Privacy Policy

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above. In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

4. HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
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• Automatically, when you visit our website or interact with the Platform, including through the use of Cookies (as detailed below) and similar tracking technologies.
• Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, as through the Services, contact us communications, registration, etc.
• Provided by Third Parties – as detailed above, our Photographers may provide us with your photographs or email address.

COOKIES AND SIMILAR TECHNOLOGIES:

We use “cookies” (or similar tracking technologies) when you access the website or interact with the Services we offer. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. You can find more information about cookies at http://www.allaboutcookies.org/.Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies, as well as change your settings and preferences, as detailed under our Cookie Policy.

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Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Transfer of Data section below, is based on the same lawful basis as stipulated in the table above. In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

6. YOUR RIGHTS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending
on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include:
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For additional information on your rights and how to exercise your rights, please see the Data Subject Request (“DSR”) form available HERE, and sending it to: dpo@pic-time.com.

‍Certain rights can be easily executed independently by you without the need to fill out the DSR Form: As a Photographer, you can correct certain data provided under your Account (such as contact information) through the account settings;

You can opt-out from receiving our emails by clicking “unsubscribe” link; You can delete Photographs;
You can use the cookie settings tool on our website to change your preferences.You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytics HERE.

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7. DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out (where applicable), or terminate your use of the Services, or you request to delete your Personal Data. Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

8. SECURITY MEASURES:

At Pic-Time, security is our highest priority. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using11SSL, we minimize the amount of data that we store on our servers, restrict access to Personal Data to Pic- Time employees, contractors and agents, etc. To learn more, you can review our Security Policy.
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Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
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Please contact us at: dpo@pic-time.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the
appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

9. INTERNATIONAL TRANSFER OF DATA:
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Our data servers in which we host and store the information are located in the EU, the US and Australia. The Company’s HQ are based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM, Salesforce, and other systems. We will take appropriate
measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the EEA is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such
Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA is transferred, in all cases pursuant to standard contractual clauses approved by the European Union ("SCCs").
Additionally, following the withdrawal of the United Kingdom (“UK”) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure
the security of the Personal Data (pending an adequacy decision from the European Commission).
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10. ELIGIBILITY AND CHILDREN PRIVACY:
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Pic-Time website and Services. The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law), and we do not knowingly process children's information. We will discard any information we receive from a User that is considered a "child" immediately upon discovering that such a User shared information with us. Please contact us at: dpo@pic-time.com if you have reason to believe that a child has shared any information with us.

11. JURISDICTION-SPECIFIC NOTICES:
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ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
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This section applies only to California residents. Pursuant to the CCPA. Please see the CCPA Privacy Notice, which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom we share the Personal Information for a business purpose, whether the Personal Information is sole or shared, the retention period, and how to exercise your rights as a California resident

12. ADDITIONAL NOTICE TO US RESIDENTS:

Residents of certain U.S. states (depending on the applicable state law, acting as an individual or in the household context only and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context or as representative of a business), may have additional rights under applicable privacy laws and be entitled to additional disclosures.
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“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope.

“Sensitive Data” includes data revealing racial, ethnic or national origin; religious beliefs; information regarding an individual’s medical history, mental or physical health condition, diagnosis or medical treatment; neural data; status as transgender or non-binary; sex life or sexual orientation; status as a victim of a crime; citizenship or immigration status;  genetic or biometric data; Personal Data collected from a known child; and precise geolocation data. We will obtain your consent before collecting Sensitive Data, such as the biometric identifiers described above, even if they are not used to identify you.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, including any Sensitive Data, the purpose of processing, the categories of Personal Data shared with third parties, the categories of third parties with whom Personal Data is shared, the categories of Personal Data that is sold or used for targeted advertising, if any, the categories of third parties to whom the Personal Data is sold, if any, a list of your data rights and instructions for exercising those rights and appealing decisions, and out contact information. This information is detailed under this Privacy Policy and further below.

Categories of Personal Data & Categories of Third Parties with Whom Personal Data is Shared:

‍Under Section 3 of the Privacy Policy “Data Sets We Collect And For What Purpose”, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent, unless we are otherwise entitled, required or permitted under applicable laws.

Additionally, under Section 5 of the Privacy Policy “Data Sharing– Categories of Recipients We Share Personal Data With” we detail and disclose the categories of third parties we share Personal Data with for a business purposes.

“Sale” of Personal Data:
‍Under US privacy laws, in principle, the term “sale” refers to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as this term is commonly understood, meaning - we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term “sale” under applicable US privacy laws, our practice of using “cookies or other third-party advertising services and sharing Personal Data for such purpose to third party advertising and marketing providers (e.g., providers of marketing tools and analytic tools, advertising networks, social media networks, media buying, search platforms) is considered a “sale”.

Such practice includes the following Personal Data categories shared with these third parties:
Identifiers – online identifiers such as IP and Cookie ID;

Internet and electronic network activity information – such as your engagement with our website and ads.

Geolocation data – derived from IP.

‍Consumer Rights Related to Their Personal Data:
‍Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
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Access – the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.

List of Third Parties – the right to receive a list of the specific third parties to which we have disclosed either your Personal Data or any Personal Data.

Delete – the right to request us to delete their Personal Data provided to or obtained by us.

Correct – the right to request us to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.

Opt-Out – the right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for profiling in furtherance of making decisions that produce legal or similarly significant effects. However, as noted above, we do not engage in profiling in furtherance of legal or similarly significant decisions.

Appeal – the right to appeal if we decline to take action in response to your exercise of a privacy right.

Non-Discrimination – the right to not be discriminated against for exercising your privacy rights.

Section 6 under this Privacy Policy “Your Rights” provides additional information regarding your principal rights.

‍Exercising Consumer Privacy Rights:
‍You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by submitting a Data Subject Request form available here or sending an email to our DPO: dpo@pic-time.com.

Further, certain rights can be exercised from the App: you may correct, revise and delete information using the App settings at any time. Additionally, any consent provided may be easily withdrawn and you may opt-out from certain features and tracking. Therefore, we recommend you use the technical solutions we have provided you to exercise your rights.

For certain rights, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual, provided that they provide proof of their authorization, and we may also require that the individual directly verify his/her identity and the authority of the authorized agent.

We will respond to your request within the timeframe required under applicable law, and we reserve the right to extend the response time subject to applicable law requirements. If we refuse to take action on a request, we will notify you and our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.

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