Privacy Policy

Effective Date: October 11, 2019


Snapshots, Inc. is committed to protecting your privacy and developing technology that gives you a powerful and safe consumer experience. This Privacy Policy outlines how Snapshots, Inc. and its affiliated companies and subsidiaries based in the United States (collectively, "PhotoDay" or "we") collect information, what information PhotoDay collects, how PhotoDay uses information, to whom PhotoDay discloses this information and how you can access, change and remove your information.

COLLECTION OF YOUR INFORMATION

PhotoDay may collect personally identifiable information from you in various ways. PhotoDay may use the following sources:

Personally identifiable information refers to information about you that can be used to contact or identify you. It includes, but is not limited to, your name, phone number, email address, postal address, certain biometric information [pursuant to our policy on the collection and use of biometric information available here] , and social networking information. The collected information falls into the following categories:

PhotoDay may also collect certain non-identifying information, or aggregate information, such as anonymous demographic information including zip codes, dates of birth, customer preferences, information about customer computer hardware and software, as well as information about the links and pages that users access within an PhotoDay website. Certain non-identifying information may be considered personally identifiable information if combined with other information which may enable you to be identified (such as a zip code with a street address); however, the same information when taken alone or combined with other non-identifying information, will be considered non-identifying information.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through PhotoDay operated public forums and sites, such information may be collected and used by others.

Occasionally PhotoDay will offer links to third party websites, including those to process payments from you on PhotoDay's behalf. PhotoDay encourages you to review the privacy policies of websites you choose to link to from PhotoDay websites so that you can understand how those websites collect, use, and share your information. PhotoDay is not responsible for the privacy policies or other content on websites other than PhotoDay websites.

USE OF YOUR INFORMATION

PhotoDay may store and use your personally identifiable information for (i) product or service fulfillment, (ii) voluntary marketing, promotional, and advertising purposes, such as to inform you of products or services available from PhotoDay, (iii) internal operations, such as improving your customer experience – this includes auditing current interactions and optimizing user experience, (iv) detecting security incidents, protecting against malicious, deceptive activity, and taking all necessary and appropriate steps to mitigate current and future risk; (v) debugging and repairing internal information technology as necessary; (vi) undertaking internal research for technological development and demonstration; and (vii) to share with trusted third party service providers to help PhotoDay perform activities to improve your customer experience with your consent ("Business Purposes"). Third parties are prohibited from using your personal information beyond providing services to PhotoDay and are required to maintain the information's confidentiality and privacy. The categories of the third parties we share personal information with follow:

The following categories of information are shared for Business Purposes:

PhotoDay does not sell, rent, or lease your personally identifiable information to third parties. PhotoDay may, from time to time, contact you on behalf of external business partners about an offering that may be of interest to you. In those cases, at your consent, your personally identifiable information would be transferred to the third party.

PhotoDay is not limited in our use of aggregate information that does not permit direct association with any specific individual, such as the number of users of our services, the geographic distribution of our users, the amount of information located or removed, etc. For example, PhotoDay may use aggregate information concerning which links and pages users access within PhotoDay's Digital Services for many reasons including to determine which PhotoDay products and services are the most popular. This data may be used to deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area.

PhotoDay will disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary (a) to conform to the edicts of the law or to comply with legal process served; (b) to protect and defend the rights or property of PhotoDay; or (c) under exigent circumstances to protect the personal safety of users of the PhotoDay website or the public.

Additionally, PhotoDay may disclose personally identifiable information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

As with any other business, PhotoDay may merge with or be purchased by another company. If PhotoDay is acquired, the company that acquires us would have access to the information maintained by us, including personally identifiable information, but would continue to be bound by this Policy unless and until it is amended.

REQUESTS TO PHOTODAY

PhotoDay strives to not only provide you with excellent experience; but also strives to do so in an ethical, lawful, and sustainable manner. Part of this is responding to data requests and providing you with certain information under various data protection and security laws ("Data Subject Request"). This Policy outlines how you can receive the information and what you can receive.

If you would like to submit a Data Subject Request, you can complete one online at PhotoDay. www.photoday.io/datarequest. If you would like to email your Data Subject Request you may send the support@photoday.io.

PhotoDay's online form must be completed accurately and completely before PhotoDay can respond. If you choose to submit a Data Subject Request you must provide us with enough information to identify you (e.g., PhotoDay profile information, order confirmation, or matter number) and enough specificity on the requested data. PhotoDay will only use the information it receives for verification. PhotoDay will not be able to disclose information if it cannot verify that the person making the Data Subject Request is the person about whom we collected information, or someone authorized to act on such person's behalf.

You may submit a Data Subject Request to receive information about PhotoDay's data collection practices. You may request information on the categories of personal information PhotoDay has collected about you; the categories of data collection sources; PhotoDay's business or commercial purpose for collecting or selling personal information; the categories of third parties with whom PhotoDay shares personal information, if any; and the specific pieces of personal information we have collected about you. If you would like to also receive information about PhotoDay's data disclosure for Business Purpose, then please include that in the Data Subject Request. PhotoDay will clarify whether the information was collected and disclosed or simply collected and kept internally.

Please note that the categories of personal information and sources will not exceed what is contained in this Privacy Policy. Additionally, PhotoDay is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. PhotoDay is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

You may request that PhotoDay delete your personal information. Your deletion request should be submitted through a Data Subject Request. Subject to certain exceptions set out below we will, on receipt of a verifiable Data Subject Request, delete your personal information from our records and direct any service providers to do the same.

