Legal & Privacy

CCPA Privacy Notice

[Last Updated: May 2026]

‍Applicability: The California Consumer Privacy Act of 2018, as revised by the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”) (collectively “CCPA”), any other California privacy laws, and this CCPA privacy notice (“CCPA Notice”) apply to Prospects, user of the Expert Hub, Photographers, and End Users and Guests who are California residents (“consumers” or “you”) and Pic-Time processes its Personal Information directly or indirectly while using our Platform, website, or Service or in order to provide our Services. Any term defined in the CCPA has the same meaning when used in this CCPA Notice. Further, when and if applicable the CCPA Notice will also disclose the use of employee Personal Information and business-to-business Personal Information.

This CCPA Notice is an integral part of our Privacy Policy, and thus, definitions used herein shall have the same meaning as defined in the Privacy Policy. When we refer to “Personal Data” under our Privacy Policy, it shall also mean “Personal Information” as defined under the CCPA.

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PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

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(A) CATEGORIES OF PERSONAL INFORMATION WE COLLECT

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We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, all as detailed in the table below.

Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below.

Personal Information 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 CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We have collected and share the following categories of Personal Information within the last twelve (12) months as a “business”, the photos, images, videos, and facial recognition information are processed and stored by us as a “service provider” and therefore are not disclosed in the table below, for more information see our Privacy Policy. Below we detail the categories of Personal Information that we collect, share for a business purpose and the categories of recipients to whom we disclose (within the last 12 months):

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Categories of Personal Information Examples of Personal Information Categories of Personal Information we collect Categories of third-party recipients to whom we disclose Personal Information for Business Purpose
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Yes: real name, unique personal identifier, online identifier, IP address, email address. Cloud computing and storage vendors. Service Providers (storage, hosting, labs, operators, vendors, etc.) process to provide the services to Pic-Time. Government and Authorities due to Law Enforcement, Subject to a law request, such as tax and social security authorities. Security vendors, for debugging, security, fraud prevention. Improving the Services, development, and optimization, and providing certain services such as printing the photos via third-party photo lab. Customer and technical support. Recruitment and HR services.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes: name, telephone number, address, email address.
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). No.
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes: transactions conducted; however, not credit card number. Cloud computing and storage vendors. Service Providers (storage, hosting, labs, operators, vendors, etc.) process to provide the services to Pic-Time. Government and Authorities due to Law Enforcement, Subject to a law request, such as tax and social security authorities. Security vendors, for debugging, security, fraud prevention.
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes: information on a customer’s interaction with our website, Platform, and Services. Cloud computing and storage vendors. Service Providers (storage, hosting, labs, operators, vendors, etc.) process to provide the services to Pic-Time. Government and Authorities due to Law Enforcement, Subject to a law request, such as tax and social security authorities. Security vendors, for debugging, security, fraud prevention. Improving the Services, development, and optimization, and providing certain services such as printing the photos via third-party photo lab. Data analysis providers- Providing analytic data on the use of our website, Platform, and Services. We limit the providers' ability to share such information, as detailed above. Marketing providers and social networks- which is not cross-contextual, ad delivery.
G. Geolocation data. Physical location or movements. Yes: approximate geolocation, addresses, however, not movement.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No [this data is processed by Pic-Time as a Service Provider and is governed by the Data Processing Agreement and not this notice]
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes: all the information under this category.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No.
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes: from the photos and videos we will be able to infer gender, however, we do not use this information. Data analysis providers- Providing analytic data on the use of our website, Platform, and Services. We limit the providers' ability to share such information, as detailed above. Marketing providers and social networks- which is not cross-contextual, ad delivery. Improving the Services, development, and optimization, and providing certain services such as printing the photos via third-party photo lab.
L. Sensitive personal information. Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life. No.

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(B) CATEGORIES OF SOURCES OF PERSONAL INFORMATION

  • Directly and indirectly from activity on our website and Platform: For example, directly from you when you inquire about our Services via our website, or indirectly, when we collect your usage data or browsing data automatically from measurement tools.
  • Directly from you: For example, from forms you complete (such as the Data Subject Request), contact us, register for free trial, etc.
  • From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers. Further, our Photographers may provide us with their Clients’ photographs, videos and images, and contact information.  

