PRIVACY POLICY

Effective Date: July 30, 2020
This privacy policy describes the treatment of information provided or collected on the sites where this privacy
policy is posted. It also explains the treatment of information provided or collected on applications we make
available on third-party sites or platforms if disclosed to you in connection with use of the application. We follow
this privacy policy in accordance with local law in the places where we operate.


1. Types of Information We Collect
2. How We Collect Your Information
3. Use of Your Information by Fotorama USA LLC
4. Sharing Your Information with Other Companies
5. Children’s Privacy
6. Data Security and Integrity
7. Data Transfers, Storage and Processing Globally
8. Changes to this Privacy Policy
9. Comments and Questions


1. Types of Information We Collect
We collect two basic types of information – personal information and anonymous information – and we may use
personal and anonymous information to create a third type of information, aggregate information. We collect the
following categories of information:


● Transaction information you provide when you request information or purchase a product or service from
us, whether on our sites or through our applications, including your postal address, telephone number
and payment information
● Information you provide in public forums on our sites and applications
● Information you provide to us when you use our sites and applications, our applications on third-party
sites or platforms such as social networking sites, or link your profile on a third-party site or platform with
your registration account
● Location information when you visit our sites or use our applications, including location information either
provided by a mobile device interacting with one of our sites or applications, or associated with your IP
address, where we are permitted by law to process this information
● Usage, viewing and technical data, including your device identifier or IP address, when you visit our sites,
use our applications on third-party sites or platforms or open emails we send.


2. How We Collect Your Information


● We collect information through technology, such as cookies, Flash cookies and Web beacons, including
when you visit our sites and applications or use our applications on third-party sites or platforms.
● We acquire information from other trusted sources to update or supplement the information you provided
or we collected automatically. Local law may require that you authorize the third party to share your
information with us before we can acquire it.


3. Use of Your Information by Fotorama USA LLC


● Provide you with the products and services you request

● Communicate with you about your account or transactions with us and send you information about
features on our sites and applications or changes to our policies
● Consistent with local law and choices and controls that may be available to you:
● Send you offers and promotions for our products and services or third-party products and services
● Personalize content and experiences on our sites and applications
● Provide you with advertising based on your activity on our sites and applications and on third-party sites
and applications
● Optimize or improve our products, services, and operations
● Detect, investigate and prevent activities that may violate our policies or be illegal


4. Sharing Your Information with Other Companies


We will not share your personal information outside Fotorama USA LLC except in limited circumstances,
including:
When you allow us to share your personal information with another company, such as:
Electing to share your personal information with carefully selected companies so that they can send you offers
and promotions about their products and services.
Directing us to share your personal information with third-party sites or platforms, such as social networking sites.
Please note that once we share your personal information with another company, the information received by the
other company becomes subject to the other company’s privacy practices.
When companies perform services on our behalf, like package delivery and customer service; however, these
companies are prohibited from using your personal information for purposes other than those requested by us or
required by law
When we share personal information with third parties in connection with the sale of a business, to enforce our
Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and
property and the rights and property of our guests and third parties, to comply with legal process or in other
cases if we believe in good faith that disclosure is required by law.


5. Children’s Privacy
We recognize the need to provide further privacy protections with respect to personal information we may collect
from children on our sites and applications. Some of the features on our sites and applications are age-gated so
that they are not available for use by children, and we do not knowingly collect personal information from children
in connection with those features. When we intend to collect personal information from children, we take
additional steps to protect children’s privacy, including:


● Notifying parents about our information practices with regard to children, including the types of personal
information we may collect from children, the uses to which we may put that information, and whether
and with whom we may share that information
● In accordance with applicable law, obtaining consent from parents for the collection of personal
information from their children, or for sending information about our products and services directly to their
children
● Limiting our collection of personal information from children to no more than is reasonably necessary to
participate in an online activity
● Giving parents access or the ability to request access to personal information we have collected from
their children and the ability to request that the personal information be changed or deleted

6. Data Security and Integrity

The security, integrity and confidentiality of your information are extremely important to us. We have
implemented technical, administrative and physical security measures that are designed to protect guest
information from unauthorized access, disclosure, use and modification. From time to time, we review our
security procedures to consider appropriate new technology and methods. Please be aware though that, despite
our best efforts, no security measures are perfect or impenetrable.


7. Data Transfers, Storage and Processing Globally


We operate globally and may transfer your personal information to individual companies of Fotorama USA LLC
or third parties in locations around the world for the purposes described in this privacy policy. Wherever your
personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the
privacy of your personal information. Additionally, when using or disclosing personal information transferred from
the European Union, we abide by the Safe Harbor Principles as set forth by the U.S. Department of Commerce,
use standard contract clauses approved by the European Commission, adopt other means under European
Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements
of the Safe Harbor Principles when transferring personal information from Australia.


8. Changes to this Privacy Policy


From time to time, we may change this privacy policy to accommodate new technologies, industry practices,
regulatory requirements or for other purposes. We will provide notice to you if these changes are material and,
where required by applicable law, we will obtain your consent.


9. Comments and Questions


If you have a comment or question about this privacy policy, please contact sales@fotoramausa.com.
Our sites and applications may contain links to other sites not owned or controlled by us and we are not
responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or
applications and to read the privacy policies of other sites that may collect your personal information.