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. USER 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.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available HERE,
and sending it to: dpo@pic-time.com.
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Certain rights can be easily executed independently by you without the need to fill out the DSR Form:
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• 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. 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 are not intended for use by children, and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: dpo@pic-time.com if you have reason to believe that a child has shared any data 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 California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”) (collectively “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.

ADDITIONAL INFORMATION FOR COLORADO RESIDENTS
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This section applies to Colorado residents acting only as an individual or household context (and not in a
commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context). Pursuant to the Colorado Privacy Act (“CPA”) please see below the disclosure of the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise
their rights, and appeal such decision, categories of third-parties the controller shares or sells the Personal Data, or sells the Personal Data for advertising and how to opt-out.

“Personal Data” as defined in the CPA means information that is linked or reasonably linkable to an identified or identifiable individual and 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 CPA scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA),
the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

“Sensitive Data” include (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. Under CPA, Pic-Time needs to provide a privacy notice that identifies the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision, categories of third-parties the controller shares or sells the personal data, or sells the Personal Data for advertising and how to opt-out.

Highlights Sections
In Section 3 to the Privacy Policy, 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. Additionally, Section 5 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 6 to this Privacy Policy details and discloses your rights and Personal Data
shared or sold for targeted advertising.

Deletion Right Exemptions
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Only you, or someone legally authorized to act on your behalf, may make a request to know or delete your Personal Data. If the request is submitted by someone other than you, proof of authorization (such as power of attorney or probate documents) will be required. The deletion right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) complete the transaction for which we collected the Personal Data or Personal Information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) debug products to identify and repair errors that impair existing intended functionality; (4) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) comply with the law or legal obligation; (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.

Response Timeline
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We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at: dpo@pic-time.com and specifying you wish to appeal. Within 60 days 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 as follows: Colorado AG at: https://coag.gov/file-complaint/.If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request. Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.


ADDITIONAL INFORMATION FOR CONNECTICUT RESIDENTS

‍Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (“CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable individual and 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 CDPA scope, such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. “Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal data collected from a known child; Precise geolocation data. In certain cases, we will process precise geolocation data if you explicitly enable the GPS permission within our properties. Under CDPA, Pic-Time is required to provide you with a clear and accessible privacy notice that includes categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.Please read the “Highlights Sections” and “Deletion Right Exemptions” paragraphs under the CPA Additional Information.

Response Timeline

‍We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45-day response period, together with the reason for the extension.If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days 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 Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

ADDITIONAL INFORMATION FOR VIRGINIA RESIDENTS

‍Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person, and does not include publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; Information excluded from the VCDPA scope, such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. The VCDPA requires Pic-Time to disclose the categories of Personal Data processed, the purpose of processing, how you can exercise your rights, including how you may appeal our decision with regard to the consumer request, the categories of Personal Data shared with third parties, and with whom, and if the Pic-Time sells Personal Data to third parties or processes Personal Data for targeted advertising. Please read the “Highlights Sections” and “Deletion Right Exemptions” paragraphs under the CPA Additional Information.

Response Timeline

‍We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at: dpo@pic-time.com and specifying you wish to appeal. Within 60 days 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 Virginia Attorney General HERE.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request. Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.


‍ADDITIONAL INFORMATION FOR UTAH RESIDENTS (EFFECTIVE JENUARY 2024)

‍Under the Utah Consumer Privacy Act (“UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your Personal Data are described below. “Personal Data” means data that is linked or reasonably linkable to an identifiable individual, and does not include de-identified data and publicly available data or data that is processed not within the scope of UCPA. Please read the “Highlights Sections” paragraph under the CPA Additional Information.

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ADDITIONAL NOTICE TO NEVADA RESIDENTS

‍Nevada law allows Nevada residents to opt out of the sale of certain types of Personal Information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to us at dpo@pic-time.com or through the DSR Form.

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