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Last updated August 22, 2026
We're a Canadian company and this policy follows Canadian privacy law. We collect what we need to run Giggle, nothing more. We don't sell your personal information. We use AI to personalize suggestions — not to train our own models on your name choices. Your shortlist is yours, unless you choose to share it with a partner.
This Privacy Policy explains how L12 Industries ("L12 Industries", "we", "our", or "us"), operating as Giggle, collects, uses, discloses, and protects personal information when you use the Giggle website at gigglebaby.app, the Giggle iOS and Android apps, and related application programming interfaces (together, the "Service").
We are based in Canada, and we handle personal information in accordance with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws, including Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25) and the personal information protection acts of Alberta and British Columbia. In this policy, "personal information" means information about an identifiable individual, as defined under those laws.
Giggle is operated by L12 Industries, based in Toronto, Ontario, Canada. L12 Industries is the organization accountable for the personal information under its control.
We have designated a Privacy Officer who is responsible for our compliance with this policy and with Canadian privacy law, including in Quebec, where the law requires that the person in charge of the protection of personal information be identified.
Privacy Officer, L12 Industries: privacy@gigglebaby.app
Support questions: support@gigglebaby.app
Mailing location: Toronto, Ontario, Canada
This policy applies to personal information processed in connection with the Service, including when you browse the website without an account, complete onboarding, create an account, use Discover and shortlist features, invite a partner, purchase a subscription, or contact support.
Under Canadian privacy law we collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise (for example to investigate a breach of an agreement or contravention of law, to comply with a subpoena or court order, or in an emergency threatening someone's life, health, or security).
How you give consent. You give us express consent when you create an account, answer onboarding questions, save or dismiss names, create a partner invitation, or purchase Giggle Plus. Where the purpose is obvious and the information is not sensitive — for example using your app interactions to keep the Service working and to fix errors — we may rely on implied consent.
We identify the purposes for collection at or before the time we collect the information, through this policy and through the screens where you provide it. We do not, as a condition of providing the Service, require you to consent to collection, use, or disclosure beyond what is necessary to fulfil the purposes described here.
Withdrawing consent. You can withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting privacy@gigglebaby.app. If you withdraw consent for processing that is necessary to run the Service, we may no longer be able to provide some or all of Giggle to you — for example, personalization and cross-device sync depend on the preference data described below. Withdrawal is not retroactive and does not affect processing carried out before you withdrew.
Account information. When you create an account, we collect your email address and password. Passwords are stored in hashed form by our authentication provider (Supabase Auth). We may also process authentication tokens and email confirmation or password-reset metadata needed to keep your session secure.
Onboarding and preferences. You may provide naming preferences such as gender preference, due date, parent or family names (for example mom, dad, last name, sibling names, middle name), ethnicity or vibe tags, syllable or sound preferences, style notes, popularity or era preferences, and example names you love or dislike. These answers are stored in your profile when you have an account, and may also be kept on your device while you use the Service without signing in.
Usage and discovery data. We collect how you interact with names in the Service, including names you shortlist, dismiss, or view; pair-pick and ranking comparisons; learned taste weights and related taste-profile data; personalized candidate queues; and explore-list preferences generated for you.
Technical and log data. Our hosting and infrastructure providers automatically generate standard server logs when your device connects to the Service. These can include IP address, approximate region derived from that address, device and browser type, operating system, request timestamps, pages or endpoints requested, and error information. We use this information to operate, secure, and troubleshoot the Service.
Partner sharing data. If you use Share with Partner, we process invitation tokens, link status between accounts, and — when a partner opens or validates an invite — limited information such as the inviter's email address and an approximate count of saved names. Linked partners can view each other's shortlists.
Information about other people. Some fields in the Service invite you to enter information about people other than yourself, such as a partner's name or email address, a co-parent's name, a family surname, or the names of existing children. Please provide this information only where you are entitled to do so, and only invite a partner who is expecting to hear from you. We use it solely to personalize your naming results or to deliver the invitation you asked us to send. If you are named by another user and want to know what we hold, contact privacy@gigglebaby.app.
Support communications. If you contact us (including via the in-app support flow that opens your email client), we receive the content of your message and any diagnostics you choose to include (for example app version, platform, user ID, or subscription state).