Please note that we may not delete your personal information if it is necessary to:

PhotoDay may not, and will not, treat you differently because you of your Data Subject Request activity. As a result of your Data Subject Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

SECURITY PROTECTIONS FOR YOUR DATA

PhotoDay takes the security of your personal information very seriously. PhotoDay uses reasonable administrative, physical, and technical safeguards to secure the personal information you share with us. Despite these safeguards and our additional efforts to secure your information, PhotoDay cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information.

The security of your PhotoDay website account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on a PhotoDay website.

Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately by emailing privacy@photoday.io. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately by emailing privacy@photoday.io.

USE OF COOKIES AND SIMILAR TECHNOLOGY

PhotoDay websites work with a first party cookie that collects anonymous traffic data, a form of aggregate information. "Cookies" are simple text files stored on your computer for use by a browser. PhotoDay may use "cookies" to assist in data collection and to track visitor website usage and trends to help us better serve you. If you reject cookies, you will still be able to view our websites, but your ability to use some areas of the websites will be limited. Some of our business partners and publishers (e.g., analytical tracking software providers) use cookies and tracking technologies on our websites. We have no access to or control over these third party cookies or tracking technologies. This Policy covers the use of cookies on our websites by us only and does not cover the use of cookies or tracking technologies by any such business partner.

We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our websites or social media and whether certain content, such as a video was viewed. We may work with a trusted third party to collect and process this information for us, based on our instructions and in compliance with this Privacy Policy.

When you visit PhotoDay's website, PhotoDay automatically collects the name of the website you visited from (called the "referring page") and the name of the website you chose to visit immediately after ours (called the "exit page"), and information about other websites you have recently visited. This information is used to improve our website, but we cannot identify you from any information we receive from cookies. Some browsers have a "do not track" feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our websites are not currently set up to respond to those signals for tracking on our websites.

PARTICIPATION IN INTERNET BASED ADVERTISING

PhotoDay may also participate in interest-based advertising using similar technology. Therefore, you may see advertising on our websites tailored to how you browse or shop, or you may see advertising for PhotoDay and its properties on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for PhotoDay and its websites, but no personal information about you is shared with those third party ad networks. Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser, or your device settings for additional information.

You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (http://www.networkadvertising.org/choices/) and DAA website (http://www.aboutads.info/choices/).

GOOGLE ANALYTICS

We utilize Google Analytics, which stores information about what pages you visit, how long you are on our website, how you got here, and what links you click on. This analytics data is collected via a JavaScript tag in the pages of our website and is not tied to any Personally Identifiable Information. If you would like to opt out of Google Analytics, Google has developed a tool that works with major internet browsers to permit you to opt-out. For more information and to install their opt-out tool, please click here: https://tools.google.com/dlpage/gaoptout.

PRIVACY POLICIES OF THIRD-PARTY SITES

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site's privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

CHILDREN'S PRIVACY

PhotoDay' websites are not targeted for use by children under the age of 13 . PhotoDay does not knowingly collect personal information from children in connection with the features of our Digital Services without the consent of a parent or guardian. PhotoDay requests that all visitors under 13 to our websites to not disclose or provide any personally identifiable information. Upon notification that a child under 13 has provided us with personally identifiable information, we will delete the child's personally identifiable information from our records. If you believe we might have any information from a child under the age of 13, please email us at support@photoday.io.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS

In addition, if you are a California resident under the age of 18, and are a registered user, you may request that we remove content or information posted on our websites or stored on our servers by (a) submitting a request in writing to support@photoday.io and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted in this Privacy Policy on how to request removal of such content or information; and (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

USERS OUTSIDE THE UNITED STATES

PhotoDay is based in the United States, and the Digital Services are hosted here. If you are using the Digital Services from another country, the laws governing our website's collection and use of personal information may be different from the laws of your country. If you decide to use the Digital Services or share your personal information with PhotoDay, you are agreeing to be governed by the laws of the United States, and you are expressly consenting to the transfer of your data to the United States.

In particular, please note that neither our website, nor the products and services we offer on our website, nor any other activities we carry out as set out in this Privacy Policy are aimed at individuals based in the United Kingdom or any jurisdiction within the European Economic Area ("EEA").

CHANGES TO THIS PRIVACY POLICY

PhotoDay will occasionally update this Privacy Policy. PhotoDay encourages you to periodically review this Privacy Policy to be informed of how PhotoDay is using and protecting your information. At a minimum, this Privacy Policy will be updated every twelve months.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Service. The Service may contain links to other web sites not operated or controlled by PhotoDay (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Service do not imply that PhotoDay endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

INTEGRATING THIRD PARTY SERVICES WITHIN THE SERVICE

One of the special features of the Service is that it allows you to enable various online third party services, such as social media and social networking services ("Third Party Services"), to be directly integrated into your PhotoDay experience. By directly integrating these services, we make your online experiences richer, and more personalized. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third Party Services. By enabling such Third Party Services, you are allowing us to pass your log-in information to these service providers for this purpose. When you add a Third Party Service account to the Service, we will collect your login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed solely by the policies of such third parties, and PhotoDay shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within the Service.

CONTACTING PHOTODAY

Please also feel free to contact us if you have any questions about PhotoDay's Privacy Policy at support@photoday.io.