Paparazme, LLC DBA Shotzy (“Shotzy” or often “we”) offers a photography services marketplace platform (“Shotzy platform”) through which a client can access a global network of photographers who can provide photography services.
Shotzy recognizes that, as technology increasingly facilitates the circulation and exchange of information, there is a need for protocols to govern the Collection, Utilization and Sharing of personal information in a manner that recognizes the rights of individuals to manage their information and the needs of businesses to Collect, Utilize and Share information for purposes that a reasonable person would consider appropriate under the circumstances.
BY VISITING A SHOTZY PORTAL OR USING ANY SHOTZY PLATFORM OR ANY SHOTZY-FACILITATED PHOTOGRAPHY SERVICES, YOU CONSENT TO SHOTZY AND THIRD PERSONS COLLECTING, UTILIZING AND/OR SHARING INFORMATION ABOUT YOU, INCLUDING YOUR PERSONALLY IDENTIFIABLE INFORMATION (OR PII), AS PROVIDED IN THIS POLICY. SHOTZY WILL NOT UTILIZE OR SHARE PII THAT WE COLLECT, OTHER THAN AS PROVIDED IN THIS POLICY. YOU SHOULD NOT PROVIDE TO SHOTZY ANY PII, UNLESS YOU ARE WILLING FOR SHOTZY TO UTILIZE AND/OR SHARE THE PII AS PERMITTED BY THIS POLICY.
Principle 2. Committing to Recognition, Openness and Accountability. Shotzy recognizes the importance to you of your Information and in particular of your PII. Shotzy will be open about our practices with respect to management of Information that we Collect, starting with this Policy. You may obtain generally understandable knowledge about this Policy and Shotzy’s implementation practices by contacting Shotzy’s Privacy Manager either via email at firstname.lastname@example.org or via traditional mail at 291 Alberta Drive, Atlanta, GA 30305 USA. Shotzy’s Privacy Manager is responsible for understanding what sort of Information Shotzy Collects and how Shotzy Utilizes and Shares the Information. The Privacy Manager is also accountable for Shotzy’s compliance with this Policy.
Principle 3. Identifying Sources of Information that We Collect. Shotzy Collects both Non-Personal Information and Personally Identifiable Information from a variety of sources, including for example:
- we may automatically Collect Information, including possibly PII, from Visitors to a Shotzy Portal and Users of any Shotzy Platform Services or Shotzy-facilitated Photograpy Services
- we may also Collect additional Information, including PII, from any Person who registers as a Client or as a Photographer, particularly in the case of photographers while verifying their credentials
- we may Collect Information from any Person who Uses the Shotzy Platform or any Shotzy-facilitated Photography Services, both automatically and through interactions such as scheduling and conducting photography, reviews of Photographers and services, surveys, electronic and voice communications and other exchanges of data or information by, through or for provision or receipt of any such services
- Clients and/or Photographers may voluntarily provide Shotzy with Information about themselves or other Persons, including possibly PII of any of them
- we may Collect Information about Users, including PII, from third Persons, such as for example credit or payment services or other providers to us of third party services
- we may also Collect Information from organizations who register as Clients or Photographers to enable their existing clients or photographers, employees, members or other personnel to Use the Shotzy Platform or Shotzy-facilitated Photography Services (including their PII)
Shotzy also may generate Non-personal Information from the PII that we Collect (such as anonymous, aggregate statistical Information), though we will take reasonable measures to ensure that the Non-personal Information is not personally identifiable and cannot later be reasonably associated with, linked to or otherwise Utilized to identify the source individual (including for example storing the Non-personal Information and PII separately). Though we will not thereafter attempt to make any such Non-personal Information personally identifiable, we may enhance Non-personal Information with other Non-personal Information that we Collect.
