Privacy Policy

As the industry leaders in 3D pens in the classroom and at home, the company WobbleWorks, Inc., and its affiliates and subsidiaries, (“3Doodler”, “we” or “us”) is committed to protecting your privacy. This Privacy Notice explains the personal information we collect and why we collect it.

When you are accessing, browsing, navigating and/or using the website 3doodle (the “Site”), you communicate your Personal Information to 3Doodler. Please be aware that our app is managed by a third party. For more details on app-related privacy, please visit https://www.makeree.com/privacy.

Please read this Privacy Notice carefully as it explains how 3Doodler collects, uses and discloses your Personal Information when you visit or make a purchase from the Site and how you can exercise your rights in this regard.

Should you have any questions, you may directly contact us by sending an email to: info@the3doodler.com.

Depending on your residency, you may have additional rights and information available to you:

Residents of the EU/EEA/UK
Residents of California
Residents of Nebraska, Rhode Island, and Texas

1. What Information We Collect

When you visit the Site, we collect certain information directly from you about your device, your interaction with the Site, and other information necessary to process your purchases. We may also collect additional information if you contact us for customer support. We also may collect information from certain third parties, such as our payment processors and customer service providers. In this Privacy Notice, we refer to any information about an individual (including the information below) as "Personal Information."

In the past 12 months we may have collected:

Type of Personal Information	Examples of Personal Information	Disclosures to Third Parties
Identifiers	First name, last name, username, email address, phone number, mailing/shipping address, billing address	Corporate affiliates, service providers and other third parties as permitted by law or with your consent
Characteristics of Protected Classifications	Age and gender	Corporate affiliates, service providers and other third parties as permitted by law or with your consent
Commercial information	Payment account information and history of purchases	Corporate affiliates, service providers and other third parties as permitted by law or with your consent
Internet or other electronic network activity information	Date and time of the visit, IP address, device, browser, operating system, system configuration data, pages viewed, search queries, websites you came from before visiting our Site.	Corporate affiliates, service providers, advertising and analytics partners, and other third parties as permitted by law or with your consent
Non-precise geolocation data	Location (based on your IP address)	Corporate affiliates, service providers, advertising and analytics partners, and other third parties as permitted by law or with your consent

The provision of certain types of Personal Information may be mandatory or optional. Mandatory information will be marked as such at the time of collection. If you refuse to provide mandatory information we may not be able to process your request.

Certain of the information we collect may be considered Sensitive Personal Information. We use Sensitive Personal Information for legitimate business purposes, including to (i) perform services or provide goods reasonably expected by an average person; (ii) detect security incidents; (iii) resist malicious, deceptive or illegal actions; (iv) ensure the physical safety of individuals; (v) for short-term, transient use; (vi) perform or provide internal business services; or (vii) verify or maintain the quality or safety of a service or device. We do not sell or share (as defined under California law) any Sensitive Personal Information.

2. How We Use Your Personal Information

3Doodler may process your Personal Information for the following purposes:

Purposes	Examples of use of your Personal Information	Legal bases (applicable only when you are based in the EEA/UK)
Managing your online request	to manage your online request (including live chat) to recontact you	Legitimate interest of 3Doodler to manage its online requests
Creating and managing your account	to create and manage your account	Terms of Service
Managing your purchase order	to manage your purchase order to manage payments and billing related to your orders to ensure customer relationship management	Terms of Service
Direct marketing communications[1] [2] [DS3] [DC4]	to send you electronic communications about our activities that might interest you (e.g., if you have subscribed to our mailing list)	Your consent
Improving the Site and your user experience	to evaluate and improve the Site to facilitate your navigation on the Site to take steps designed to protect the security of the Site	Legitimate interest of 3Doodler to improve the Site and your user experience
Pre-litigation or litigation management	to take action against any identified breach to manage any dispute or litigation	Legitimate interest of 3Doodler to defend its rights and interests
Compliance with legal and regulatory obligations	to comply with applicable legal and regulatory obligations to manage your requests when you exercise your rights	Legal and regulatory obligations to which 3Doodler is subject

3. Disclosures of Your Personal Information

In the past 12 months, we may have disclosed the Personal Information described in Section 1 to the following recipients:

Recipients	Purposes
3Doodler, its duly authorized employees	For administrative, operational and commercial management of the Site and to process your requests and orders.
Service providers (e-commerce service provider, third party payment processing services providers, hosting provider, IT service providers, social media, etc.)	For operational and technical purposes related to the Site and related services, as well as to satisfy purposes of Section 2.
Third party advertising partners (Google, AdRoll, Facebook, etc.)	For advertising our products on third-party websites and mobile apps, matching you with the users of third-party advertising partners and creating targeted audiences for our products ads.
Promotion partners	For conducting joint marketing or promotions.
Law enforcement, judiciary and government regulators	Exclusively in case of an express and justified request from them or in case of an alleged violation of legal or regulatory provisions.
Lawyers and all interested parties	Exclusively in the case of the management of possible disputes and other legal matters where appropriate.
Other third parties	Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of 3Doodler or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where Personal Information is transferred to one or more third parties as assets of 3Doodler.

