Last Modified: September 20, 2021

Our Privacy Policy

Welcome to our company’s privacy policy! We’re glad that you’d like to know more about how
we keep your information safe. This policy will give you information about how we look after
your personal data when you visit our website (regardless of where you visit it from) or use our
services or our applications (apps). The policy also tells you about privacy rights and how the
law protects you.

So, if you’re looking for more information on how we collect, store, use and share your personal
data we collect, this is the place for you!

Now to start us off with, a couple of practical but highly important details for you to take note of!

Who we are
LaughingBirds.com is owned by The Results Group LLC. When we use “we”, “us” or “our” in
this policy, we are actually talking about Results Group LLC.

How to contact us
We don’t have an appointed a data protection officer (“DPO”). You get to talk with one of the
senior leadership directly who take responsible action for overseeing questions in relation to this
privacy policy. If you have any questions about this policy, please contact us at:

Results Group

Attn: Data Protection People
Or by email: Info@LaughingBirds.com
Telephone: +1 860-228-6728

Your rights as a someone we have personal data about (data subject)
You can make changes to your account information yourself by editing them from within your
account settings. If you wish to unsubscribe from e.g. newsletters or marketing emails you will
be able to do so via the link provided in those emails. If you wish to delete cookies placed, our
cookie policy will help show you how to do that (more on that later in the Policy under Cookies).
At any point while we are in possession of or processing your personal data, you have the
following rights:

1.  Right of access – you have the right to request a copy of the information that we hold about you.
2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. If we are legally obligated to keep the information or if it is impossible or unproportionate, we won’t delete it but we will only keep it for as long as it is needed and we have time limits on our data systems.
4.  Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
5. Right of portability – you have the right to have the data we hold about you transferred to another organization.
6. Right to object – you have the right to object to certain types of processing such as direct marketing.
7. Right to object to automated processing, including profiling – you also have the right not to have a computer make decisions about you directly (this doesn’t include general marketing based on your age or gender).
8. Right to judicial review – if we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

One thing to bear in mind before contacting us. Our sites and applications may contain links to other sites not owned or controlled by us. It could as an example be social media platforms/services. We are not responsible for the privacy practices of those sites, so if you
have questions regarding such sites, you need to contact the site directly. We also really
encourage you to be aware and read the privacy policies of other sites because they may very
easily be collecting, storing, using and sharing your personal information.

Complaints about our behavior

You have the right to complain if you don’t feel the Results Group is living up to our
responsibilities when it comes to your data.

Our senior leadership at the Results Group take your complaint very seriously. You can contact
us on this email info@LaughingBirds.com We will send you a confirmation within 7 days and do
our very best to deal with the issue within 1 month. If the issue is
You can complain about:

1. how your personal data has been processed;
2. how your request for access to data has been handled;
3. how your complaint has been handled;
4. appeal against any decision made following a complaint.

Our rules for collecting data
We take your privacy really seriously, so we’ll only ask for the information we need to have so
we can give you great service.

Whenever we collect customer data, we make sure:

• We ask for permission to collect the data
• We only use the data for the agreed reason and for the time it’s needed
• We will as a minimum meet the local data protection laws in the country where we provide you with a service via our website or our applications.
• We keep data that we’re legally required to have on record
• We explain why we need the data and how we’ll use it (unless we have legitimate reason
• not to)
• We check and update privacy information on a regular basis (we might also cross-check the data against other database to make sure it’s correct)
• We don’t share data with anyone unless we have a legal or legitimate reason, or we have permission from you or if you are a child under 16 from your parents.
• Collecting data in our online channels

We collect your personal and anonymous information from you when you visit any of the sites
on our LaughingBirds.com domain or when you use one of our applications. When you visit our
online channels, you’ll be able to check if we’re collecting data under terms and conditions of
the site.

We also receive information via third party when you visit our page on social media sites or
channels (e.g Facebook, Twitter, Youtube, Instagram, Wechat etc).

Types of personal information we collect

When you’re visiting any of these online channels, we may collect:

• Registration information that we use to help you set up an account (e.g. your name, country, gender, date of birth, email address, username and password).
• Payment or transactional information that we use when you buy products or use online services (e.g. postal address, phone number or credit card number).
• Location information or your IP Address that we use to give you relevant online content.
• Information you’ve shared publicly on our forums.
• Information you’ve sent to an individual or group using our messaging, chat or post services
• Information you provide when you use our own online channels or third-party channels (such as social networks) or if you link your LAUGHINGBIRDS.COM registration account to a third-party platform.