Principle 4. Identifying PII Collected and How We Utilize and Share It. Some of the specific types of Personally Identifiable Information that we may Collect include the following:
- name, age, gender and occupation
- domain name, internet protocol address, browser type and logon credentials
- unique device identifiers and mobile network information
- email address and/or social media contact details
- mailing address, country and postal code
- social security or federal employment identification numbers for US Photographers and Clients for reporting payments and/or receipts to the Internal Revenue Service (and possibly equivalent information for Photographers and/or Clients located elsewhere)
- voice communication contact details
- payment protocol information, including account details
- geographic location, including possibly precise physical location
- unique session numbers for Photography sessions and some Uses of the Shotzy Platform and Shotzy-facilitated Photography Services
- statistics reflecting Visits to the Shotzy Portals and Use of Shotzy Platform and Shotzy-facilitated photography Services, including payments and receipts therefor and other characteristics thereof
- Information that you may provide voluntarily when Visiting a Shotzy Portal or Using either the Shotzy Platform or Shotzy-facilitated Photography Services or during your participation in a photography session Shotzy may Utilize the Personally Identifiable Information that Shotzy Collects in accordance with this Policy for a variety of purposes, including for example:
- providing the Shotzy Platform and facilitating the provision of Photography Services (including semi-public profiles of Photographers available to Clients on the Shotzy Portal, which will include the Photographer’s photograph and Clients’ reviews of the Photography Services provided)
- identifying, engaging and communicating with individuals who are or may be photographers or in need of photography services (including facilitating Photography Services and/or arrangements between Clients and Photographers)
- providing notices regarding the scheduling and conduct of Photography sessions and other Shotzy Platform Services and Shotzy-facilitated Photography Services
- interacting with Clients and Photographers to arrange for and carry-out receipts and payments and other administrative details for, related to or as a result of Photography sessions or other Shotzy Platform Services or Shotzy-facilitated Photography Services
- identifying and communicating with individuals interested in receiving information about the Shotzy Platform or any Shotzy-facilitated Photography Services
- hiring, employment and training purposes • operating, maintaining and improving the Shotzy Portals and the Shotzy Platform and possibly customizing the same for certain Users
- providing advertising through the Shotzy Portals, the Shotzy Platform and possibly through Shotzy-facilitated Photography Services
- analyzing data, patterns and other aspects of or regarding Photography sessions or other Uses of the Shotzy Platform or Shotzy-facilitated Photography Services
- developing additional products and services, including possibly products or services based on the forgoing analyses
- complying with governmental laws or regulations
- contacting Users for information verification and/or direct marketing purposes Shotzy may Share the Personally Identifiable Information that we Collect in the following ways:
- all PII disclosed or included in the Content of a Photography session will be available to other participants in the Photography session
- if you are registered as a Client or Photographer at the request of a third Person (such as your existing client or photographer or your employer, for example), then we can Share your PII with that third Person
- we sometimes obtain services related to a Shotzy Portal or the Shotzy Platform from third Person service providers, and we may Share your Information, including your PII, with those providers. Examples of these situations are: o web-hosting services or domain administrators o Collecting Information and maintaining and/or managing our databases o payment processing or related activities o providing other services to assist Shotzy in operating a Shotzy Portal or the Shotzy Platform or otherwise in conducting our business we require that these third Persons agree not to use any Information that we Share with them for any purpose other than fulfilling their obligation to Shotzy, and that they will otherwise handle such Information in accordance with this Policy
- we may engage or contract with advertising providers to target advertising and other content to you and possibly to provide you with offers that we think may interest you (based on your Use of a Shotzy Portal, the Shotzy Platform or any Shotzy-facilitated Photography Services). We may Share your Information, including your PII, with those providers. These advertisements and content may be delivered through a Shotzy Portal, the Shotzy Platform or Shotzy-facilitated Photography Services or via mail, delivery services, email or social media. These providers may also receive your Information, including your PII, when you click on their advertisements or other content (and your click is your consent for the transfer of the relevant Information)
- we may select third Persons to develop and offer to you products and services that Shotzy believes may be of interest to you (also based on your Use of a Shotzy Portal, the Shotzy Platform or any Shotzy- facilitated Photography Services). We may Share your Information, including your PII, with these third Persons
As a result, websites of third Persons may be accessible from a Shotzy Portal or the Shotzy Platform, and you may be requested to provide Information to those third Persons through their websites and services, including possibly your PII. Those third Persons maintain their own privacy policies. This Policy does not extend to the sites or actions of those third Persons and covers only Information that Shotzy Collects. SHOTZY IS NOT RESPONSIBLE FOR THE POLICIES OR PRACTICES OF ANY SUCH THIRD PERSON. WE RECOMMEND THAT YOU REVIEW THE PRIVACY POLICIES OF THOSE THIRD PERSONS BEFORE PROVIDING THEM WITH ANY OF YOUR INFORMATION.
