When we refer to “you” or “your,” we mean the person accessing the Services.  If the person accessing the Services acts on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.  

What Information Is Collected?

We collect, retain and use information voluntarily provided by you through your use of the Site and Products and Services.  For example, the information we may collect and retain includes, but is not limited to, the following categories of information:

• Your contact information, such as your first and last name, occupation, business title/position, company name, home and mobile phone number, e-mail address, home and employer address, fax number, unique device identifier of your devices that connect to or access the Site, demographic information and/or payment information when you communicate with Institute, use the Services, request materials or subscribe to our content or services;
• Your username and password in order to register to create an account;
• Your payment information, including, but not limited to, credit and debit card information and bank account number, in order to enable you to purchase the Products and Services;
• Your subscription history relating to the Site and use of the Products and Services;
• Information regarding your browser and other technical specifications required to use our Site;
• Computer data or files, often called “cookies,” including web beacons, pixels, gifs, widgets, tags or similar technologies, which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of the Site and to perform certain functions, such as saving your passwords and your personal preferences regarding the use of the Site, evaluating the popularity of those links or the information contained in emails or on third-party sites; and
• Other information regarding your use of the Site or Services, Site usage statistics, time stamps, IP address, browsing history, clickstream data, general geographic location, product settings, adjustments made to products, types of device you use to connect to the Site, type of computer operating system you use (e.g., Microsoft Windows, Google Chrome OS, Mac OS, Android or iOS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari) and the domain name of your internet service provider.  We use this information to measure our website traffic, diagnose problems with our server, administer our Site, analyze trends, improve the Site, and to help provide a more personalized experience.

How We Collect User Information?

We may collect personal information from you on our Site or through our Products and Services when you undertake any of the following actions:

• Access, use or browse the Site;
• Register for an account on the Site;
• Order or request the Products, Services, content offerings, literature, services or other information during your visit to the Site via e-mail, fax or other online or offline means;
• Contact, communicate with or otherwise interact with Institute or its personnel via e-mail, the Site, including its blogs or discussion portals and forums, fax, telephone, or by other means whether online or offline;
• Sign up to receive announcements, e-mails, newsletters or other marketing materials; 
• Contact, communicate, post or comment via the blogs or discussion portals and forums on the Site or which are otherwise sponsored by Institute;
• Register, enroll or participate in surveys, questionnaires, promotions or any other service(s), events or activities online or offline sponsored by Institute, or offered in connection with the Site or Services.  

In addition, and as described in this Privacy Policy, we may also obtain personal information from third parties and sources other than our Site or Services, such as advertisers, marketers and analytic data collection services.  If we combine or associate information from other sources with personal information that we collect throughout the Site or Products and Services, we will treat the combined information in accordance with this Privacy Policy.   

How Is User Information Used?  

We may use all the information you provide, or that we collect or receive, in a variety of ways in connection with the operation of the Site and the Products and Services. For example, we may use personal information about our users for a variety of purposes related to our business, including, but not limited to:

• Developing, operating, maintaining, enhancing, and providing all of the features and services found on our Site or Services now and in the future;
• Understanding and analyzing the usage trends and preferences of our users, to improve the way our Services works, and to create new features and functionality;
• Allowing you to receive information from us regarding Institute, Products, Services or other products or services;
• To process customer-initiated or authorized payments;
• Tracking information about your visits to our Site or use of the Products and Services to allow us to provide better service;
• Sending or initiating direct marketing programs, such as newsletters or information about the Site, the Products and Services and new products or services we are offering;
• Contacting you regarding an inquiry on the Site or Products and Services that you have initiated;
• Using content from social media platforms where you discuss our products or use a hashtag related to the Products and Services;
• Allowing you to comment or post on the blogs or discussion portals or forums on the Site or sponsored by Institute ;
• Other purposes necessary to carry out our obligations under this Privacy Policy or our Terms of Use; and
• With the authorization of users, we may also display on our Site personal testimonials of satisfied users of our Site and Products and Services.

How Is User Information Shared?

Institute may share information about you as follows:

• We may provide users’ personal information to third-party service providers, suppliers, payment processors, vendors, advertisers, consultants and affiliates, which may include our independent contractors, for purposes of, including, without limitation, providing the Products and Services; initiating and collection of user payments; initiating direct marketing programs on our behalf; data tracking; maintenance or development of our Site and/or Products and Services; development of online products, services, or customer service or new product development; or other contracted promotional opportunities provided to our users.  
• We may share information, which is aggregated and anonymized regarding your online browsing preferences to evaluate our products or allow our third-party service providers and vendors that we work with to better serve our users.  We will not share your personal information in these instances, other than as described in this Privacy Policy. 
• We may also share your personal information in connection with law enforcement requests or in response to investigations, subpoenas, court orders, or other legal process to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.
• We may also disclose your information to an affiliated or unaffiliated third party as part of reorganization, merger, sale, joint venture, assignment, bankruptcy (or similar proceedings), transfer or other disposition of all or any portion of Institute’s business or operations, including those of its subsidiaries or divisions.  Any third party to which Institute transfers or sells the Products and Services or related assets will have the right to continue to use the personal and other information that you provide to us.
• We may share your information as otherwise authorized by you.  