Why we need to process personal data

In legal terms, the way we ‘process data’ describes how we collect, store, use, share and delete
the data we receive from customers. When you share your personal information with us on our
online channels, we’ll process your data as described in this Privacy Policy.

As we’re a global company that sells toys directly to customers and offers many different
experiences for our fans, we need to process personal customer data, so that:

• Customers can buy products from our online LAUGHINGBIRDS.COM Shop and have them delivered where they want
• Customers are able register for any accounts and services they want to use
• Customers can use the online and offline LAUGHINGBIRDS.COM experiences we’ve created for them
• Customers can share information on our public forums
• We can send customers any information they’ve asked us for or answer their questions
• We can ask customers to give us feedback on our services through questionnaires and surveys
• We can provide our customers with relevant marketing information about our products.

Always keep in mind, that if you’re using a LAUGHINGBIRDS.COM service through a third-party
channel like social media or a LAUGHINGBIRDS.COM app, your personal data may also be
processed by that third-party according to their own privacy processes.

We may use automated decision making in processing your personal information for some
services and products. An example is our fraud prevention and detection efforts on
shop.LaughingBirds.com. You can request a manual review of the accuracy of an automated
decision if you are unhappy with it.

How we process personal data
When you visit our online channels or when you use third-party sites or platforms, we use
technology such as cookies, flash cookies, pixels and web beacons to process your personal
data.

Please visit our Cookie Policy for more information, including information about how to delete
cookies places on your device and how to prevent them from being put there in the first place!
Be mindful that if you do enable a prevent cookies functionality on your device, some of our
services and functionalities on the site will no longer work.

We also collect information from other trusted sources, so we can update or add to the personal
information we’ve collected ourselves.

Sharing information with trusted subsidiaries (other LAUGHINGBIRDS.COM companies)
Our subsidiaries (the other companies in the Results Group) may sometimes need to access
your information to provide services to you on our behalf. Because the Results Group is
passionate about your privacy, we have made a decision to implement the same privacy
protection all over the world, so you can feel safe no matter which Results Group company is
using your data. Legally, other Results Group companies will then be acting as ‘data
processors’ and will be subject to data processing laws. They need your personal data so they
can:

• Deliver products and services you’ve requested
• Get in touch with you about your account or transactions
• Send you information about our sites, applications and policies
• Send you any newsletters you’ve signed up for (you can unsubscribe at any time)
• Process information that the subsidiary is formally contracted to process on our behalf, e.g. carry out a purchase placed by you, manage your LAUGHINGBIRDS.COM ID account activity or your VIP account data.
• Identify, review and stop any activities that could breach our policies or break the law
• Sharing information on public forums and chat

As our public forums and chat services can be read by everyone, any personal information you
share on them can be seen publicly. If you’d like us to remove any of your personal information
from public areas of the site, please email our Customer Service. If we can’t remove your
personal information for any reason, we’ll let you know why. If you’re under 16 years old, you’ll
need the permission of a parent or guardian to use our public forums or chat features.

Sharing your LAUGHINGBIRDS.COM ID
You can use your LAUGHINGBIRDS.COM ID on our trusted partners’ third-party websites, so
you can play virtual games without creating a separate account. If you choose to use your
LAUGHINGBIRDS.COM ID, we’ll have access to some information that you provide to the thirdparty websites. We’ll collect, store, use and process that information according to this Privacy

Policy. Third-party sites will also be able to access some information from your
LAUGHINGBIRDS.COM ID profile, so you can to take part in experiences on their site. Please
read their privacy policy if you’d like to know more about how they use your information.
Sharing information on Social Media (Features) and Widgets
Some of our websites may include social media links such as the Facebook ‘like’ button,
widgets like ‘Share this button’ and interactive mini-programs. If you click on any of these links,
the features may collect your IP Address and record which page you were visiting at the time.
The features may also use cookies so that the feature can function properly. Social media
features and widgets are hosted by third parties or may be hosted directly on our website. When
you’re using these features and widgets, your personal data will be processed by that third-party
according to their own privacy policies.

