Effective date: June 15, 2022

Aflac is working with Sproutel, Inc. to provide request and distribution services for My Special Aflac Duck® to families and organizations.

This Privacy Policy does not apply to My Special Aflac Duck. Please see the My Special Aflac Duck Privacy Policy for more information.

If you are providing information related to a testimonial for My Special Aflac Duck, this Privacy Policy does not apply. Testimonials are covered by a separate consent and appearance release.

At Sproutel, we care about how your personal information is used and shared, and protecting your privacy. By visiting or using the various websites owned and operated by Sproutel under the myduck.sproutel.com domain, including, without limitation, the https://myduck.sproutel.com website (each, a “Website”, and collectively, the “Websites”), and requesting any My Special Aflac Ducks (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to our collection, use, and sharing of your information in the following ways.

I. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States (such statutes, the “PII Laws”), (2) information protected by the California Consumer Privacy Act (the “CCPA”) and the California Online Privacy Protection Act (“CalOPPA”), and (3) personal information and private information, as defined by the New York Stop Hacks and Improve Electronic Data Security Act (the “SHIELD Act,” and collectively with the PII Laws, CCPA, CalOPPA, and the SHIELD Act, the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you are accessing, viewing or using any of our Websites and/or Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

II. What Type of Information Does Sproutel Collect?

Sproutel does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect the following types of information:

A. Information You Provide to Us:

Information necessary to provide the Services. We collect Personal Information from you when you submit a request for My Special Aflac Duck. For example, when you request My Special Aflac Duck we may collect your name, phone number, e-mail address, address, and additional information. If you are a family, we may also collect information about your child, including your child’s name and age. You can choose not to provide us with certain information, although that may affect the functionality of the Services.

B. Information Collected Automatically:

Whenever you interact with any of our Websites, we automatically receive and record information on our server logs from your browser including data related to how you interact with the Websites and the page you requested. You may be able to change the preferences on your browser or mobile device to send “do not track” signals or to prevent or limit your computer or device’s acceptance of cookies. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

III. What Does Sproutel Do with Personal Information?

Sproutel collects Personal Information to fulfill requests for My Special Aflac Duck. We may use information (including: names, email addresses, addresses, organization affiliation, job title, child name, child age, child diagnosis) to verify requests are aligned with the mission of the Aflac Foundation to support families of children with cancer or blood disorders including sickle cell.

IV. Will Sproutel Share Any Information It Collects?

We share information necessary to fulfill requests for My Special Aflac Duck. This includes sharing your name and address with our logistics partner. We do not, and will never, sell your Personal Information or use your Personal Information for purposes not related to the My Special Aflac Duck program.

We will share your Personal Information with third parties as described below:

A. Organizations:

We share the information you provide to us with Aflac, for purposes of internal reporting and improving and further developing the My Special Aflac Duck program.

B. Families:

We only share the information necessary to fulfill your request for My Special Aflac Duck. We do not share your Personal Information with Aflac. We share general, anonymized information with Aflac to support Aflac’s internal reporting about the program (including: child age, geographic region).

C. Business Transfers:

We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

D. Protection of Sproutel and Others:

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Sproutel, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

E. With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

V. What Are Users’ Rights to Control Their Personal Information?

Except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Sproutel’s collection and use of your Personal Information.

A. Requests to Sproutel:

You may request (1) the correction, updating, deletion, or restriction of collection and use of your Personal Information, (2) the categories of Personal Information Sproutel has collected, (3) the categories of sources from which Sproutel has collected your Personal Information, (4) the business purpose(s) for collecting and disclosing your Personal Information, (5) an account of how Sproutel has used or is using your Personal Information, (6) a copy of your Personal Information retained by Sproutel, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible, (7) the categories of third parties with whom Sproutel shares your Personal Information, (8) the categories of Personal Information which we share with third parties, and the contact information for such affiliates and/or third parties, (9) a list of all third parties that have received your Personal Information from Sproutel, and (10) the specific pieces of Personal Information Sproutel has collected about you.

We will respond to all such requests within 30 days, subject to lawful extension of that period, and there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; and requesting further information, although we will avoid doing so to the extent possible. To the extent permitted by the Privacy Laws, Sproutel retains the right to deny any request if we cannot verify that it originated from you. If you request that your Personal Information be deleted or that we restrict our disclosure of your Personal Information such that we cannot provide that information to third parties we rely on to provide your request for My Special Aflac Duck, we reserve the right to end and/or limit your access to the Services. If we do not have your Personal Information, have not collected your Personal Information, or have not disclosed or transferred your Personal Information to another party, we will inform you in response to a request regarding your Personal Information. In order to make any of the requests above, please follow the following directions:

You may contact us at:

Attention: Data Protection Office
Sproutel, Inc.
60 Valley St Ste 29
Providence, Rhode Island, 02909 USA
privacy@sproutel.com

B. Withdrawal of Consent:

You may withdraw your consent at any time by contacting us at:

Attention: Data Protection Office
Sproutel, Inc.
60 Valley St Ste 29
Providence, Rhode Island, 02909 USA
privacy@sproutel.com

C. “Do Not Sell My Information”:

Sproutel does not sell Personal Information as the CCPA defines “sell.”

VI. Is Information About Me Secure?

We employ appropriate administrative, organizational, technical, and physical measures to protect your Personal Information, which we regularly review and update as necessary. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. The Websites may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

VII. Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register for the Services. If you are under 16, please do not attempt to register for the Services or send any information about yourself to us, including your name, telephone number, or email address. No one under age 16 may provide any Personal Information to us or through the Services.

As part of supporting My Special Aflac Duck distribution to families, we ask parents for Personal Information about their child (including: name, age, and diagnosis). In the event that we learn that we have collected Personal Information from a child under age 16 without the involvement of a parent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 16 that was not provided with a parent’s consent, please contact us at:

Attention: Data Protection Office
Sproutel, Inc.
60 Valley St Ste 29
Providence, Rhode Island, 02909 USA
privacy@sproutel.com

VIII. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

IX. Questions or Concerns; Contact Information

If you have any questions or concerns regarding our privacy policies, please contact our data protection officer by sending a detailed message to privacy@sproutel.com. Alternatively, you may contact us by postal service as follows. We will make every effort to resolve your concerns.

Attention: Data Protection Office
Sproutel, Inc.
60 Valley St Ste 29
Providence, Rhode Island, 02909 USA
privacy@sproutel.com