Principle 5. Utilizing and Sharing Non-personal Information. We may Utilize or Share Non-personal Information that we Collect for any lawful purpose without any obligation to you, provided that this Information is not reasonably associated with or linked to you (or Utilized to identify you) and that this Information remains in a non-personally identifiable form. Shotzy directs the Shotzy Platform toward a general audience and not toward children under 13. Shotzy does not knowingly Collect any Information from children under 13 years of age, whether on a Shotzy Portal or through any Shotzy Platform or any Shotzyfacilitated Photography Services.
Principle 6. Explaining How to “Opt Out” and other Legal Matters. Shotzy offers you the opportunity to “opt-out” of receiving certain communications from Shotzy and/or of having Shotzy Share your PII with third Persons for certain purposes. You may elect to opt-out at any time at your discretion. While your decision to opt-out should not affect your ability to Visit the Shotzy Portals, it may affect your ability to use the Shotzy Platform and/or Shotzy-facilitated Photography Services, as some communications and PII Sharing are required for the Shotzy Platform to operate properly and/or to facilitate Photography Services. Accordingly, if you opt-out of these communications or of this PII Sharing, Shotzy may have to cancel your Use of the Shotzy Platform and/or of Shotzy facilitated Photography Services. It may take up to 30 days to complete implementation of your opt-out, during which period you will continue to receive communications from Shotzy and Shotzy will continue to Share your PII as permitted herein.
Note that you may have to contact our third Person service providers directly in order to opt-out of receiving communications or of having your PII Shared in relation to the services that we procure from them.
Irrespective of any “opt out” that you may elect, Shotzy may always Share any PII that Shotzy Collects, if, when and to the extent that Shotzy has a reasonable and good-faith belief that the Sharing is necessary to enforce any of Shotzy’s Agreements for the Shotzy Platform or Agreements to Provide Photography Services, to comply with a court order or other legal process, to avoid injury to any Person, to protect or enforce Shotzy’s intellectual property rights, or to enforce any other rights of Shotzy under this Policy or applicable law. If Shotzy takes any such action, then Shotzy will use reasonable efforts to notify you to the extent reasonably possible and permitted by law.
California law provides that California residents/individuals may request businesses to tell them how their PII has been Shared with third Persons for direct marketing purposes. But there is an exception for a business that has adopted and disclosed a policy of not disclosing an individual’s PII to third Persons for direct marketing purposes, if that individual has exercised an option to opt-out of such disclosure. As indicated above, Shotzy has adopted a policy of allowing you to opt-out of the disclosure of your PII to third Persons for direct marketing purposes. Accordingly, Shotzy qualifies for the exception.
Principle 7. Explaining How We Secure and Update Your Information. Shotzy will take reasonable actions to assure the security of your PII under our control, including at least industry standard measures to protect against loss, misuse or unintended alteration.
However, Shotzy relies upon you to update and correct your Information (including your PII) from time to time, as necessary or appropriate, though we will endeavor to take reasonable actions to assure that Information in our control is current, accurate and reliable for its intended use. You may contact our Privacy Manager as aforesaid to review or change any of your Information that we may have Collected.
Principle 8. Explaining Our Use of Automated Tracking Technology. Shotzy employs “cookies,” “web beacons” and other automated tracking technology to Collect Information regarding your Visits to Shotzy Portals and your Use of the Shotzy Platform and any Shotzy-facilitated Photography Services. Cookies are small files that are placed on a computer or mobile device to allow us to recognize the computer or device. Web beacons pass Information from your computer or device to us. The cookies, web beacons and other tracking technology that we employ may expire when you close your web browser or may remain on your computer until you delete them. Third Person service providers and advertisers that we engage or contract with may use similar technology. Your browser and email programs should include instructions about these functions and how to disable them if you choose (though the Shotzy Platform will likely not function properly, if you do).
Principle 9. Explaining Policy Versions and Ownership Transfer. From time to time, Shotzy may make changes, additions or deletions to this Policy to adapt to changing business conditions or for other reasons. These changes, additions or deletions may include materially greater Utilization and/or Sharing of your Information (including possibly your PII).