Sharing information with other companies
Please see our category list of trusted third parties that we may share your information
with here.

We won’t share your personal information outside the Results Group except:

• When we need to enforce the terms of use or the policies that we ask customers to agree to;
• When we need to protect the safety, security, rights and property of our customers or thirdparty partners;
• When we need to meet legal processes or if disclosure of the data is required by law;
• When we’re asking other companies like e.g. couriers, shipping and warehouse service provides, payment providers, IT platform providers, fraud detection and prevention providers, survey providers, product catalogue providers and customer service suppliers to deliver services on our behalf; We have contracts with the companies to make sure they only use your personal information for agreed services and meet legal requirements;
• When we store your information using secure cloud storage services/facilities. We have contracts with companies to make sure they only use your personal information for the agreed services and meet legal requirements;
• If a merger, acquisition or sale of assets ever meant we needed to share information with a third party – in this case we’d email you and post a notice on our website to publish the change of owner and we’d also tell you how your data would be used and give you options regarding your personal data;
• When you’ve given us permission to share your information with third parties so they can send you information on their products and promotions (you can opt out of these emails by contacting our LAUGHINGBIRDS.COM Customer Service team although in some cases you may also need to contact the third-party directly);
• When you have given us permission to share your information with third parties, so they can provide you with marketing information and promotions regarding our products (as an example personalized advertising provided via a social media platform). You can opt out of such marketing activities by adjusting your cookie settings on your device. In some cases, you may also need to contact the third party directly (in case of social media adjust your privacy settings and request deletion of collected information by the third-party site)
• When you’ve asked us to share your personal information with third-party sites or platforms like social networking sites – once it’s been shared, your personal data will be processed by that third-party according to their own privacy processes

How long do we keep your personal information
We’ll keep your personal information as long as your account is active or as long as it’s needed
to provide a service. We have so called retention polices for each of the categories of personal
information that we process.

If you’d like to cancel your account or for us to delete your data, we’ll only keep information that
we need for legal reasons, to resolve disputes or to enforce our agreements.

Our Cookie Policy
Cookies are small data files that your browser places on your computer or device. A cookie itself
does not contain or collect information. However, when it is read by a server via a web browser
it can help a website deliver a more user-friendly service – for example, remembering previous
purchases or account details.

Like most websites, our online channels and our applications (apps) collect some information
(e.g. information on IP addresses, browsers, internet service providers, referring pages, exit
pages, operating systems, date stamps, time stamps and clickstream data). This information
won’t be linked to any other information we collect about you unless you have given your
consent that we may do this.

Both we and our third-party tracking utility partners use browser storage, app storage, cookies,
pixls, beacons, scripts and tags to analyze trends, administer the site, track user movement
through the site and collect demographic information about our overall user base. We may
receive reports on these from our third-party tracking utility partners on an individual and
aggregate basis. For more information about cookies, please read our full Cookie Policy.
Keeping children safe online

We care deeply about making sure children are safe online and have extra privacy processes in
place to make sure we’re keeping our younger fans safe when they’re using our online
channels. In fact, some features have age gates so to prevent children from inadvertently using
such features. We also take all reasonable care to secure that we don’t knowingly collect, store,
use or process personal information from children who may use those features without proper
parental consent.

We’ve joined a digital child safety program which audits our company on a yearly basis to make
sure we follow the rules in the way interact with children online.

We also follow all relevant laws for children aged between 13 and 18 and when it comes to
personal data, we consider anyone under the age of 16 years a child 

If you have any questions or concerns about our Privacy Policy, please contact our Data
Protection Officer at info@LaughingBirds.com.

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of
charge) at https://feedback-form.truste.com/watchdog/request. To view a list of properties
covered by our Dispute Resolution provider, please click the seal located at the top of this
section.

When we do process personal information from children, we take extra steps to protect their
privacy including:

• Making sure we tell parents what personal information we collect, store, use and process from their child and explaining whether we share the information
• Meeting legal requirements by asking for parental consent to collect, use and process a child’s data and asking for consent to send their children information about our products and services
• Limiting how we collect, store, use and process personal information from children so only data that is reasonably needed for them to take part in an online activity is collected
• Giving parents access or the option to ask for access to personal information we’ve collected from their child – parents can also ask for their children’s personal information to be changed or deleted

Collecting and using children’s information
While some of our websites, channels and apps are designed with families and users of all ages
in mind, others are intended to be used mainly by children. Whenever we collect personal
information from a child, we only keep the information for the time we need it to provide a
service or for the time it’s legally required to be kept on record.