Website local data. On the website, certain tools store shortlists, likes/dislikes, filters, and related preferences in your browser's local storage. That web shortlist is not synced to a Giggle account today.
Subscription status. We receive entitlement and purchase-state information from RevenueCat and the Apple App Store or Google Play so we can unlock Giggle Plus features. We do not receive or store your full payment card number.
Analytics and diagnostics (mobile). On the mobile app we use product analytics and crash reporting that may include a user identifier, email (when you are signed in), device/app context, and event details such as onboarding steps, swipe or paywall interactions, and error traces.
Information we do not collect. We do not request precise GPS location, camera or photo library access, contacts, or push-notification tokens for the Service as configured today. We do not store payment card numbers on our servers. We do not ask for government-issued identification numbers, financial account details, or health information, and you should not send them to us.
We limit our collection, use, and disclosure of personal information to what a reasonable person would consider appropriate in the circumstances, and to the purposes identified below. If we later want to use your information for a materially different purpose, we will identify that purpose and obtain your consent where the law requires it.
We use personal information to:
• Provide, personalize, and improve Discover, shortlist, explore lists, and related features • Sync your preferences and shortlist across devices when you are signed in • Enable optional partner sharing at your direction • Process and manage Giggle Plus subscriptions and restore purchases • Send transactional messages such as account confirmation and password reset • Analyze product usage and diagnose crashes or errors • Secure the Service, prevent abuse, and enforce our Terms of Service • Respond to your support and privacy requests • Comply with applicable law
We use third-party AI services (currently Anthropic) on our servers to help compile onboarding preferences into discovery settings, rank name candidates for your feed, and generate short personalized reveal-card copy.
When these features run, preference and taste-related information you provide or generate in the Service (for example style notes, loved or disliked names, shortlist and dismissal signals, and related profile fields) may be sent to the AI provider for inference so we can return personalized results.
We do not use your personal name choices to train our own machine-learning models. Our AI providers process data under their terms as our processors or subprocessors. You should not submit sensitive information you do not want processed for personalization.
Giggle personalizes your results automatically. We use your onboarding answers and your in-app signals to build a taste profile, score and order name candidates, and assemble the queues and explore lists you see. This is profiling in the sense used by Canadian privacy law: an automated system infers preferences about you and shapes what the Service shows you.
We do not use automated processing alone to make decisions that produce legal effects or similarly significant effects about you — for example decisions about credit, employment, housing, insurance, or access to services. Personalization affects which names we suggest and in what order; it does not determine your eligibility for anything.
If you are in Quebec, the law gives you the right to be informed when a decision is based exclusively on automated processing of your personal information, to learn the personal information and principal factors used, and to have the decision reviewed by a person. If you believe such a decision has been made about you, contact privacy@gigglebaby.app and we will respond.
You can influence personalization directly by changing your onboarding preferences in the app, and you can ask us to reset your taste profile by contacting us.
Partner features are optional. If you create an invitation, the person who opens the link may see your email address and an approximate count of names you have saved. If both of you accept a link, each of you can see the other's shortlist (including updates while the link is active).
You control whom you invite. You can leave a couples link, which dissolves the shared relationship going forward. Invitation links expire after a limited period (approximately 14 days). Only invite people you trust.
Website. We do not currently set first-party analytics cookies on the website. The website may use browser local storage to remember shortlists and tool preferences on your device. The site may load fonts or other assets from third-party content delivery networks, which can receive standard technical request data such as IP address.
Mobile app. The app uses software development kits (including PostHog for product analytics and Sentry for crash reporting) that store identifiers and event data on your device and transmit them to those providers. These are not browser cookies but serve a similar purpose for analytics and reliability.
Browser signals. Because we do not run advertising trackers or share personal information for behavioural advertising, there is no cross-site advertising activity for a "Do Not Track" or Global Privacy Control signal to switch off on our website. We therefore do not currently respond to those signals, and we will update this section if that changes.
You can clear website local storage through your browser settings, and you can delete the mobile app or contact us to request account-related deletion as described below.
We use service providers who process personal information on our behalf or as needed to operate the Service. Key providers include:
• Supabase — authentication and database storage • Anthropic — AI inference for personalization features described above • RevenueCat — in-app subscription and entitlement management • Apple App Store and Google Play — payment processing for in-app purchases • PostHog — product analytics (mobile) • Sentry — crash and error reporting (mobile) • Vercel — hosting for the website and API
These providers may process data under their own privacy policies. We use contractual and other means to require that they provide a comparable level of protection while the information is being processed on our behalf, and that they use personal information only as needed to provide their services to us — except where they act as independent controllers of the information (for example Apple or Google in respect of store billing).
