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California Consumer Privacy Act Privacy Policy

Effective Date/Last Updated: 17 January 2023.

The section of the Privacy Policy relates to the California Consumer Privacy Act (CCPA Section) applies solely to individuals who are residents of the State of California (consumers or you) as required under the California Consumer Privacy Act, as amended, including without limitation by the California Privacy Rights Act of 2020 (CCPA). This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use our website (www.polaroid.com including without limitation the sub domain names: radio.polaroid.com and press.polaroid.com, hereinafter referred to as the Website), when you create account and become a member of our loyalty program, when you make use of our products or services or through other channels including but not limited to phone and email conversations, attending our events, social media interactions on other third party websites such as social media websites, viewing our emails, or through our authorized services providers.

This CCPA Section supplements the information contained in the Privacy Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. All other terms shall have the meaning set forth in the Privacy Policy or Terms of Use as applicable. The other provisions of the Privacy Policy continue to apply except as supplemented by this CCPA Section.

Please read this CCPA Section carefully before using the Website or submitting personal information to us. This CCPA Section is incorporated into and subject to our Terms of Use. BY ACCESSING OR USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS CCPA SECTION AND THE TERMS OF USE. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this CCPA Section, please do not provide us with such information. This CCPA Section does not apply to third-party websites accessible through our Website or other applications.

Personal Information We Collect

As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (PI or personal information).We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.

  • Identifiers – such asreal name, alias, billing and postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
  • Other elements– such asname, characteristics or description, address, telephone number, bank account number, credit card number and preferences expressed (e.g. communication and shopping preferences), and settings chosen.
  • Commercial information – such asproducts and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity – such asbrowsing history, search history, online shopping activities, a consumer’s interaction with an internet website, application, or advertisement, access dates and times, app features or web pages viewed, app crashes and other system activity.
  • Geolocation data – such aslocation information while using one of our apps or the Website, including where you have registered with us and where you place an order with us.
  • Sensitive Information. – such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; the contents of a consumer’s mail and email, unless the business is the intended recipient of the communication.

Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

We will retain your personal data for no longer than is necessary for the purpose(s) for which it is collected or processed, unless we have or deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.

With regards to the use of our digital services, we will retain your data for a period of two (2) years after your last login using our (account) services. The reason is that when you would reactivate your account, you can easily continue to make use of our services within that two-year period. If you are inactive for a longer period of time, we will notify you and remove your data, unless you indicate otherwise. However, a longer retention period of your personal data may occur if this is necessary to comply with a legal obligation. For example, in our accounting system certain personal data are required to be retained for a minimum of 7 years after the end of a tax year. If a dispute or (legal) proceedings are expected, we may also retain your personal data for a longer period of time.

Purposes We Collect and Use Personal Information

We collect and use your PI for the following business or commercial purposes.We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.

A. to make the Website available to you;

B. to provide you with information, products, or services you request from us.

C. to process payments;

D. to provide you with content which is tailored to your individual tastes;

E. to maintain any registered account that you hold with us and to enable you to take part in our loyalty program;

F. to contact you (including by push notifications and email) about availability of products, promotional offers and products and services which we think may interest you;

G. to communicate with you in social media concerning our products and services;

H. to carry out our obligations and enforce our rights including those arising from any contracts entered into with you including for billing, payment, and collections;

I. where we have a legal right or duty to use or disclose your personal data (including for crime and fraud prevention and combating and to comply with a court order) or for company acquisition/asset sale;

J. to ensure that content from our services is presented in the most effective manner for you and your device. We may create lookalike audiences with the help of third parties for the same purpose;

K. to administer, secure, adapt and improve our services, the Website and for internal operations, including, for example, to prevent fraud and abuse of our services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends;

L. to provide customer service and engage in quality control activities concerning our products and services;

M. to comply with legal obligations applicable to Polaroid;

N. obtaining external (legal) advice and/or the establishment, exercise or substantiation of a legal claim;

O. as necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public; and

P. to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sources of Personal Information We Collect

  • You. We may collect personal information that you provide during your interactions with us, such as through our Website, by email, or when you communicate with our associates online or by phone. We may also collect information when you attend an event, or participate in an online challenge or promotion. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
  • Related Entities and Affiliates. We may collect information about you from our related parties and affiliates.
  • Service providers and contractors. When you obtain products and services from us, we may collect your PI from service provider and contractors who collected information about you that is needed to provide those products and services.
  • News outlets, social media, surveys, and certain third parties. In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of PI about you.
  • Information Collected Automatically. As you navigate through and interact with our Website, we may compile statistical information concerning your usage of the Website through analytics services, such as those provided by Google Analytics and Google Enhanced. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:
    • Details of your visits to our Website, such as traffic data, location data, logs and other communication data and the resources that you access and use on the Website
    • Information about your computer and internet connection, including your IP address, operating system, and browser type.
    • Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Website.
    • Information about your preferences to make your use of the Website more productive, via the use of Cookies. For more information on Cookies, please see our Cookie Policy.While all of this information can be associated with the IP address your computer had while you visited the Website, it will not be associated with you as an individual or with any other information you may submit through the Website or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Website. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

IMPORTANT: BY USING THE WEBSITE, YOU CONSENT TO THE PROCESSING OF ANY PERSONAL INFORMATION FOR THE PURPOSES AND FUNCTIONS DESCRIBED ABOVE.

Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you.However, because our Website is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.

Third Party Website Links. Some portions of our Website may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

Email Communications. We may collect your email address via cookies and pixels on the Website through the use of trusted third-party partners.These partners may combine your email information with other information they have access to such as mailing address so that we may send relevant marketing offers to you via direct mail.

Disclosures of Personal Information.

We do not sell or share your personal information to third parties, we do not have actual knowledge that we have sold personal information of minors under age 16. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.

We may, however, disclose your personal information with services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services.

We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer to a third-party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.

Of the categories of PI collected noted above, during the past 12 months, we disclosed the following:

I. Address and other identifiers- such as name, alias, postal addresses, email address, phone number, user or account name, unique personal identifier, online identifier, Internet Protocol address or other similar identifiers) – are shared with the following Third Parties for the purposes as indicated:

  1. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.
  2. Our business partners. For example, we might disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  3. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
  4. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

II. Financial information – such as bank account details, credit history, income details or other similar identifiers in combination with any required security or access code, password, or credentials allowing access to an account – is shared with the following Third Parties for the purposes as indicated:

  1. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.
  2. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  3. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
  4. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
  5. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

NOTE: The information in this category may include the following elements of Sensitive Personal Information: log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credential allowing access to an account

III. Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers – is shared with the following Third Parties for the Purposes as indicated:

  1. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.
  2. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  3. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
  4. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
  5. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

IV. Internet or other electronic network activity – such as browsing history, search history, online shopping activities, a consumer’s interaction with an internet website, application, or advertisement, access dates and times, app features or web pages viewed, app crashes and other system activity – is shared with the following Third Parties for the purposes as indicated:

  1. Third parties as directed by you. We may disclose your personal information to third parties to whom you direct.
  2. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  3. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
  4. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
  5. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

NOTE: The information in this category may include the following elements of Sensitive Personal Information: the contents of mail, email, or text messages, to which the business was not the intended recipient.

V. Geolocation data – including where you have registered with us and where you place an order with us – is shared with the following Third Parties for the purposes as indicated:

  1. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.
  2. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  3. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
  4. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
  5. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

NOTE: The information in this category may include the following elements of Sensitive Personal Information: precise geolocation.

Our Websites and Children

We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.

Security

We take precautions to protect data and information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. However, no system for safeguarding personal or other information is 100% secure and, although we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information.

Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding the password, security questions and answers, and other authentication information you use to access our Website.

Applicable law

This CCPA Section is governed by the laws of the State of California, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this CCPA Section shall lie exclusively with the state and federal courts within California. If any provision of this CCPA Section is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this CCPA Section, which shall remain in full force and effect.

Changes to this CCPA Section

We reserve the right to revise this CCPA Section at any time. If we make any material changes, we will update the date noted above. We reserve the right to provide notice of any changes in other ways as well. Your use of this Website or submission of personal information after such changes constitutes your agreement to the CCPA Section as amended. Except to the extent we receive your authorization, or as permitted or required by applicable law, we will handle your personal information in accordance with the terms of this CCPA Section and the Privacy Policy in effect at the time of the collection. Please check our Website periodically for updates.

Shine the Light. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Polaroid to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding 2021 sharing activities). You may submit your request using the contact information in this Policy.

Eraser Law. If you are a California resident under the age of 18, and a registered user of any Website where this Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in this Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Your Rights Under the California Consumer Privacy Act. The section described your rights under the CCPA with respect to your personal information.

Right To Know About Personal Information Collected or Disclosed.We generally describe in this CCPA Section our current and practices for the prior 12 months related to the categories of personal information we collect, how we collect and use the personal information, and how we disclose your personal information. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics for the preceding 12 months, to the extent applicable:

  • the categories of personal information,
  • the categories of sources from which the personal information is collected,
  • the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,
  • The categories of personal information we sold or disclosed for a business purpose,
  • the categories of third parties to whom the business discloses personal information, and
  • the specific pieces of personal information the business has collected about you.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.

Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:

  • Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between Polaroid and you.
  • Help to ensure security and integrity to the extent the use of the consumer's PI is reasonably necessary and proportionate for those purposes.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  • Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when Polaroid's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Polaroid and compatible with the context in which the consumer provided the information.
  • Comply with a legal obligation.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.

Right to Request Correction. You have the right to request that Polaroid correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.

Authorized Agent.You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this CCPA Section. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Questions. If you have questions about this CCPA Section, please contact us as described above in the Policy.

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