PLR IP HOLDINGS, LLC AND PLR ECOMMERCE, LLC
Updated as of December 20, 2019
- How do we collect information?
- How do we use your personal information?
- How do we disclose your personal information?
- Which analytics and interest-based advertising partners do we use?
- What choices do you have about your personal information?
- Do we recognize Do Not Track signals?
- Do we collect information from children?
- How long do we retain your personal information?
- How secure is my information?
- Links to third-party websites
- Notice to California Customers – Your California Privacy Rights
- International Users
- What about updates?
- Additional Information and How to Contact Us
What information do we collect?
We collect and receive a variety of types of information, such as:
- Contact information, such as your name, email address and postal address;
- Preference information, such as your contact and marketing preferences;
- Demographic information, such as your date of birth;
- User generated content, such as comments, reviews, photos, videos, from social media interactions;
- Correspondence information, including information about your email and other written communications with us, and the information that you share in those communications; and
- Automatically-collected information about your devices and online activities (“automatically collected information”), such as:
- Your location
- IP address
- Device type
- Browser type
- Operating system or platform
- Name of Internet Service Provider
- Referring website
- Exiting website
- Pages visited on our website
- Frequency, time, data, and duration of your visit on our website
- Whether you open emails from us
- Links you click on in our emails and on our website, including ads
- Whether you access our website from multiple devices
- Other interaction you may have on our website
- Device Unique Device Identifier (e.g., Unique Device Identifier (UDID) or International Mobile Equipment Identity (IMEI))
- Mobile device MAC or IP address,
- Information about your mobile device's operating system
- Information about your mobile carrier
How do we collect information?
We collect information on our website, through our ads, and through our email and other communications and interactions with you. We obtain information directly from you when you provide it to us and we also obtain information about you from third-party sources, including automatically collected information (discussed below) and information we receive from publicly available sources. We collect and obtain:
- User provided information: We collect information you provide to us when you sign up for our newsletter or mailing lists, sign up for contests and special promotions, fill out a survey, send us email, send us postal mail, engage in a business relationship with us, or speak with us on the telephone.
- Information from social media: When you interact with us over social media, we may collect information about you. If you post information or otherwise interact with us through social media websites, social media platform plug-ins, or other applications we use, we may collect or receive information that you provide or that is automatically collected by the social media platform. Information that you post on social media platforms may become public, depending on your account settings. Information collected by social media platforms when you interact with their services is governed by the social media platforms’ respective privacy policies. For more information about how you can customize your privacy settings and how third-party social media websites handle your personal information, please refer to their privacy policies. We have a presence on Facebook, Twitter, Instagram, YouTube, Snapchat, and Pinterest.
- Information from third parties: We receive personal information from: (a) third-party service providers that we use to perform business functions on our behalf (including, without limitation, web hosts, email service providers, analytics companies and advertising networks); (b) marketing affiliates that we work with to develop and encourage relationships with consumers interested in Polaroid products; (c) brand licensees with whom we have a relationship in which they may, depending on the relationship, develop, manufacture, market, and/or sell Polaroid products; and (d) other third-party partners we work with to supplement or enhance our information. We also may collect information from publicly available sources. For information on the third-party partners with which we work, please click here.
- Information collected using automated collection methods / cookies: When you use our website, read our emails, interact with our ads and other online content, interact with us on social media platforms, or otherwise engage with us through a computer or mobile device, we and our third-party partners collect automatically collected information. This information typically is collected through a variety of technologies, including cookies, web beacons, location-identifying technologies, social media widgets, and similar technologies (collectively, “automated collection methods”). Automated collection methods we and our third-party partners use include:
- Web beacons or tags, which are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our website, or open an email we send to you;
- Website log files, which we or our service providers create automatically when you access and use our website; and
- Flash cookies, also known as locally shared objects, which are able to handle more complex information than a browser cookie and are able to pass information across the different browser types you may have installed on your device. To learn more about flash cookies, click here; and
How do we use your personal information?
The following is a description of how we use the personal information we collect and receive from other sources. Automatically collected information and other personal information may be combined with other information that we collect directly from you or that we receive from other sources and used for the purposes described below.
- To provide services to you.
- To provide the website and its functionalities to you.
- To provide services requested by you. For example, if you sign up for our newsletter, we will use the information you give us to send you our newsletter.
- To respond to your requests. If you contact us with a question or a request, we will use your information to respond to your request. For example, if you contact us via email with a question, we will use the information in that email and the email address you used to contact us to respond to you.
- To provide you with location-specific services. If you elect to share your location information with us, we may use that information to tailor options, functionality or offers related to your location. We also may use your IP address to determine your general location, which also may be used to tailor offers to you.