While children can choose whether to share their information with us, there are features of our
websites that won’t function if they haven’t given us their information. Where personal
information is needed for features to function, we’ll only ask for information that is reasonably
required to take part in the activity.

Here are some examples of times when we collect children’s data:

• When children register online Children can register on our websites to access a variety of services including content, games and competitions. During registration, we may ask a child to provide their parent’s or guardian’s email address, the child’s first name, gender, their birth date, their username and password. We use this information for security and notification reasons. We strongly encourage children to create a username that excludes any personal information.

• When children share content they’ve created themselves Some of our websites allow children to create or use content themselves. Since only some of these features require personal information from the child, not all activities require consent from a parent or guardian. Whenever an activity could potentially allow a child to share personal information, we either review the content ourselves and make sure personal information is removed or ask for permission from a parent or guardian to collect the data. Types of personal data that children have shared with us in the past include stories, free-text fields, drawings that allow text or free-hand entry of information, photographs of your child, sound clips, movie files or any type of content or other persistent identifiers that clearly identifies the child in some way. If, as well as collecting content that includes personal information, we also plan to share the content publicly or with a third party for their own use, we’ll ask the parent or guardian for ‘verifiable parental consent’ (which is a higher level of parental consent).

• When children enter contests and sweepstakes If a child wants to enter a competition, we ask for the personal information we need for a child to take part. We usually only ask for the child’s first name (so we can tell the difference between children from the same family) and the email address of a parent or guardian (so we meet legal requirements to notify the responsible adult). We’ll only contact the parent if the child wins the contest or sweepstake to find out where to send the prize. If the competition asks the child to create content to enter, we may need to ask for parental consent by email in advance to ensure we meet the privacy requirements for content children have created themselves (please see the information above about children creating content). Without consent, children won’t be able to take part in our competitions.

• When children receive emails from us We may need ask for their child’s contact details (including their email address) so that we can reply to a question they’ve asked us. To meet legislative requirements around the world, we’ll delete any information we have on the child as soon as the reply’s been sent. If we need to get in touch with the child a second time, for example to reply to additional questions, we would request an email address from their parent or guardian. We’d then only keep the child’s online contact information for the time it takes us to honor their request and wouldn’t use the information for any other purpose. If we ever need a child’s online contact information for ongoing communication, we’d ask for the parent’s or guardian’s email address at the earliest opportunity so that we can keep the adult informed of the data we’re collecting and to give the parent an option to ask us to stop collecting data. Parents or guardians can opt out of any communication we have with their child at any time by following the unsubscribe instructions within each communication (if there is more than one type of communication, the adult may need to opt out of each individually). Alternatively, they can contact our LAUGHINGBIRDS.COM Customer Service team.

• When children receive app push notifications Many apps send users ‘push notifications’ to their customers’ mobile phones or devices to tell them about updates (sometimes even when the app is not in use). Some of our apps are designed to be used by children. We ask children to provide the email address of their parent or guardian, so we can tell the adult about their child’s request before we send children push notifications from our apps. We don’t link the device identifier with any other personal information without parental consent. If you would like your child to stop receiving push notifications from one of apps, you can change the settings on the device your child’s using at any time.

• When we collect location information Some of our websites, channels and apps are designed for children. We request consent from a parent or guardian by email before collecting information on a child’s street name, address or coordinates. We do that because such information will effectively make us able to identify a specific child. As an opposite, we don’t require parental consent to collect information on a child’s city, country or region as long as it isn’t linked directly to the specific child. The reason for this, is that such generic information will not make us able to identify a specific child. If you would like to stop us collecting this type of location information, you can adjust the settings on the device your child is using at any time. Alternatively, please contact our LAUGHINGBIRDS.COM Customer Service team.

