Polaroid Legal

This Privacy Policy explains how Polaroid International B.V. (Polaroid, we or our) collects, stores and uses your personal data when you use (Use) the Polaroid application (the App). Please read this Privacy Policy carefully.

We respect your right to privacy. The processing of your personal data is subject to the rules of the General Data Protection Regulation ((EU) 2016/679) (GDPR), as well as the national implementation acts of the GDPR.

1. Who we are

Polaroid is a company registered with the commercial register in The Netherlands (Chamber of Commerce registration number 59065982) whose registered office is at Danzigerkade 16C, 1013 AP, Amsterdam, The Netherlands. Polaroid is part of the Polaroid group of companies. You may contact us on privacy@polaroid.com.

With regard to your personal data that we process as a result of the Use of the App (see paragraph 2), we are the controller within the meaning of the GDPR. This means we have certain statutory duties and responsibilities regarding our processing activities. This Privacy Policy serves to inform you on how we meet our duties and responsibilities.

2. The personal data we collect about you

When you Use the App, we and/or our third party data processors acting on our behalf (see paragraph 5) collect the following personal data about you:

Personal data you provide to us:

  • ArrowUser data: such as (sur)name, email, social media handle, and any other information you choose to provide to us;
  • ArrowContent: such as submitted or otherwise provided photos, videos, text, information, graphics and other content within the App. NB. Any content transmitted through the App using the Polaroid Scanner, Polaroid AR Picture, Polaroid Lab Printer or the Camera Connectivity and Control will be stored on your third-party smart device only. Polaroid will not collect, store nor have access to this content;
  • ArrowUsage and preference data: we collect data about how you and other App users interact with our services, preferences expressed, and settings chosen;
  • ArrowDevice data: we collect data about your mobile device, including, for example, the hardware model, operating system and version, software, IP address, file names and versions and preferred language;
  • ArrowLocation data: we collect data about the location where your device is used;
  • ArrowLog data: when you interact with our services and hardware products within the App, we create server logs, which include access dates and times, app features or pages viewed, app crashes and other system activity.

Personal data collected from other (third party) sources:

  • ArrowPersonal data available through public sources: In order to be able to offer our services in the App correctly and to create the best user experience, we collect personal data from third parties, such as app stores, operating system and device manufacturers, and analytical companies.

We do not access any personal data from the Google Play Store and/or the Apple App Store.

3. Legal bases of the processing of your personal data

The GDPR requires a legal basis for the processing of personal data. For each purpose (see paragraph 4), we will indicate the legal bases on which we process your personal data.

Our legal basis for processing your personal data is:

  • ArrowYou have given your consent to the processing of your personal data (purpose A and B);
  • Arrowthe processing is necessary for the performance of a contract to which you are a party, or in order to take action at your request prior to the conclusion of a contract (e.g. offering our services within the App) (purpose C and D);
  • Arrowthe processing is necessary for us to comply with our legal obligations to which Polaroid is subject (purpose F and J);
  • Arrowthe processing is necessary for our legitimate interests or those of a third party (purpose D, F, G, H, I, and K). The legitimate interest we pursue is the proper conduct of our business activities, such as ensuring that the content from our services is presented in the most effective manner, to troubleshoot software bugs and operational problems and provide you with information on products and offers which are relevant to you.

When processing is based on consent, you have the right to refuse consent at any time without prejudice. You also have the right to withdraw your granted consent at any time, after which we will stop the further processing of your personal data. However, withdrawal of your consent does not affect the lawfulness of the processing prior to that moment.

4. How we may store and use your information

Polaroid (and third party data processors acting on our behalf) may collect, store and process your personal data:

A. to feature the content (such as photos, videos, information, text, graphics, or other content) you have submitted to Polaroid in the App, and to credit you in relation to this content;

B. to answer questions you have submitted to Polaroid in the App;

C. to make this App and its features available to you;

D. to provide our services to you;

E. to develop and distribute our app;

F. 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;

G. to ensure that content from our services is presented in the most effective manner for you and your device;

H. to administer, secure, adapt and improve our services and products 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 analyze usage and activity trends;

I. to be able to answer and handle legal requests and/or complaints;

J. to comply with legal obligations applicable to Polaroid; and

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

5. Disclosure of your personal data to third parties

In some cases, we share your personal data with third parties. We only provide your personal data to third parties if this is necessary for one or more of the purposes listed in paragraph 4. Your personal data may be shared with the following parties and/or for the following reasons:

Company acquisition or business or asset sale: in the event that a third party acquires all or part of our business and/or assets, we may disclose your personal data to that third party in connection with the acquisition. We also reserve the right to disclose your personal data to third parties as part of any business or asset sale carried out because Polaroid has gone into insolvency or any similar situation, but only where lawful and compliant with the applicable data protection legislation, as amended from time to time.

Comply with applicable law: we may disclose your personal data where necessary to comply with applicable law or an order of a governmental or law enforcement body. We may also disclose your personal data in response to a request for personal data by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.

Subsidiaries and affiliated entities: we may share your personal data with our subsidiaries and affiliated entities within the Polaroid group that provide services or conduct data processing in relation to the App on our behalf.

Other relevant parties: we may disclose your personal data where necessary with our processors, vendors, consultants, marketing partners, and other service providers who need access to such personal data to carry out work on our behalf for the performance of any contract we enter into with them.