- To offer and conduct promotions and contests.
To conduct data analytics to support our website and business
Typically, these analyses are done using of aggregated or otherwise de-identified data. We use information, including automatically-collected information collected using automated collection methods, to manage and improve our website and our business. For example, we use such information to:
- Manage our business needs, such as monitoring, analyzing, and improving the services and the website’s performance and functionality. For example, we analyze website user behavior and conduct research and analysis about the way you and other users use our website.
- Manage risk and protect the website. We use data to better protect our services, our website, and you by helping to detect and prevent fraud and abuse of the website and our services.
- Tailor ads to your apparent interests. For more information about interest-based advertising, review the “Which analytics and interest-based advertising partners do we use?” section below.
- Develop new products, services and offers.
For other purposes
- To operate and improve our business.
- To maintain our records.
- To market to you. Information we collect about you and how you use and interact with the website and our services, ads, and other online content helps us to improve our website and offer additional products and services that we think might interest you. For example, we analyze information about user interactions with our marketing emails and online ads (such as whether emails have been opened or whether ads are clicked on) to determine whether those communications and ads are effective, and to understand what other website functionalities, products or services may interest you.
- For legal, contractual and safety purposes. We will use your information as necessary to enforce the terms of our website, to comply with all applicable laws and regulations, to defend or protect us, our users, you, or third parties from harm or in legal proceedings, to protect our rights, to protect our security and the security of our users, employees, and property, to respond to court orders, lawsuits, subpoenas, and government requests, to address legal and regulatory compliance, to verify your identity or communications from you, to comply with contracts and other agreements to which we are a party, and to notify you of changes to our terms, policies, or practices.
- To conduct internal monitoring and training.
- To meet our contractual obligations with you when we engage in a business relationship with you.
- For other purposes for which you provide your consent. For other purposes which are disclosed to you at the time your information is collected or for purposes which can be inferred from or are obvious given the circumstances of collection. For example, if you give us your personal information when entering a contest we will use that information to facilitate your participation in that contest.
How do we disclose your personal information?
We do not share your personal information with third parties except in the circumstances described below.
- Our Third-Party Partners. We may share your information with the categories of third parties listed below:
- Third-Party Service Providers. We may share personal information with third parties who provide business services to us or on our behalf. For more information about third-party service providers we work with, click here.
- Brand Partners. We may share your personal information with our brand partners, typically, our brand licensees. These third parties operate as separate controllers, and are responsible for their own compliance with data protection laws. For more information about brand partners with whom we may share your personal information, and information about their practices, click here.
- Marketing Affiliates. We may share personal information with retailers with which we have marketing affiliate relationships. These relationships involve linking or referring our website users to our marketing affiliates’ websites so that users can make purchases directly from those third-party marketing affiliates. As an Amazon Associate, we earn from qualifying purchases. As a marketing affiliate of Target, Bestbuy, and iTunes we earn from qualifying purchases. For more information about third parties with whom we have marketing affiliate relationships, including information about their practices, click here.
- Promotional Partners. From time to time we may send offers for products and services that may be of interest to selected groups of Polaroid.com users on behalf of third-party promotional partners. When we do this, we generally do not give those third-party promotional partners your personal information. However, in some circumstances we may do so. For example, occasionally, we may run a contest, sweepstakes, or other special officer in conjunction with a retail or brand partner or a social media influencer and we may share personal information such as your email address as part of that offer. Where such sharing information will occur, we will notify you in the terms and conditions relating to the offer.
- Legal Protection. It may become necessary for us to release personal information to law enforcement, government entities, courts, government regulators, our legal advisors, or other third parties as required or allowed by applicable law if we believe the release is necessary or required for us to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request; (ii) enforce our Terms and Conditions or other policies, contracts or agreements; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect the rights, property or safety of Polaroid.com, our owners, service providers, licensees, users or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Which analytics and interest-based advertising partners do we use?
We work with a number of other third-party partners to collect information in order to provide tailored services, ads, and product offerings to you. For more information about our analytics and third-party ad partners, and information about their practices, click here.
What choices do you have about your personal information?
We offer certain choices about how we communicate with you, what personal information we collect and obtain about you, and what information we share with others:
- Information You Give Us
You have the right not to provide us with certain information, such as your name, email address and postal address. However, that may limit your ability to fully utilize the benefits of Polaroid.com or participate in other services or offers. For example, without your contact information we cannot provide you certain information (such as our newsletter) or facilitate your participation in certain contests or offers.
- Interest-Based Advertising
In addition to using the management tools described in the “Which analytics and interest-based advertising partners do we use?” section above, you can manage third-party advertising preferences for some of the third-party partners we work with to serve advertising across the Internet by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices. For more information about our third-party ad partners, and information about their practices, click here.