• When we collect ‘persistent identifiers’ So we can give visitors to our online channels more relevant and personalized online experiences, we automatically collect some types on information (e.g. information on IP addresses, mobile device identifier, browsers, internet service providers, referring pages, exit pages, visitor frequency, operating systems, date stamps, time stamps and clickstream data). We collect this information using technologies such as cookies, pixels, flash cookies, web beacons and other unique identifiers (which we define under the Cookie Policy section of this Privacy Policy). We may collect this information ourselves or ask a third party to process the data on our behalf. We use this data to give children access to online features and activities, to customize content, to improve our online channels, to analyze the performance of our online channel and to create anonymous reports. If we ever want to collect children’s data for any other reason, we would contact the child’s parent or guardian for consent in advance. A list of third-party operators who collect ‘persistent identifiers’ on our sites and apps can be found in our Cookie Policy. 

What if we accidentally collect children’s data?

If we discover that we’ve unintentionally collected information from a child in a way that doesn’t
meet COPPA requirements, we will delete the information immediately.

Requesting parental consent
Asking for low-level consent by email
If we need to collect a child’s personal information, we’ll ask for parental consent according to
COPPA legal requirements. We’ll send the child’s parent or guardian an email explaining what
information we’re collecting, how we plan to use it and ask the parent to give or deny their
consent. If we don’t receive parental consent in a reasonable time, we’ll delete all information
we’ve collected from the child including the adult’s contact information that we asked for in order
to request consent.

Asking for high-level ‘verifiable consent
If we want to share a child’s personal information publicly or with a third party, we’ll seek a
higher level of parental consent than the email request described above. We may ask for
verification by credit card or other payment method (with a nominal charge involved), verification
over the phone or through a video chat to a trained customer service representative or a signed
consent form to be returned to us by mail, email attachment or fax. We may give the parent a
guardian a PIN or password that they’ll be able to use in future communications to confirm the
adult’s identity.

What if a parent or guardian hasn’t been contacted for consent?
If a child under the age of 16 accesses an online channel that’s designed for children by using
an age gate, we’ll email the child’s parent or guardian before collecting any personal information
from the child. If you think that your child is taking part in an online activity that collects their
personal information and you or another parent/guardian hasn’t received an email letting you
know or seeking your consent, please contact our Data Privacy Officer
at info@LaughingBirds.com. We won’t use email addresses provided for parental consent for
any other purpose unless the adult has expressly opted in to marketing emails or taken part in
an activity which allows email contact.

Parental choices and controls
At any time, parents or guardians can refuse to allow us to use and collect further personal
information from their child. Parents or guardians can ask us to delete the personal information
we have collected in connection with their child’s account from our records. As personal
information is required for some services, deleting a child’s records may result in an account,
membership, or service being unavailable to the child in future.
If a child has a registered LAUGHINGBIRDS.COM ID, parents or guardians can access, change
or delete the personal information we’ve collected from their child by:

• Using their child’s username and password to log into their child’s LAUGHINGBIRDS.COM ID account
• Getting in touch with our LAUGHINGBIRDS.COM Customer Service team

If you’d prefer to contact us, please let us know your child’s username along with the your own
telephone number and email address. We’ll need to confirm your identity as the parent or
guardian of the child before granting access to the child’s personal information. We will respond
to your request within a reasonable timeframe.

If we make material changes to how we use Personal Information collected from a child under
the age of 16, we’ll tell their parent or guardian by email and ask for ‘verifiable parental consent’
for the new uses of the child’s personal information.

Sharing information we have consent to share with others
If we’ve received high-level parental consent to share a child’s personal information publicly, we
may also share personal information with our service provides or legal authorities. We may
share information with our service providers including software solution companies, online
security partners and customer services. Our contracts with these companies make sure they
only use personal data for the agreed purpose.

We may share personal information to meet legal processes or if disclosure is required by law.
As allowed by relevant laws, we may also share personal information collected from children to:

• Comply with a request from to a law enforcement or public agency (including schools or children services) or to avoid liability
• Make a disclosure that we believe may stop a crime being committed
• Help an investigation related to public safety
• Protect the safety of a child who’s using our online channels
• Protect the technology of our service providers or security of our online channels themselves

Parents have the right to consent to the collection, use and processing of their child’s personal
information without also having to consent to the disclosure of that information to third parties.
We don’t share information with third parties other than as described above.

Our employees
Whether you’re an existing employee or applying for a job with us, we’ll process specific
information relevant for your employment and application. The principles in this Privacy Policy
will also apply to your employment and application.