Beyond the service providers listed above, we may disclose personal information in these circumstances:
• At your direction. When you ask us to, such as when you create a partner invitation or link accounts with a partner. • Legal and safety reasons. To law enforcement, regulators, courts, or other government authorities where we believe in good faith that disclosure is required or permitted by law — for example in response to a subpoena, warrant, court order, or other lawful request — or where disclosure is necessary to investigate suspected fraud or a breach of an agreement, to protect the rights, privacy, safety, or property of you, us, or others, or to respond to an emergency that threatens someone's life, health, or security. • Professional advisors. To lawyers, accountants, auditors, bankers, and insurers in the course of the professional services they provide to us, subject to their duties of confidentiality. • Business transactions. In connection with an actual or prospective financing, investment, merger, acquisition, reorganization, or sale of all or part of our business or assets, or in an insolvency or receivership. Where Canadian privacy law permits a disclosure in connection with a prospective business transaction, we will use the information only for purposes related to that transaction and require the other party to protect it and to return or destroy it if the transaction does not proceed. If Giggle is acquired, we will notify you and the acquiring party will be bound by this policy for information collected before the change, unless you agree otherwise.
We do not otherwise share your shortlist, taste profile, or account information with third parties for their own purposes.
We do not sell, rent, or trade personal information, and we do not disclose it to third parties for their own advertising or marketing purposes. We do not participate in interest-based advertising networks or use advertising identifiers to target ads to you.
We may create de-identified, anonymized, or aggregated information from personal information — for example counts of how often a name is shortlisted across all users, or statistics about how people move through onboarding — and use it to understand demand, improve the name catalog and ranking, and describe the Service publicly.
We use this information in a form that does not identify you, and we do not attempt to re-identify de-identified information except to test that our de-identification works as intended, or as permitted by law. Where information is anonymized in accordance with generally accepted best practices and applicable law, it is no longer personal information under this policy.
Canada's Anti-Spam Legislation ("CASL") governs commercial electronic messages sent to or from Canada.
Today, the emails we send are transactional and service-related: account confirmation, password reset, partner invitations you ask us to send, subscription and account notices, and replies to your support requests. These are the messages needed to run the Service and to respond to your requests.
We do not currently operate a marketing mailing list. If we begin sending promotional or commercial electronic messages, we will do so only with the consent CASL requires, will identify ourselves and provide our contact information in the message, and will include a working unsubscribe mechanism that we honour promptly. Unsubscribing from promotional messages would not stop transactional messages about your account.
L12 Industries is based in Canada. Some of our service providers store or process personal information in the United States or other countries — for example analytics, hosting, AI inference, and subscription infrastructure. When you use the Service, your information may be transferred to, stored in, and processed in those locations as needed to operate Giggle.
While personal information is in another country, it is subject to the laws of that country and may be accessible to that country's courts, law enforcement, and national security authorities under their legal processes, and those laws may offer protections different from Canadian law. This notice is also intended to satisfy the requirement in Quebec to inform you that your personal information may be communicated outside Quebec.
Before entrusting personal information to a provider outside Canada, we assess whether the information will receive adequate protection, and we use contractual and other means to require a comparable level of protection while it is being processed on our behalf. We remain accountable for personal information transferred to our providers. If you would like more information about our practices for cross-border handling of personal information, contact privacy@gigglebaby.app.
We retain personal information only as long as necessary to fulfil the purposes for which it was collected, or as required by law. In practice, we retain account and profile data for as long as your account remains active, unless a shorter period applies or you ask us to delete it.
Share invitations typically expire after about 14 days. Certain explore-list sets rotate on a similar cadence. Behavioral signals used for ranking may be weighted or decayed over time as part of product design.
When we delete an account in response to a verified request, associated server-side profile, shortlist, dismissal, taste, queue, explore-list, and share records that cascade from your user account are removed from our primary database. Residual copies may remain briefly in backups or logs until those systems rotate. Local data on your devices may remain until you clear app storage, sign out (which clears certain local session and flow keys), or uninstall the app. Website local storage remains on your browser until you clear it.