For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies or to share your advertising ID with third parties. For some information on controlling your mobile choices, click here. To help control or block certain ads in mobile applications you may choose to download and utilize the Digital Advertising Alliance’s mobile app by clicking here. We do not guarantee that all of the third parties we work with will honor the elections you make using any of these options.
- Email Choices
You may unsubscribe from our newsletter or from marketing emails from us by clicking the ”Unsubscribe” link at the bottom of any newsletter or marketing email from us, as applicable, or by submitting an email request here. Please note that opting out of receiving marketing emails or our newsletter will not prevent us from sending you administrative communications or legal notices, for example, emails about changes to our terms, policies or business practices.
- Managing Cookies
You can learn more about cookies and manage your cookie preferences for Polaroid.com at any time here. For additional information about managing cookies, please visit www.allaboutcookies.org. For browser-specific information on how to adjust cookie configurations on the following browsers, please click on the relevant link below:
Please keep in mind, that we use browser cookies to, among other things, improve the functionality of the website and to enhance your experience on Polaroid.com. Therefore, changing your cookie preferences on Polaroid.com or your browser or device settings to refuse, disable or delete cookies may impact your use of some of the features or services on our website as they may not function properly without cookies.
Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set, in which case you would have to revisit the applicable pages and renew your opt-out after clearing cookies. Please also keep in mind that browser cookie management tools will not remove flash cookies or prevent other automatic collection methods from functioning.
- Mobile Devices Your mobile device may offer settings relating to cookies, pixel tags, and other automated collection methods. We encourage to you to visit your device’s help menu to learn about your options to limit tracking when using your device.
- Social Media Platforms and Networks We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
Do we recognize Do Not Track signals?
Do we collect information from children?
Our website is not directed to or intended to be used by children under 16 years of age. No one under the age of 16 is authorized to provide any personal information to or on the website, and we do not knowingly request or collect personal information from any individual under 16 years of age. If you are under 16 years of age, do not use this website, sign up for our newsletter, or provide any information about yourself to us, including without limitation your name, email address, postal address or location. If you are a parent or guardian and believe that your child under the age of 16 has submitted personal information to us in connection with the website or otherwise, please email us at firstname.lastname@example.org so that we can take steps to delete the personal information as required in accordance with applicable law.
How long do we retain your personal information?
How secure is my information?
Polaroid has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, unauthorized access, alteration, or destruction. Although we take reasonable steps to safeguard personal information, no practices are 100% secure, and we do not guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. You must protect against unauthorized access to your computer and important information. We strongly recommend that you log off each time you finish using a shared computer.
Links to third-party websites
Notice to California Customers – Your California Privacy Rights
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any.
To make such a request, send an email with the subject heading “California Privacy Rights” to email@example.com or write to us by post at: PLR IP Holdings, LLC, Attn: Legal Department/California Privacy Rights, 4350 Baker Road, Suite 180, Minnetonka, Minnesota 55343. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Pursuant to applicable California law, including the California Consumer Privacy Act (CCPA), Polaroid makes the following disclosures regarding the personal information it collects:
|Category of Personal Information||Category of Source from Which Data is Collected||Purpose of Collection||Category of Third Parties to Whom Data is Disclosed|
|Contact information, such as your name, email address and postal address||Directly from user||To provide services to you; to provide the website and its functionalities to you; to provide services requested by you; to respond to your requests; to market to you||Service Providers|
|Preference information, such as your contact and marketing preferences;||Directly from user||To market to you; to tailor ads to your apparent interests.||Service Providers|
|Demographic information, such as your date of birth||Directly from user; Cookies and other tracking technologies||To market to you; to tailor ads to your apparent interests.||Service Providers|
|Location data||Social media; Directly from user; Cookies and other tracking technologies||To market to you; to tailor ads to your apparent interests.||Service Providers|
|User generated content, such as comments, reviews, photos, videos, from social media interactions;||Social media; Directly from user; Cookies and other tracking technologies||To market to you; to tailor ads to your apparent interests.||Service Providers|
|Correspondence information, including information about your email and other written communications with us, and the information that you share in those communications||Directly from user||To provide services to you; to provide services requested by you; to respond to your requests||Service Providers|
|Automatically-collected information, such as your location; IP address; device type; browser type; operating system or platform; name of Internet Service Provider; referring website; exiting website; pages visited on our website; frequency, time, data, and duration of your visit on our website; whether you open emails from us; links you click on in our emails and on our website, including ads; whether you access our website from multiple devices; other interaction you may have on our website; Device Unique Device Identifier (e.g., Unique Device Identifier (UDID) or International Mobile Equipment Identity (IMEI)); mobile device MAC or IP address; information about your mobile device's operating system; information about your mobile carrier||Cookies and other tracking technologies||To conduct data analytics to support our website and business; manage our business needs, such as monitoring, analyzing, and improving the services and the website’s performance and functionality||Service Providers|
If you are a California resident, pursuant to the California Consumer Protection Act (CCPA), you have the right to request:
- the categories of personal information Polaroid has collected about you;
- the categories of sources from which your personal information is collected;
- the business or commercial purpose of collecting or selling your personal information;
- the categories of third parties with whom Polaroid shares your personal information;
- the specific pieces of personal information Polaroid has collected about you;
- the categories of personal information that Polaroid has sold about you and the categories of third parties to whom the personal information was sold, if applicable;
- deletion of your personal information; and
- an opt out of having your personal information disclosed or sold to third parties.
