EXHIBIT “A”

PRIVACY POLICY

Privacy Policy

This Privacy Policy explains how Nesting Owl, LLC (“Nesting Owl”, we”, “our”, or “us”), handles Personal Information in connection with its products, services, apps, and websites both online and offline (collectively, the “Services”). This Privacy Policy applies to all Personal Information received and processed by Nesting Owl. “Personal Information” means any information or set of information that relates to an individual, which can be either direct or indirect, and can be collected by or on behalf of Nesting Owl.

Please read this Privacy Policy before using our Services or submitting Personal Information to us. By accessing and using the “Services”, you agree and consent to the collection, use and disclosure of your Personal Information as outlined in this Privacy Policy.

Our Privacy Policy explains:

·         Information Collected

·         How Information is Used

·         Information We Share

·         Links to Other Sites

·         How Collected Information is Kept Secure

·         Children’s Online Privacy Protection Act Disclosure

·         Changes to this Privacy Policy

·         Contact Information

Personal Information Collected

Personal Information You Give to Us. The information we collect on or through our Services may include:

·         Personal Information that you provide by filling in forms on our website or through your purchase, use or access of our Services. This includes information provided when you request a consultation or information material from us; or when we process and respond to your inquiries related to our Services.

·         Records and copies of your correspondence with us (including email addresses).

·         The video or streaming content you send, upload or provide us with access to as a part of providing our Services to you.

Personal Information We Collect About You.

·         Contact information and contact preferences (such as name, email address, mailing address, phone number, and emergency contact information).

·         Biographical and demographic information (such as date of birth, age, gender, ethnicity, and marital status).

·         Information regarding any children, parents or legal guardians.

·         Financial information to complete a transaction.

·         Username and password that you may select in connection with establishing an account on our websites or mobile apps.

·         Your photograph, social media handle, digital or electronic signature.

·         Publicly available information.

·         As you navigate through and interact with our websites, we may use automatic data collection technologies to collect certain information about your browsing actions on our websites including:

                                i.Details of your visits to our websites, including resources that you access and use on our websites, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.

                              ii.Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.

                            iii.Information on your interaction with our Services and advertisements.

·         Inferences drawn from other Personal Information listed above, to create a profile reflecting your preferences, characteristics, behavior, attitudes and abilities

How Personal Information is Used

We may use your Personal Information for our legitimate interests, including:

·         To manage our websites, including your registration and account

·         To provide the Services you purchase, respond to your questions, and carry out the transactions you have requested

·         For our internal purposes (such as auditing, data analysis, and research to improve and develop our products, services, content, advertising, and communications)

·         To monitor and protect against suspicious, fraudulent or illegal activities, and to identify violations of our Services’ policies

·         To enhance and personalize our Services and our marketing efforts

·         To establish and maintain communications with you

·         Where you have requested participation in a Service trial with Nesting Owl

·         To making proposals for future Services needs

·         To allow our affiliated companies to notify you of certain products or services offered by our affiliated companies

·         To process transactions through service providers

·         To meet legal, security, processing, and regulatory requirements

·         To compiling statistics for analysis of our websites and our business

We use Personal Information about you where you have given us consent to do so for a specific purpose not listed above. For example, we display personal testimonials of satisfied Clients on our Services. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at nestingowlsleep@gmail.com.

Why We Process Personal Information 

We process Personal Information where it has a legal basis for doing so. Legal bases include:

·         The transfer or processing is in Nesting Owl’s legitimate interest in providing you with access to our Services and programs.

·         The transfer or processing is necessary for the performance of a contract between you and Nesting Owl (or one of its affiliates).

·         The transfer or processing is necessary for the performance of a contract between Nesting Owl and a third party.

·         The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests.

·         The transfer or processing is required by applicable law.

Personal Information We Share

We may share and use your Personal Information in the following ways:

·         During a group coaching session involving you, any other Nesting Owl’s clients and our coaches.

·         With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.

·         To comply with the law, a judicial proceeding, court order, a subpoena or other legal process, such as requests from public and governmental authorities or law enforcement, or to exercise our legal rights or defend against legal claims.

·         Where we believe it is necessary to (a) protect and defend the rights, property or safety of Nesting Owl, our employees, other users of the Services, or the public; (b) enforce the terms and conditions that apply to use of the Services; or (c) respond to claims that any content violates the rights of third parties.

·         Where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, brand protection, situations involving potential threats to the safety of any person, violations of this Privacy Policy, or as otherwise required by law.

·         In connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website(s) of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

·         With third party service providers and individuals that help us provide our Services or perform services on our behalf (e.g., advertising serving technologies, e-mail service providers, delivery services, database management, web analytics, payment processing and other services). These third parties have access to your information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your Personal Information for any purpose other than to provide this assistance, except to the extent required by law.

We may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

**Please note, Nesting Owl DOES NOT sell Personal Information to third parties.

Links to Other Sites

Our websites may include links to other web sites whose privacy practices may differ from those of Nesting Owl. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

How Collected Information is Kept Secure

The security of your Personal Information and our clients’ information is important to us. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We urge you to exercise caution when transmitting Personal Information over the Internet. We cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information; therefore, when submitting Personal Information to Nesting Owl online, you must weigh both the benefits and the risks.

Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

[If you are planning on using any particular analytics services like google or Facebook, you can list them here and include links to their policies and procedures.]

Privacy Supplemental Notice – Children’s Online Privacy Protection Act Disclosure

This Privacy Supplemental Notice supplements the information contained in this Privacy Policy and applies solely to all information collected, used, or disclosed subject to Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”).

Due to the nature of the Services we provide, when you purchase, participate in, access or use our Services, we may acquire Personal Information about your child(ren) or child(ren) for whom you are the primary caregiver (“Children”), such as their first and last name, birthdate, physical or home address, video or audio file, and geolocation information (“Child Related Personal Information”). The Child-Related Personal Information we collect in connection with our Services may pertain to Children under the age of 13.

We may use and share such Child Related Personal Information: (1) to provide our Services to you and/or the  Child(ren); (2) to comply with the law; (3) in accordance with your consent or instructions; and/or (4) as necessary for internal business interests.

We work with a number of third-party service providers to help us run our websites and provide our Services. We may share the Child-Related Personal Information with our service providers solely as necessary for them to perform a business, professional, or technology support function for us.

By entering into a transaction for any Services with us, you expressly grant us permission to collect, access, use and disclose any of the Child-Related Personal Information we receive in connection with the Services.

We may retain the Child-Related Personal Information collected online for a reasonable amount of time to perform the task for which we collect it, unless otherwise requested by you. We reserve the right to keep certain Child-Related Information necessary for record keeping to the extent permitted and/or required by law.

We agree to delete all Child Related Personal Information securely.

You have the right to:

·         Review Child Related Personal Information collected.

·         Request deletion of Child Related Personal Information.

·         Restrict disclosure of Child Related Personal Information to third parties unrelated to the Services we provide.

·         Refuse further collection or use of Child Related Personal Information.

To make these requests or to withdraw your consent at any time, please contact us at: nestingowlsleep@gmail.com.

Changes to this Privacy Policy

If we change our privacy practices, an updated version of this Privacy Policy will reflect those changes. We will provide notice of such changes by updating the effective date listed on this Privacy Policy. It is your responsibility to check this Privacy Policy frequently to view any amendments. Your continued interaction with Nesting Owl, in the activities covered above, will be subject to the then-current Privacy Policy. 

Contact Us

If you have any questions regarding our Privacy Policy, please contact us at nestingowlsleep@gmail.com.

This Privacy Policy is dated November 2021.