Where we have used personal information to make a decision about you, we retain that information for the minimum period Canadian privacy law requires so that you have a reasonable opportunity to request access to it.
Subscription and purchase records held by Apple, Google, or RevenueCat are retained according to those providers' policies.
Subject to limited exceptions in Canadian privacy law, you have the following rights over the personal information we hold about you:
• Access. Ask us to confirm whether we hold personal information about you, and to give you access to it, along with an account of how it has been used and to whom it has been disclosed. • Correction. Ask us to correct information that is inaccurate, incomplete, or out of date. Where appropriate, we will pass the correction on to anyone who has access to the information. • Deletion. Ask us to delete your account and the personal information associated with it. • Withdraw consent. Withdraw your consent as described in the Your consent section above. • Portability. If you are in Quebec, request that the computerized personal information you provided to us be communicated to you, or to another organization you designate, in a structured, commonly used technological format. • Object to certain uses. Ask us to stop using your information for a particular purpose, such as resetting your taste profile.
How to make a request. Email privacy@gigglebaby.app from the address associated with your account when possible, and describe what you are asking for. We may need to verify your identity before we act, and we will only ask for the information needed to do that.
Our response. We will respond in writing within 30 days of receiving your request, as PIPEDA requires, or tell you within that period if we need an extension permitted by law and why. Access is generally provided at no cost; if a request would involve a cost, we will tell you the estimated cost in advance and give you the chance to withdraw or modify the request. We may be unable to fulfil part of a request — for example where doing so would reveal personal information about another person, where the information is protected by solicitor-client privilege, or where another legal exception applies. If we refuse a request in whole or in part, we will explain why and tell you how to challenge our decision.
Today, account deletion and data export are handled by email request rather than a self-serve in-app tool. Signing out of the app does not by itself delete your server-side account data.
If you have a question or concern about how we handle personal information, please start with our Privacy Officer at privacy@gigglebaby.app. We will acknowledge your concern, investigate it, and tell you the outcome. If we find your complaint is justified, we will take appropriate steps, including correcting our practices and policies where needed.
If you are not satisfied with our response, you may contact the privacy regulator for your jurisdiction:
• Office of the Privacy Commissioner of Canada — priv.gc.ca • Quebec: Commission d'accès à l'information du Québec — cai.gouv.qc.ca • Alberta: Office of the Information and Privacy Commissioner of Alberta — oipc.ab.ca • British Columbia: Office of the Information and Privacy Commissioner for British Columbia — oipc.bc.ca
Giggle is intended for adults making naming decisions. Our Terms of Service require you to be at least 18 years old to use the Service. The Service is not directed to children or to anyone under 18, and we do not knowingly collect personal information from them.
We do not ask for a user's age beyond the confirmation of eligibility described in our Terms of Service, and we do not build profiles of minors.
If you are a parent or guardian and believe someone under 18 has provided us with personal information, contact privacy@gigglebaby.app. We will verify the situation and take steps to delete the information and close the account promptly.
We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encrypted session storage on supported mobile platforms, encryption of data in transit, and access controls limiting who on our side can reach production data. Our service providers are required to maintain comparable protections.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
If a breach of security safeguards involving your personal information creates a real risk of significant harm to you, we will report the breach to the Office of the Privacy Commissioner of Canada and notify you as soon as feasible, as PIPEDA requires, and will meet any additional notification obligations under provincial law, including Quebec's confidentiality incident requirements. We keep records of breaches of security safeguards as the law requires.
The Service may link to websites, apps, and services operated by others — for example the Apple App Store, Google Play, or pages we reference in editorial content. A link is not an endorsement, and we do not control how those third parties handle your personal information. Their privacy policies, not ours, govern what they collect when you visit them. We encourage you to read them.
We may update this Privacy Policy from time to time. We will revise the "Last updated" date at the top and, for material changes, provide additional notice through the Service or by email where appropriate. Where a change would involve using personal information we already hold for a materially new purpose, we will obtain your consent where the law requires it. Continued use of the Service after an update becomes effective means you acknowledge the revised policy.
For privacy questions or requests, contact our Privacy Officer:
Privacy Officer L12 Industries Toronto, Ontario, Canada privacy@gigglebaby.app
Questions? Email privacy@gigglebaby.app