LAUGHINGBIRDS.COM Partners
We define LAUGHINGBIRDS.COM Partners as other companies doing business with the
Results Group. We process information on our LAUGHINGBIRDS.COM Partner companies for
collaboration and evaluation purposes.

Data security and integrity
The security, integrity and confidentiality of customer information is extremely important to us.
We use technical, administrative and physical security measures to protect personal information
from unauthorized access, disclosure, use and modification. All external transfers that contain
personal information are done using encrypted technology. Credit card information is handled
by approved service providers that meet PCI (Payment Card Industry) standards and have
appropriate safeguards in place.

Although we regularly review our security procedures and evaluate new technology and
methods to make our online channels safer, no security measures are perfect or impenetrable.
Our customers, employees and partners also play an important role in protecting information.
We encourage customers to choose passwords that are difficult for others to guess and to keep
their personal passwords secret.

Should you notice any flaws or concerns in our security, please contact our
LAUGHINGBIRDS.COM Customer Service team as soon as possible.
If we ever experience a data breach in which customer information is at risk of being misused,
we’ll contact customers according to legal requirements. If necessary, we’ll also contact data
protection authorities.

Data transfers, storage and processing globally
As we’re a global company, we may transfer your personal information to individual subsidiaries
of the Results Group or third parties in locations around the world for the purposes described in
this Privacy Policy. Whenever your personal information is transferred, stored or processed by
us or by companies carrying out such services on our behalf, we’ll take reasonable steps to
safeguard the privacy of your personal information. Additionally, when using or disclosing
personal information we abide by our Binding Corporate Rules, when these become effective.
The Binding Corporate Rules provide the highest security to you when it comes to how your
information is processed.

Binding Corporate Rules and local legal requirements
We want to make sure we as a minimum use the standards of data privacy and security that
follows from the European General Data Protection Regulation (“GDPR”) anywhere in the world
where we collect, store, use or share your personal data. Where your local rules require more
from us than that, we will adjust our practice to make sure your data is safe with us no matter
where in the world you are! To bind us to that promise we have implemented something called
with Binding Corporate Rules with effect from June/2016 ‘Binding Corporate Rules. These rules
are set by European data authorities across the European Union (EU) and set the some of the
highest standards in the world on data collection, storage, use and sharing.

IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Last Updated: December 16, 2019

This section provides information for California residents, as required under California privacy
laws, including the California Consumer Privacy Act (“CCPA”). California privacy laws require
that we provide California residents information about how we use their personal information,
whether collected online or offline, and this section is intended to satisfy that requirement.
Under the CCPA, “personal information” is any information that identifies, relates to, describes,
is reasonably capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular California resident or household.

Categories of Personal Information that We Collect, Disclose, and Sell
Below please find the categories of personal information about California residents that we
collect, sell, and/or disclose to third parties or service providers for a business purpose. A
“Business Purpose” may include, for example, sharing your personal address with the US Post
Office for shipping. Other than letters to Santa Claus, they tell us it is difficult to ship anything
without including personal information.

NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, postal
address, unique personal identifier, online identifier, Internet Protocol (IP) address and email
address.
• Do we collect? YES
• Do we disclose for business purposes? YES
• Do we sell? NO

CUSTOMER RECORDS: Paper and electronic customer records containing personal
information, such as name, address, telephone number, credit card number and debit card
number.

• Do we collect? YES
• Do we disclose for business purposes? YES
• Do we sell? NO

PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California
or federal law such as sex and age. Any “sale” (as defined under the CCPA) of information
under this category is for the purpose of enabling users to register accounts and preventing
children from using certain websites, apps and services without first receiving parental consent.

• Do we collect? YES
• Do we disclose for business purpose? NO
• Do we sell? NO

PURCHASE HISTORY AND TENDENCIES: Commercial information, including products or
services purchased, obtained, or considered.

• Do we collect? YES
• Do we disclose for business purposes? NO
• Do we sell? NO

BIOMETRIC INFORMATION: Physiological, biological or behavioral characteristics that can be
used alone or in combination with each other to establish individual identity, including DNA,
imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings,
keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that
contain identifying information.

• Do we collect? NO
• Do we disclose for business purposes? NO
• Do we sell? NO

USAGE DATA: Internet or other electronic network activity information, including, but not limited
to, browsing history, search history, and information regarding a resident’s interaction with an
internet website, application, or advertisement.

