PLR IP HOLDINGS, LLC AND PLR ECOMMERCE, LLC

PRIVACY POLICY

Updated as of August 21, 2018

This Privacy Policy (the "Privacy Policy") sets forth details of how PLR IP Holdings, LLC and PLR Ecommerce LLC (“Polaroid,” "we," "us," or "our") obtain, use, share, and protect personal information. This Privacy Policy applies to any personal information we collect or receive, including information collected through your use of our website, www.polaroid.com (“website”), and any information we obtain from other sources. This Privacy Policy does not apply to your use of websites operated by third parties that are linked to or accessed from Polaroid.com.

Click on the links below to jump to each section:

What information do we collect?

We collect and receive a variety of types of information, such as:

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:

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 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:

For other purposes

How do we disclose your personal information?

We do not share your personal information with third parties except in the circumstances described below.

Which analytics and interest-based advertising partners do we use?

We use Google Analytics to recognize you and link the devices you use when you visit our website or otherwise engage with us. Google Analytics allows us to better understand how our users interact with our website and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website “How Google uses data when you use our partners' websites or apps” here. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here. You can find Google’s Privacy Policy here.

Third-party ad networks, including Google, use cookies (such as the DoubleClick cookie) to serve ads based on your past visits to the website. For more information about how Google Ads uses cookies and other technologies to personalize ads, click here. Google’s ability to use and share information collected by Google Ads is restricted by Google’s Terms of Service and Privacy Policy. If you would like to learn more about how to manage your Google Ad Settings to opt-out of receiving personalized ads served by Google, click here. We also use the DoubleClick cookies and/or pixels in connection with Google Ads. Click here if you would like to learn more about how you can install a browser plugin to maintain your preference to opt out of personalized ads from Google, even if you've cleared your cookies.

The Facebook pixel is installed on certain pages of our website. The Facebook pixel is a tool that allows us to measure the effectiveness of our ads by understanding the actions taken on our website. We use the data collected through the Facebook pixel to measure ad conversions, make sure that our ads are shown to the right people, build advertising and custom audiences, and retarget ads shown to you on Facebook and Instagram. For more information on the Facebook pixel, click here. For more information about how Facebook uses and shares information, see its Privacy Policy and Cookies Policy. For more information about how to control the ads you see on Facebook and how to manage your ad settings and preferences, click here.

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:

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.

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.

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.

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.

Do we recognize Do Not Track signals?

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them at this time. For information about the choices you have about limiting how you are tracked online (for example, for advertising practices described in this Privacy Policy), please see the “ What choices do you have about your personal information?” section above.

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 privacyconcern@polaroid.com 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?

We will keep your personal information for the period necessary to fulfill the purposes described in this Privacy Policy unless a longer retention period is permitted or required by law. In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

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.

Our website provides links to third-party websites that we do not operate, control or maintain. Our website also may contain third-party ads. The third parties operating those websites and serving those ads have their own privacy practices and policies, and we are not responsible for their actions. For example, our website links to the “Polaroid Originals” website maintained at polaroidoriginals.com. That website is operated by one of our brand licensees, Impossible America Corp., which sells Polaroid Originals-branded products, and with whom we also have a marketing affiliate relationship. We do not operate the Polaroid Originals website and we are not responsible for the privacy practices of Impossible America, Corp. (its Privacy Policy may be found here). We urge you to read the privacy policies of all third-party websites and third-party advertisers to learn more about their privacy practices and policies.

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 privacyconcern@polaroid.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.

International Users

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:

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 privacyconcern@polaroid.com.

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 privacyconcern@polaroid.com.

Individual Rights

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 privacyconcern@polaroid.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.

When you access the website, you will be required to affirmatively consent to the terms of this Privacy Policy and cross-border data transfers. By checking the appropriate box(es), you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (including the uses, disclosures, and transfers to third countries outside of the European Union of information about you by us) that are described in this Privacy Policy. Any consent you provide will be entirely voluntary and may be withdrawn at any time. However, by not providing consent(s), some or all functionality on the website may not be available to you.

What about updates?

Please note that this Privacy Policy may change from time to time. We will post any changes to this Privacy Policy on this page. If we make material changes to this Privacy Policy, we may notify you of those changes by additional means, for example, by posting a notice on our website, by sending you notification of the revised policy by email, if you have provided your email address to us, or by other means.

Additional Information and How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at privacyconcern@polaroid.com or write to us at:

PLR Ecommerce, LLC
4350 Baker Road, Suite 180
Minnetonka, Minnesota 55343

If you are a resident of the EU and your inquiry with us has not been satisfactorily addressed, or if you believe we are processing your personal data not in accordance with the law or this Privacy Policy, you may file a complaint with the supervisory authority in your country of residence.