Analytics: this App uses Google Analytics for Firebase, Google Firebase Crash Reporting and Amplitude Analytics services (i) provided by Google resp. Amplitude and (ii) providing insight into App usage and user engagement. Google and Amplitude will use this information on our behalf for the purpose of evaluating your use of the App and compiling reports on App activity for us. Some Firebase and Amplitude Analytics services process personal data, that will be provided to us by Google resp. Amplitude in an aggregated manner. For this reason, a data processing agreement is concluded with Google and Amplitude. However, the aggregated data received from Google and Amplitude does not represent personal data for us as we are not reasonably able to identify a specific user on the basis of this information, nor do we make any efforts to personalize it subsequently. We process these aggregated data to analyze and optimize usage behavior in general, for example by evaluating crash reports.

We may, in some cases, merge your personal data with the data of third parties. We do this, for example, to see your previous purchases.

6. Submitted content

You may decide to submit content (such as photos, videos, text, information, graphics or other content) to Polaroid within the App via one of the App features (e.g. Instant Answers or Creative Calls). If you do so, you consent to Polaroid processing this content for the purpose of disclosing the content (in combination with your name and/or social media handle) within the App, on Polaroid’s social media channels, websites and e-newsletter. Polaroid can use your email address to contact you for collaboration opportunities in relation to your content.

You may request Polaroid to remove your content from the App, other digital channels and its systems at any time by reaching out to services@polaroid.com or privacy@polaroid.com. For more information about how Polaroid will use with submitted content please see the User Generated Content Policy – Polaroid App.

NB. This paragraph does not apply to content transmitted through the App using the Polaroid Scanner, Polaroid AR Picture, Polaroid Lab Printer or the Camera Connectivity and Control. This content will be stored on your third-party smart device only. Polaroid will not collect, store nor have access to this content.

7. International transfers

We (or our processors) may transfer personal data that we collect from you to third party (sub) processors located in countries that are outside of the European Economic Area (EEA) and to other Polaroid group companies in connection with the above purposes. For example, some Polaroid group companies or processors are domiciled in the United States, which leads to the disclosing of your personal data outside the EEA.

In such situations we will ensure that appropriate safeguards are in place that offer an adequate level of protection of your rights and freedoms as a data subject in accordance with the GDPR. We do this, for example, by concluding standard contractual clauses for the transfer of personal data approved by the European Commission, or by transferring your personal data only to third parties that are considered to guarantee an adequate level of protection according to the European Commission.

8. Data retention

We will retain your personal data for no longer than is necessary for the purpose(s) for which it is collected or processed and/or in accordance with legal obligations. After a retention period, we will delete or anonymize your personal data, unless we retain (part of) your personal data for another purpose. We will only do so if we have a legal basis to retain your personal data. We will ensure that personal data are only accessible for that other purpose.

For example, we retain data for the following periods:

  • ArrowUser data and content submitted to Polaroid within the App via one of the App features will be removed within six months if the submitted content does not comply with the User Generated Content Policy of the Polaroid App or violates laws or regulations;
  • ArrowUser data and content submitted to Polaroid within the App via one of the App features that does comply with the User Generated Content Policy will be retained for two years, unless we have your permission to retain the data for a longer term, or unless you have requested us to remove the data earlier;
  • ArrowUsage and preference data, Device data, Location data and Log data will be anonymized as soon as we collect it;

However, a longer retention period of your personal data may occur if this is necessary to comply with a legal obligation. If a dispute or (legal) proceedings are expected, we may also retain your personal data for a longer period of time.

We will in any case comply with legal data retention obligations. If you would like to receive more information about the retention periods that we apply, please contact us on privacy@polaroid.com.

9. Your rights

As a data subject, you have a number of rights that you may exercise in the context of our processing of your personal data:

  • Arrowthe right of information about the personal data we process about you;
  • Arrowthe right to access your processed personal data;
  • Arrowthe right to rectification of the personal data that we hold about you; 
  • Arrowthe right to erasure of your personal data (under circumstances listed in the applicable law); 
  • Arrowthe right to restrict the processing of your personal data (under circumstances listed in the applicable law); 
  • Arrowthe right to object against the processing of your personal data (e.g. in relation to the processing of your personal data for advertising purposes); 
  • Arrowthe right to data portability (you can ask us to provide you or a third party with your personal data in a readable and accessible form); and 
  • Arrowthe right to withdraw your consent to the processing of your personal data. 

For security purposes we may occasionally request proof of identity before we are able to exercise your rights. If you wish to exercise any of the above rights, please contact us on privacy@polaroid.com.

Please take into account that your rights are not absolute in all cases, and that we may not be required to comply with your request. If that is the case, we will make sure you will be informed of this.

10. Updates to this Privacy Policy

This Privacy Policy was last updated in February 2025 and replaces our previous Privacy Policy. Please check back regularly to stay informed of updates to this Privacy Policy. If we make any changes to this Privacy Policy in the future, we will publish the revised Privacy Policy on the App. If changes are made that may significantly affect you as a data subject, we will do our best to directly inform you about those changes. All changes will take effect as soon as the Privacy Policy has been published on the App.

11. Questions and complaints

In case you have any questions or complaints regarding the processing of your personal data, please contact us on privacy@polaroid.com. If you are of the opinion that we process your personal data in an improper or unlawful manner, that we do not/insufficiently take regard of your objection or request in the context of your rights or if you wish to make a complaint in the context of the processing of your personal data, you have at all times the right to lodge a complaint with the competent Data Protection Authority.