• Do we collect? YES
• Do we disclose for business purposes? YES
• Do we sell? NO

GEOLOCATION DATA: Precise geographic location information about an individual or device.

• Do we collect? NO
• Do we disclose for business purposes? NO
• Do we sell? NO

AUDIO/VISUAL: Audio, electronic, visual information, such as photos and videos. Some of our
websites allow users to create and upload content themselves. Whenever an activity could
potentially allow a user to share Audio/Visual information, we either review the content
ourselves and make sure personal information is removed or, if a child shared the content, we
ask for permission from a parent or guardian to collect the data. Any “sale” (as defined under
the CCPA) of this information is for the purpose of monitoring these activities and preventing
this category of information from being made public.

• Do we collect? YES
• Do we disclose for business purposes? YES
• Do we sell? NO

EMPLOYMENT HISTORY: Professional or employment-related information.

• Do we collect? NO
• Do we disclose for business purposes? NO
• Do we sell? NO

EDUCATION INFORMATION: Information that is not publicly available personally identifiable
information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C.
section 1232g, 34 C.F.R. Part 99).

• Do we collect? NO
• Do we disclose for business purposes? NO
• Do we sell? NO

PROFILES AND INFERENCES: Inferences drawn from any of the information identified above
to create a profile about a resident reflecting the resident’s preferences, characteristics or
behavior.

• Do we collect? YES
• Do we disclose for business purposes? YES
• Do we sell? NO

California Residents’ Rights
California law grants California residents certain rights and imposes restrictions on particular
business practices as set forth below.

Right to Opt-out. California residents have the right to opt-out of our sale of their personal
information. Opt-out rights can be exercised by visiting our Cookie Policy or by going directly to
our Cookie Settings page and deleting or preventing cookies from being used. You can also
click on the “Do Not Sell My Data” link at the bottom of every webpage.

Right to Opt-In. We do not sell personal information about residents who we know are younger
than 16 years old without verifiable parental consent.

Notice at Collection: We are required to notify California residents, at or before the point of
collection of their personal information, the categories of personal information collected and the
purposes for which such information is used.

Verifiable Requests to Delete, Requests to Know. Subject to certain exceptions, California
residents have the right to make the following requests, at no charge, up to twice every 12
months:

Right of Deletion: California residents have the right to request deletion of their personal
information that we have collected about them, subject to certain exemptions, and to have such
personal information deleted, except where necessary that we maintain such personal
information in order to:

• Complete the transaction for which the personal information was collected, provide a good or
service requested by the California resident, or reasonably anticipated within the context of a
business’s ongoing business relationship with the California resident, or otherwise perform a
contract between the business and the California resident.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or
prosecute those responsible for that activity.

• Debug to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another California resident to exercise his or her right
of free speech, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6
(commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when the businesses’
deletion of the information is likely to render impossible or seriously impair the achievement of
such research, if the California resident has provided informed consent.

• Enable solely internal uses that are reasonably aligned with the expectations of the California
resident based on the consumer’s relationship with the business.

• Comply with a legal obligation.

• Otherwise use the California resident’s personal information, internally, in a lawful manner that
is compatible with the context in which the California resident provided the information.
Right to Know – Right to a Copy: California residents have the right to request a copy of the
specific pieces of personal information that we have collected about them in the prior 12 months
and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable
and, to the extent technically feasible, readily useable format that allows the individual to
transmit this information to another entity without hindrance.

Right to Know – Information: California residents have the right to request that we provide them
certain information about how we have handled their personal information in the prior 12
months, including the:

• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information;
• categories of third parties/with whom we have disclosed or shared their personal information;
• categories of personal information that we have disclosed or shared with a third party for a
business purpose;
• categories of personal information collected; and
• categories of third parties to whom the residents’ personal information has been sold and the
specific categories of personal information sold to each category of third party.

Submitting Requests. Requests to exercise the right of deletion, right to a copy, and / or the
right to know may be submitted by contacting us at 1-800-835-4386 (toll free) or by emailing us
at info@LaughingBirds.com. We will respond to verifiable requests received from California
consumers as required by law.