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(C) USE OF PERSONAL INFORMATION

We may use the Personal Information collected as identified above, for the following purposes: To fulfill or meet the reason you provided the Personal Information (support, respond to a query; monitor and improve our services; analyze which types of ads should be provided as part of the services; provide the services; marketing our services; analyzing our services and your use of the services and website; respond to law enforcement; or otherwise as detailed in our Privacy Policy.

We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

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(D) SALE OR SHARE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  

For retargeting and analytic purposes, when we promote our Services, we use third-party tools that are able to market our Services online (“Campaigns”), measure those Campaigns, identify individuals who are interested in our Services, etc. this is done by placing cookies, pixel or other tracking technology on our website and sharing with these vendors the online identifiers and online behavior information.  The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help promote our services and understand your use of our website.  

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

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Category (corresponding with the table above) Category Recipient Purpose of Sale or Share
Category A
Category F
Category G		 Marketing tools and vendors. Targeted advertising, cross-contextual behavioral advertising (“CCBA”), promoting the Services, analytics and security services.

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For more information about the types of cookies used, please refer to the Cookie Declaration: https://www.pic-time.com/legal/cookie-declaration.

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(E) CHILDREN UNDER AGE 16

We do not knowingly collect information from children under the age of 16. However, the photos, videos, and other Content stored by End Users, Authorized Users or Photographers on our Platform could include children’s photos, family photos, etc. We do not use this information.  

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(F) DATA RETENTION

The retention periods are determined according to the following criteria:

  1. For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example: if you contact us, we will retain your contact information for at least until we address your inquiry.
  2. To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
  3. To resolve a claim, we might have a dispute with you, including any legal proceeding between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

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EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM

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(G) YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and in the Data Subject Request Form available HERE.

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California Privacy Right Details
The right to know what Personal Information the business has collected. The right to know what Personal Information the business has collected about the consumer, including 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, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.
Deletion Rights. The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.
Correct Inaccurate Information. The right to correct inaccurate Personal Information that a business maintains about a consumer
Rights related to Sharing for Targeted Advertising and Sale of Personal Information You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising”, often referred to as “interest-based advertising” or “targeted advertising” and the sale of your Personal Information.
Limit the Use or Disclosure of SPI. Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.
Opt-Out of the Use of Automated Decision Making. In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
Non-Discrimination. The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
Data Portability. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

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To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

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(H) HOW CAN YOU EXERCISE THE RIGHTS?

We provide the option to opt-out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:

  • You can opt-out from cookies using our cookies setting tool, where you can further change your preferences at any time. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations.  If you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings or our cookie consent management (“CMP”). For more information about the types of cookies used, please refer to the Cookie Declaration: https://www.pic-time.com/legal/cookie-declaration.
  • California resident and wish to opt-out from having your data used for interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.
  • We honor Global Privacy Control (“GPC”) signals as a valid request to opt-out of the "sale" or "sharing" of your personal information. We process these signals in a frictionless manner without fees or changes to your user experience. To learn how to enable GPC, visit https://globalprivacycontrol.org/

You may exercise by using the Data Subject Request Form available HERE. The instructions for submitting, the general description of the process, and verification requirements, when applicable, including any information the consumer or employee must provide, are all detailed in the DSR Form available HERE, and send it to our privacy team at: dpo@pic-time.com.  

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(I) AUTHORIZED AGENTS

You can designate an authorized agent to submit requests on your behalf via the methods above. However, we will require written proof of the agent’s permission to do so and verify your identity directly. We will not verify your identity if the agent provides the power of attorney documentation.

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(J). NOTICE OF FINANCIAL INCENTIVE

We may, at times, offer you various financial incentives such as promo codes, discounts and special offers when you register with our newsletter by providing us with contact information and identifiers such as your name and email address. When you sign up for our newsletter, email list or other discounts and special offers, you opt for a financial incentive. You may withdraw from a financial incentive at any time by opting out from our newsletter through the unsubscribed link within the email. Generally, we do not assign monetary or other value to Personal Information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the Personal Information is related to the estimated cost of providing the associated financial incentive(s) for which the information was collected. You can end program participation at any time by contacting us at: dpo@pic-time.com to unsubscribe or cancel your participation in any special offer. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

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(K) RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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(L) CONTACT US:

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(M) UPDATES:

As required under the CCPA, we will update the CCPA Notice every 12 months, if needed. The last revision date will be reflected in the “Last Update” heading at the top of this CCPA Notice.

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OTHER CALIFORNIA OBLIGATIONS

Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding the disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form available HERE.

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Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.