After the effective date of any such changes, additions or deletions, the new version of this Policy shall apply. Shotzy will notify you of changes, additions or deletions to this Policy via any form of communication that is reasonable under the circumstances, including email announcements on Shotzy Portals or through the Shotzy Photography services marketplace platform. Shotzy will wait 30 days after such notice before implementing any changes, additions or deletions that permit Shotzy more latitude in Utilizing or Sharing your PII. Shotzy will handle your PII in accordance with the version of this Policy that was in effect when we Collected the PII, unless we obtain your consent otherwise.
If Shotzy transfers to a third Person ownership or control of a Shotzy Portal and/or the Shotzy Platform (directly or indirectly), then Shotzy may transfer your Information (including your PII) to the third Person, provided that the third Person’s Utilization and Sharing of such Information will continue to be governed by this Policy. Your consent to this Policy is your consent to such a transfer.
Principle 10. Explaining the Defined Terms Used in this Policy. This Policy uses the following terms, which warrant definition:
- “Client” is any Person who signs-up for or applies to Use the Shotzy Platform or who initiates or attempts to initiate, directs the initiation of, pays for or benefits from any Shotzy Platform Service. If an individual Person is accepting this Policy as a Client but acting for another Person (for example, as an officer, employee or agent of such other Person), then that other Person is also a Client.
- “Shotzy Photography services marketplace platform” means the software designed, written and/or implemented by or on behalf of Shotzy that permits a Photographer to connect with a client and provide Photography Services and all of the code and electronic protocols and prompts associated therewith, whether resident in the “cloud,” on the Photographer’s or Shotzy’s computers or servers or on a Client’s or other participant’s mobile device or computer, and the associated aspects of any Shotzy Portal.
- “Shotzy Platform Services” means the services associated with facilitating Photography services on or through the Shotzy Platform
- “Shotzy Portal” means the shotzyapp.com website, any Shotzy mobile or smart- phone application or any other website or application owned or operated by or on behalf of Shotzy.
- “Collect” or “Collection,” as in Collecting Information, means the act of gathering, acquiring, obtaining or receiving Information from any source, including third Persons, by any means.
- “Content” of a photography session means and includes any and all images produced by the Photographer during a session
- “Information” means either or both Non-personal Information and Personally Identifiable Information.
- “Photographer” means an individual who photographs. If a Photographer is acting for or through an employer or agent, then the term “Photographer” also includes the employer or agent.
- “Photography session” means photography conducted on or through the Shotzy Platform.
- ” Photography Services” means all services associated with connecting photographers and clients and providing clients with the images taken by the photographer during a photography session. “Shotzy-facilitated Photography Services” are Photography Services provided through the Shotzy Platform.
- “Non-personal Information” means information that may not by itself be reasonably associated with, linked to or used to identify and individual.
- “Person” means any individual or any legal entity.
- “Personally Identifiable Information” means information that may be reasonably associated with, linked to or used to identify an individual, allowing that individual to be personally identified or contacted (but it does not include the name, title or business address, telephone number or email of an employee or other representative of an organization).
- “Share” or “Sharing,” as in Sharing Information, means making Information available to Persons outside of Shotzy.
- “Use” or “Using,” as in Using the Shotzy Platform or Shotzy-facilitated Photography Services, means each and every incident of initiating, conducting or participating in a Photography session on or through the Shotzy Platform; Visiting, listening, copying, playing or replaying, sending, posting, sharing, editing, filing, acting upon, commercializing, benefiting from or using a Photography session conducted on or through the Shotzy Platform (or any Content thereof) or a video or audio recording of all or part thereof; uploading or downloading information to or from, exchanging data or otherwise communicating with or through or interacting with any Shotzy Portal in relation to the Shotzy Platform, and any Photography or any Content thereof.
- “Utilize,” as in Utilizing Information, means treatment and handling of Information by or within Shotzy.
- “Visit” or “Visiting,” as in Visiting the Shotzy Platform means each and every incident of access, display, viewing, browsing or otherwise interacting with the Shotzy Platform or any associated aspect of a Shotzy Portal.
Principle 11. Language. This Policy is written in and intended to be governed by the English language. If you are not comfortable reading the English language, then it is your responsibility to have this Policy translated into a language that you are comfortable reading.
Copyright © June 17, 2017 Paparazme, LLC All Rights Reserved.