Right to Non-Discrimination and Incentives. The CCPA prohibits discrimination against
California residents for exercising their rights under the CCPA and imposes requirements on
any financial incentives offered to California residents related to their personal information.
Discrimination: Businesses may not discriminate against residents who exercise their rights
under CCPA. Discrimination may exist where a business denies or provides a different level or
quality of goods or services, or charges (or suggests that it will charge) different prices or rates
or impose penalties on residents who exercise their CCPA rights, unless doing so is reasonably
related to the value provided to the business by the residents’ data.

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or
deletion of California residents’ personal information, residents have the right to be notified of
any financial incentives offers and their material terms, the right not be included in such offers
without prior informed opt-in consent, and the right to be able to opt-out of such offers at any
time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives.

California Privacy Rights under California’s Shine-the-Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who
provide us certain personal information are entitled to request and obtain from us, free of
charge, information about the personal information (if any) we have shared with third parties for
their own direct marketing use. Such requests may be made once per calendar year for
information about any relevant third party sharing in the prior calendar year. California residents
who would like to make such a request may submit a request in writing
to info@LaughingBirds.com. The request should attest to the fact that the requester is a
California resident, and provide a current California address.

Notice to Australian Residents:
In regard to how we process your information to be compliant with local legislation the following
will apply in supplement to the Privacy Policy:

We generally collect personal information directly from you where this is reasonable and
practical but may also acquire information from other trusted sources to update or supplement
the personal information you provided or which we processed automatically.

• We may also use your personal information to tell you about the products and services of the
Results Group or third parties. From time to time, we and our Results Group entities and
business partners may contact you by mail, telephone, email or other electronic messaging
services (such as text, voice, sound or image messages including using automated calling
systems) with information about products and services (including discounts and special offers).
If you no longer wish to receive marketing or promotional information from us and our Results
Group entities or our partners, you can unsubscribe at any time. There are certain messages
relating to the goods and services we provide to you that cannot be unsubscribed from.

• Should the Results Group experience a data breach and your information be involved, we will
contact you if there is a risk of serious harm to you and if we are legally obliged to do so. In
some instances, the Results Group will also be legally obliged to contact (data protection)
authorities when a breach of privacy information occurs.

• We will take such steps that are reasonable in the circumstances (if any) to destroy or deidentify personal information when it is no longer required.
Changes to this Privacy Policy

We may change this Privacy Policy to accommodate new technologies, industry practices,
regulatory requirements or for other purposes. We will provide prior notice to users by email and
post the information on our online channels if these changes are material and request your
consent if legally required.

Third party vendor categories
The Results Group works with several trusted partners to secure that we provide you, our
business partners and our employees with the best experience possible. This means that we
will at times need to allow third parties to process personal data.

To give you an overview we have categorized the type of vendors we use and what we use
them for on a category basis.
However, if you wish to know what cookies we are placing on your devices – please look at our
detailed third- party cookie list.

We process personal data with vendors in the following categories:

• IT Service providers
We use a series of trusted partners worldwide to provide us with IT services and system
administration services – in regards to both our customer and partner facing activities as well as
our internal IT and administration systems.

• Global payment provider and processing partners
To secure a safe and efficient payment process both online, in our stores or through invoicing or
money transfers.

• Cloud storage partners
We store our and your data at secure data centers around the world.

• Fraud Prevention and detection partners and agencies
Working with the Results Group worldwide to secure that the Results Group is not defrauded.

• Warehousing, packing, shipping, postage and delivery partners
Helping us get our products into the hands of our customers and business partners around the
world.

• Catalogue printing and mailing and postal partners
Helping us making sure catalogues and magazines come your way.

• Marketing partners
To be able to provide targeted and personalize advertisements, promotions and campaigns both
when you are interacting with LAUGHINGBIRDS.COM on our online platforms, on social media,
instore or otherwise.

• Social Media Partners
To be present and allow you to interact with the Results Group on the platforms where you are.

• Survey, questionnaires and product review suppliers
Helping us secure that we get your all-important feedback of your LAUGHINGBIRDS.COM®
experience!

• Tax and customs authorities, regulators and other authorities globally
Who require reporting of processing activities in certain circumstances.

• Professional advisers
Including lawyers, bankers, auditors and insurers globally, who provide consultancy, banking,
legal, insurance and accounting services to the Results Group.