4. Security

We have implemented technical and organizational measures designed to protect your Personal Information. However, please understand that no method of transmission over the Internet or method of storing data is 100% secure. Therefore, we cannot guarantee absolute security.

5. Data Retention

As a general rule, your Personal Information will only be retained for the period necessary for the accomplishment of the purposes for which such information was collected, or as necessary to fulfill legal or regulatory obligations.

Your Personal Information will be kept as long as

We have a relationship with you;
We are required by law;
We need to in order to protect ourselves as a business or protect any other third party.

6. Transfers of Your Personal Information

We are located in Hong Kong although our service providers are located in countries worldwide. This means that we may transfer your Personal Information across borders. Where we are required to protect a transfer of Personal Information across borders, we will implement appropriate safeguards (such as European Commission approved Standard Contractual Clauses or an intercompany agreement with appropriate contractual protections) to protect that Personal Information. Please contact us using our details above should you require further information about the contractual protections we use.

7. Minors

The Site is not intended for individuals under the age of 18. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the email address above to request deletion.

8. Third-Party Services

Our Site may contain references and/or links to third-party websites and services, including references and links to third parties that accept and process your payments to us and operate our loyalty program. We are not responsible for any third party's data collection or privacy practices, and we have no control over what information third parties track or collect. Any access to and use of such linked websites is not governed by this Notice but instead is governed by the privacy policies of those third-party websites. We encourage you to review the privacy policies posted on those third-party websites for further information.

9. Marketing Opt-Outs

Opting-Out of Marketing Emails: You can unsubscribe from our marketing and promotional communications by clicking on the unsubscribe link in the emails that we send. Even if you opt-out of marketing, we may still communicate with you; for example, to send you service-related messages that are related to the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies When you visit or use our website or online services, our server may create cookies, which are small text files that a website can send to your internet browser and may be stored in your browser or elsewhere on your computer. To learn how we use cookies and how to opt-out of our use of non-necessary cookies, please visit our Cookie Notice.

10. Contact us

If you have questions or comments about this policy, you may email us at info@the3doodler.com.

You can also write us at:

WobbleWorks, Inc. / 3Doodler
89 5th Avenue
Suite 602
New York
NY 10003
USA

11. Updates to this Privacy Notice

We may update this Privacy Notice from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. Therefore, we recommend you review this Privacy Notice each time you visit the Site.

12. EU/EEA/UK Data Rights

If you are based in the EU/EEA/UK, you have the following rights over your Personal Information:

Your rights	Scope of your rights
Right to access	You have the right to request: ? confirmation of whether 3Doodler processes your Personal Information or not; ? a copy of such Personal Information; and ? information on the use of your Personal Information by 3Doodler in a clear, transparent and understandable way (as provided in this Privacy Notice).
Right to rectification	You have the right to request the correction of your Personal Information if your Personal Information is obsolete, inaccurate or incomplete.
Right to delete	You have the right to request the deletion of your Personal Information (or right to be forgotten), when one of the following conditions applies: ? you object to the processing of your Personal Information and there are no overriding legitimate reasons justifying the continued processing of your Personal Information (e.g., legal obligation); ? you object to marketing activities; ? you decide to withdraw your consent on which the processing is based; ? your Personal Information is no longer useful for the original purposes for which it was collected or for any other type of processing; ? the use of your data does not comply with the applicable legal or regulatory provisions.
Right to restriction of processing	You have the right to request the restriction of the processing of your Personal Information during a limited period of time, in particular in order to verify your Personal Information or 3Doodler's processing of it, where one of the following conditions applies: ? you contest the accuracy of your Personal Information, the processing of which is thus restricted for the period necessary for 3Doodler to verify the accuracy of such Personal Information; ? the processing is unlawful and, rather than requesting the deletion of your Personal Information, you prefer to restrict its use; ? 3Doodler no longer needs your Personal Information for the purposes of the processing, but you need your Personal Information for the establishment, exercise or defense of legal claims; ? you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of 3Doodler may override your interests, rights and freedoms.
Right to data portability	You have the right to request a copy of your Personal Information in a structured, commonly used and machine-readable format and also request the transmission of your Personal Information to another data controller where technically feasible. This right is not exercisable in all circumstances, it applies only if it fulfils all the following conditions: ? your request is only related to your Personal Information (excluding anonymous or third-party data); ? your request does not adversely affect the rights or freedoms of others, in particular those of 3Doodler (e.g., trade secrets) or those of third parties (e.g., intellectual property rights); ? the processing is carried out by automated means (paper files are therefore not included); ? the processing is based on consent or the performance of a contract (to check if it is the case, you can see Section 2 of this Privacy Notice).
Right to object	You have the right to object to our processing of your Personal Information at any time if the processing is based on our legitimate interest. 3Doodler will no longer process your Personal Information, unless 3Doodler demonstrates compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, such as the respect of a legal obligation or for the establishment, exercise or defense of legal claims.
Right to withdraw your consent	You have the right to withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the Personal Information processing operations previously carried out.
Other rights	Depending on your country of residence, you may have additional local rights with respect to our processing of your Personal Information.

