PRIVACY POLICY

[Last updated: 24 May 2018]

DLVR PHOTOS LTD. (“dlvr. photos”, “we” or “us”) is committed to safeguarding any personal information that may be collected through our website (“Site”) and Service. This privacy policy (“Privacy Policy”) describes our practices of processing data from our clients and partners (“Photographer”) once they register to open up a gallery (“Gallery”), online store (“Store”), use our marketing services and platforms, as well as visitors to the Site or visitors of a Gallery or Store (all, collectively the “Service”).  This privacy policy is an integral part of Terms of Service which govern your use as the Site or Service (collectively the “Agreement”).

We have included below information about which data is collected, how we process and use your data, but before, we would like to explain the basis on which we do so:

• Where you sign up for any of our services, we process your personal data in order to perform our contract with you;
• If we have a legitimate interest in processing data, such as for direct marketing or online identifiers when you access our Site; or
• We will also process your personal data where you have provided us with consent to do so.

1. What Information We Collect and How We Collect It

Depending on your interaction with us (meaning, if you are just browsing our Site, or if you have registered to our Services and opened an account, etc.), we may collect two types of information you, as follows:

• Non-Personal Data: The first type of information is non-identifiable information which may be made available or gathered through your use of the Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Information”). The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted or automatically (but not limited to): the time and date you access our Site or a Gallery (e.g., pictures used, pages viewed, etc.) and approximate geo-location. 

• Personal Data: The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either: (i) contact information such as your name, email address, etc., which you have submitted voluntarily; or (ii) your Internet Protocol (“IP”) addresses (the addresses of computers on the Internet). Note that, while IP is considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information. Therefore, we treat such information as Personal Information, in accordance with applicable laws. The IP is collected by our third party analytic partners that offer ways to opt-out, all as detailed below.

You are not required by law to provide us with any information. You can always avoid from providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services. For example, if you are a Business Partner, we will not be able to provide you with access to the Platform if you do not provide us with the information required through the registration process.

In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

Information we collect from visitors of our Site or a Gallery:

Information We Collect from Photographer

2. How we Collect Information

Depending on the nature of your interaction with the Services, we may collect information as follows:

• Automatically – we may use Cookies (as elaborated in the Section below) to gather some information automatically.
• Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a registration process, newsletter registration, contact us communications, etc.

3. Disclosure of Information

Although we make every effort to preserve user privacy, we may need to disclose Personal Information when required to do so by law or when necessary to comply with a current judicial proceeding, a court order or legal process served on our Site, or when we believe in good faith that disclosure of information is necessary to prevent imminent physical harm or to report suspected illegal activity. We may also disclose your personal data to enforce our policies or respond to claims that a listing or other content violates the right of others. In all cases, such information will be disclosed in accordance with applicable laws and regulations. We may also share your information with:

• Other companies or business entities, in the event we are merged with or acquired by such company or business entity.
• A third party performing services on our behalf and has agreed to keep such information confidential (such as the processing of your credit card payment if applicable or the conduct of an online survey, for example.)

4. Securing the Information

We take reasonable technical and organizational measures to guard against unauthorized or unlawful processing of the information collected and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by our site reduce the likelihood of security problems to a level appropriate to the type of data involved. For more information on our technical organizational security measures please see: www.dlvr.photos#security.

5. Information You Share

Our services let you share information (including photos which are uploaded to our Site) with others. Remember that when you share information with another person, that person can then share that information with others. For example, when you give permission to another person to view your photos, that person is then able to print your photos and, also, to share them with others.

6. Cookies

We may make use of 'cookies' on our website. A cookie is a small text file that can be placed and stored on your computer's hard disc when you visit a website for record keeping purposes. A cookie itself is not designed or intended to read any information from a user's computer (other than the contents of the cookie); rather, it is an identifier used by the website that originally placed it on your hard drive. The actual contents of the cookie information can be retrieved by the same server to identify the computer and subsequently to customize, monitor, or regulate the use of a site based on information stored on the host server. Therefore, cookies only identify the user's computer to the website which may correlate other information, including personally identifying information, with the cookie. We use cookies to allow us to automate access and the data entry functions of our website such as to correlate online ordering information for purchases you may make while at the website (if any), tailor our website to your preferences or interests, or customize promotions or marketing. In addition, cookies allow us to track use of our Site to determine those areas which are useful or popular and those that are not thereby enabling us to improve and update our Site effectively. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you are not sure how to do this or whether you have this option you should consult the documentation that accompanied your web browser. You should be aware that if you elect not to accept cookies, some parts of our site may not function properly or permit access.

We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Site, such as:

• Google Analytics this cookie is placed in order to track and analyze the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google’s policies located at:link. We also encourage you to review the Google Analytics’ currently available opt-outs for the web tool available at:  link.

7. Links

We may offer links from our website to other websites which may be hosted by our partners or by unrelated companies which we think may be of interest to you. Such websites are not governed by this privacy policy and we make no representation as to their practices for dealing with your personal information. We recommend that you check the privacy policy of any website at the beginning of your visit.

8. Children

 You represent and warrant that, (i) if you are located in the US, you are at least 13 years of age; or if you are located in any other GEO, you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children.  If we obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete such user’s Personal Information. If you become aware or have any reason to believe that a Child has shared any information with us, please contact us at: support@dlvr.photos. 

9. User Right and Choice

You can access and modify your account information by going into your account settings or clicking on your name in the Gallery as well as make any changes to any consent that you may have given in respect of us contacting you relating to information that you receive from us. You may also ask at any time that your preferences as to the type of communications that you receive from us are modified in order to stop receiving them or to be added to our mailing list. You can also do this by following the instructions included in each communication or newsletter.

Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.

The principal rights under applicable data protection law in relation to Personal Information are as follows:

• the right to access any information which is provided to us;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent (to the extent applicable).

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. If you wish to exercise your rights you can do it through the account as detailed above or by contacting us as support@dlvr.photos.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

10. Retention and Storage of the Information We Collect

We will retain your information for a reasonable time to permit us to use it for the purposes that we have communicated to you. We may use the services of third party companies to physically collect and store your information on our behalf. Any such companies will have to comply with the terms of this policy.

11. Changes to this Privacy Policy

We may change the terms of this privacy policy from time to time without notice in order to reflect our practices and provide greater protection for your information. Information collected by us will be dealt with in accordance with the provisions of our policy which were in effect at the time of collection. If we change this privacy policy, we will change the “last updated” date at the top of the page.

12. Data Transfer

We may store or process your Personal Information in the United States or in other countries. Please note that any information you provide to us through your use of our Site or Service may be transferred to and processed in countries other than the country from which you accessed our Site or Service, including the United States. If you are a resident of the European Economic Area ('EEA') we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

13. Contacting Us

Any requests for access to your information, modification of your information or questions in respect of this policy should be sent to the following email address: support@dlvr.photos

505 14^th st

STE 900

Oakland, CA 94612

USA

DATA PROTECTION OFFICER:

If you have any requests regarding the data collected under this policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at:

legal@dlvr.photos.  dpo@dlvr.photos.

Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.