Behavioral Advertising

We may also use third-party vendors, such as Google Analytics, to advertise to our users online. These third-party vendors may display Institute’s product and service advertisements on other websites based on your Internet usage.  More specifically, these vendors may use first-party cookies, third-party cookies and other tracking technologies, including, but not limited to, Google Analytics, Hotjar, Facebook Pixel, Facebook Custom Audience, Facebook Connect, Google Adwords, and others, together to inform, optimize and serve ads based on your past visits to the Site or another site affiliated with Institute’s products or services. You can opt-out of Google Analytics for Display Advertising by using Google’s Ads Settings.

How Is User Information Protected?

We maintain reasonable administrative, physical and technical safeguards for all user information collected through our Site and Services.  All information provided to Institute is transmitted using SSL (Secure Socket Layer) encryption.  SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us.  We also protect account information by placing it on a secure portion of our Site that is only accessible by certain qualified employees of Institute.  Unfortunately, however, no data transmission over the Internet, wi-fi, Bluetooth, or other communication protocol is guaranteed to be 100% secure.  While we strive to protect your information, we cannot ensure or warrant the security of such information.

How Can Users Limit Information Collected?  

While we work hard to use and disclose our users’ personal information only for the purposes identified above, you can choose not to provide personal information or limit the personal information obtained by us as follows:  

• You may have your contact information removed from our marketing lists to inform users of new or relevant products, services and special offers by clicking on the unsubscribe link in any communication received from us, or by emailing us at Institute.
• You may limit the collection of “cookies” through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the Site and/or Services.
• You may limit the ability of Google Analytics to track your online activity, as outlined in the “Behavioral Advertising” section above.

Communications with You

You authorize Institute to transmit e-mail, send postal mail or to telephone you to (i) respond to your communications or requests, (ii) promote our products/services, including without limitation the Services, and (iii) for the purposes of any applicable law regarding notification of persons whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person, any required notification may, where permitted by law, be made by the use of e-mail, telephone, fax or mail (including a notice printed in an available area of a bill or statement) or by posting a notice on the Site.  YOU AGREE TO THE FOLLOWING MEANS OF COMMUNICATIONS.

Children Under the Age of 18

Our Site and Services are not designed for children, and we do not knowingly collect information from any person under the age of 18.  If you are under the age of 18, you are not permitted to register for an account on the Site or to otherwise submit any personal information to Institute.  If you provide information to Institute through the Site, Services or offline, you represent that you are 18 years of age or older.  

Updating Your Information

You are responsible for keeping your information current.  You may update your information by contacting us at info@cuddlebright.com. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Institute’s internal reporting, processing and retention policies and all applicable legal obligations.  

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at info@cuddlebright.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Notice of Privacy Rights of California Residents

If you are a resident of the state of California, the following rights are available to you under the California Consumer Privacy Act.

Right to access

You have the right to request that we disclose the categories of personal information collected, the categories of sources from which personal information is collected, the business or commercial purpose for collection, the categories of third parties with which we share personal information, and the specific pieces of personal information that we have about you.  You also have the right to request that we provide your personal information to you in a readily useable format. 

Right to request deletion

You have the right to request that we delete personal information that we collected from you.  Note, however, that certain requests to delete personal information may be denied if we are required or authorized to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations, including, but not limited to, to provide a customer requested product or service.  Historical transactional records cannot be deleted.  

Right to non-discrimination

You have the right not to receive discriminatory treatment by Institute for exercising these privacy rights.  We do not offer financial incentives related to the provision of data.  

Authorized agent

You have the right to designate an authorized agent to make these requests on your behalf.

To exercise any of these rights, please e-mail us at info@cuddlebright.com.   To protect your privacy, you will be required to provide authenticating information prior to making changes or gaining access to your information.  We will respond to inquiries, requests to review, and change requests to personal information within forty-five (45) days.

Sales of Personal Information

Institute does not sell your personal information.

International Visitors and Data Transfers

The Site is hosted in the United States and is intended for United States visitors.  If you are accessing the site from the EU or other regions with laws governing data collection and use that may differ from the laws of the United States, please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer.  When we transfer personal data from other countries, including to the United States, we use a variety of legal mechanisms to help ensure your data is appropriately protected.

Other International Users

If you are visiting the Site from outside of the United States, your connection may be made through and to servers located in the United States, your registration, entries and orders placed through the Site may be fully processed in and from the United States, and all information you provide may be processed and maintained in our web servers and internal systems located within the United States.  The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected.  By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.  By using the Site, you authorize the export of personal information to the United States and its storage and use as specified above when you provide such information to us.  This Privacy Policy and our legal obligations are subject to the laws of the State of California and the United States, regardless of the location of any user.  Any claims or complaints must be filed exclusively in the courts of the United States in the State of California, Los Angeles County. 

Contacting Us

For additional information pertaining to our Privacy Policy, please contact us at the following address:  

The Simms/Mann Family Foundation 

9320 Wilshire Blvd. Suite 300

Beverly Hills, California 90212

You can also send an email to:  info@cuddlebright.com.  Please do not include personal or other sensitive information in your e-mail correspondence.