To submit a request, or designate an authorized agent to make a request under the CCPA on your behalf, please contact us at firstname.lastname@example.org. To verify your identity when you submit a request, Polaroid will match the identifying information you provide us to the personal information we have about you.
Polaroid will not be required to comply with your request to delete your personal information if it is necessary for Polaroid to maintain your personal information in order to:
- complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of Polaroid’s ongoing business relationship with you, or otherwise perform a contract between you and Polaroid;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- 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 in the public interest that 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 achievement of 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 the Polaroid;
- comply with a legal obligation; or
- otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Polaroid will not discriminate against you in the event you exercise any of the aforementioned rights under CCPA, including, but not limited to, by:
- denying goods or services to you;
- charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- providing a different level or quality of goods or services to you; or
- suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Controllers of Personal Data
PLR Ecommerce, LLC, of 4350 Baker Road, Suite 180, Minnetonka, Minnesota 55343, and PLR IP Holdings, LLC, of 4350 Baker Road, Suite 180, Minnetonka, Minnesota 55343, are the data controllers of the personal data processed through the website.
Legal Bases for Processing Personal Data
If you are an individual located in the European Union (EU), we collect and process personal data about you where we have a legal basis for doing so under applicable EU laws. This means we collect and process your data only when:
- It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving our website, and increasing the security of the website and network infrastructure;
- You have consented to the collection and processing for a specific purpose, such as providing our newsletter to you, or sharing your information with third parties when we offer promotions jointly with those third parties (any consent you provide will be entirely voluntary and may be withdrawn at any time);
- It is necessary to fulfil our contractual obligations; or
- It is necessary to comply with a legal obligation.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Some examples of where we rely on your consent to process your personal data include sending you our newsletter and marketing emails. Any consent you provide will be entirely voluntary and may be withdrawn at any time. If you wish to withdraw your consent, please contact us at email@example.com.
- Some examples of our legitimate interests and the personal data being processed include:Website and network security (IP address)
- Customer support (email address, social media handle)
- Improving our website (hardware information, activity logs)
Where we rely on our legitimate interests to process your personal data, you may have the right to object. More information on exercising this right can be found in the Individual Rights section below. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at firstname.lastname@example.org.
If you are located in the EU, you may make a request for access to your personal information that we have about you by sending an email to us, calling us, or writing to us at the address specified in the “Additional Information and Contacting Us” section below. We are not able to grant all access requests and we may request additional information from you in order to verify your identity before accommodating an access request.
If you are located in the EU, you have certain rights under EU data protection law with respect to your personal data, including the right to request access to, correct, and delete your personal data. You may also have the right to receive a copy of your personal data in a commonly used and machine-readable format, and to transmit such data to another controller. You also may object to processing of your personal data or ask that we restrict the processing of your personal data in certain instances. To request deletion of, access to, or to make changes to your personal data, or to otherwise exercise any of the rights in this paragraph, please email us at email@example.com and specify the nature of your request. Additional information may be requested from you to verify your identity and/or to determine whether and how we can process your request. If you delete or limit the use of your personal data, or if you transmit your personal data to another controller, you may not be able to use all of our website’s functionalities or services.
Transfers, Storage, and Processing - Important Information for Users Outside the U.S.
Our website is operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States or any other jurisdiction in our sole discretion. Users of our website should be aware that the laws that apply to the use and protection of personal data in the United States or other countries or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our website from jurisdictions outside of the United States do so at their own choice and risk and are solely responsible for compliance with local law. While we take steps to safeguard your personal data, the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal data. Accordingly, the level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our website may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.
What about updates?
Additional Information and How to Contact Us
PLR Ecommerce, LLC
4350 Baker Road, Suite 180
Minnetonka, Minnesota 55343
4823-6324-8814, v. 1