It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in Section 2 of this Privacy Notice, as follows:

	Access	Rectification	Erasure	Restriction	Data portability	Objection
Consent	Yes	Yes	Yes	Yes	Yes	Withdrawal of consent
Steps prior to entering into a contract			Yes		Yes	No
Contract			Yes		Yes	No
Legitimate interest			Yes		No	Yes
Legal obligation			No		No	No

Under certain circumstances, we may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that Personal Information is not disclosed to an individual who does not have the right to receive it.

If you have any questions or wish to exercise your rights, you may directly contact us by sending an email at: info@the3doodler.com.

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

13. California Privacy Disclosures

These Additional California Privacy Disclosures supplement the information contained in the Privacy Notice. These Disclosures apply only to individuals residing in California.

The types of Personal Information 3Doodler collects, the sources, and the manner in which 3Doodler collects that Personal Information can be found in the "What Information We Collect" section of the Privacy Notice.

We may use and disclose Personal Information for the business and commercial purposes detailed in the "Disclosures of Your Personal Information" section of the Privacy Notice.

We retain your information as described in the "Data Retention" section of the Privacy Notice.

We have not sold consumer information for any monetary value. However, our use of cookies, and tracking technologies may constitute "sharing" under certain U.S. state consumer privacy laws. We have sold or shared the following categories of Personal Information with our targeted advertising service providers and partners: Identifiers, Non-precise geolocation data, and Internet activity information. We do not knowingly sell the Personal Information of minors under 18. To opt-out of targeted advertising, please use the "Do Not Sell or Share" link at the bottom of our home page, contact us at info@the3doodler.com or call us at +1-888-321-1330.

Shine the Light

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties to which we disclosed Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Your California Rights

If you are a California resident, you may have the following rights with respect to the Personal Information we process about you:

Right to Know and Access. You may have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, selling, or sharing the Personal Information, and the categories of third parties to whom we have disclosed your Personal Information, and the specific pieces of Personal Information we have collected about you.
Right to Delete. You may have the right to request that we delete Personal Information that we have collected from you.
Right to Correct. You may have the right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Opt-out of Sales or Sharing. You may have the right to opt-out of the "sale" or "sharing" of your Personal Information as those terms are defined by the California Consumer Privacy Act.
Right to Non-Discrimination. Should you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand certain features of the Services may be unavailable to you.

Exercising Your California Rights

Please contact us using the information provided in the "Contact Us" section below to exercise your rights.

You can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable law.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

Contact Us

If you have questions about these Disclosures or how we process your Personal Information, or if you would like to exercise any of your privacy rights, you may contact us by emailing info@the3doodler.com or +1-888-321-1330.

14. Additional U.S. State Privacy Disclosures

These Additional U.S. State Privacy Disclosures supplement the information contained in the Privacy Notice. These Disclosures apply only to residents of Nebraska, Rhode Island, and Texas.

We have not sold consumer information for any monetary value. However, our use of cookies, and tracking technologies may enable us to engage in targeted advertising. We use the following categories of Personal Information with our targeted advertising service providers and partners: Identifiers, Non-precise geolocation data, and Internet activity information.

Consumer Privacy Rights You may have the following rights, subject to any applicable exemptions or limitations:

Right to Access. You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Delete. You have the right to request that we delete your Personal Information under specific circumstances.
Right to Opt-out. You have the right to object or opt-out of processing for the purpose of targeted advertising.
Right to Data Portability. You have the right to request a copy of your Personal Information in an accessible format.
Right to Equal Service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites, services, or properties.
Right to Appeal. If we do not grant your consumer request, you may have the right to appeal that denial.

You can exercise your privacy rights as described in "Submitting a Privacy Rights Request," below.

Submitting a Privacy Rights Request

To exercise any of the state rights above, please submit a request to us by either by calling us at +1-888-321-1330. or by emailing us at info@the3doodler.com. Making a consumer request does not require you to create an account with us. Applicable law may limit the number of times that you can submit a particular request within a 12-month period.

We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.