Last Updated: January 2023
1. About Splashlight
2. Personal Information Collection
3. How We Use Your Personal Information
4. How We Share Your Personal Information
5. Social Media and Technology Integrations
6. Analytics and Advertising
8. Information Pertaining to Children
9. Additional Disclosures for California Consumers
10. Your Privacy Rights and Choices
12. Contact Us
13. Splashlight Group Entities
- 1. About Splashlight
Splashlight is a visual content creation company headquartered in the United States. Over the years, Splashlight has built a reputation for bringing the quality standards of high-fashion and luxury photography and video into the high-velocity, high-volume world of content creation. For more information, please visit www.splashlight.com.
- 2. Personal Information Collection
Personal Information You Provide to Splashlight
We collect different types of personal information that you voluntarily submit, which including in the preceding twelve (12) months include:
- Identifiers, such as your name, email and mailing addresses and phone number;
- Professional or employment-related information, such as your employer or company name, job title, industry, type of company and size of company;
- Registration information, such as information regarding your visit to our studios;
- Commercial information, including records of products or services purchased from us;
- Support information, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online; and
- Marketing information, including your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Please do not submit any personal information to us that we have not requested. Please note that if we have requested personal information from you and you decide that you do not want to share certain personal information with us, then this may prevent us from providing our Services and Communications to you.
Personal Information Collected Automatically
Splashlight also automatically collects certain information about your device and how your device interacts with our Services and Communications. The categories of personal information we automatically collect and have collected in the last twelve (12) months include your device’s IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Services and Communications, and your browsing habits on and usage of the Services and Communications through your device.
We use various current – and later – developed technologies to collect this information (“Tracking Technologies“), including the following:
- Cookies. A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited. For more information, please see our Website & Cookies Notice.
- Location-identifying Technologies. Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
Information on Behalf of Our Customers
Splashlight acknowledges that you may have rights in connection with Customer Data. If your information has been processed by Splashlight on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to Splashlight, please provide the name of the Splashlight customer on whose behalf Splashlight processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.
Information from Other Sources
We may obtain personal information about you from other sources. The categories of other sources from which we collect and have collected personal information from in the last twelve (12) months include:
- Social networks when you reference our Services and Communications or grant permission to us to access your information;
- Vendors and service providers, including for data analytics and marketing and advertising our products and services to you;
- Partners with which we offer co-branded services or engage in joint marketing activities; and
- Publicly-available sources such as data in the public domain.
- 3. How We Use Your Personal Information
- To operate and manage our Services and Communications;
- To perform our Services and Communications for you as a customer of Splashlight, and communications requested by you, including to respond to any questions or requests and provide customer support;
- To monitor and analyze trends, usage, and activities;
- To improve our Services and Communications, including our website, marketing efforts, products and services;
- To undertake our contractual obligations to you as a customer of Splashlight;
- To manage any complaints or claims relating to services you provide to us, or our Services and Communications we provide to you;
- To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
- To provide you with advertisements;
- Where necessary, to comply with laws and regulations, under judicial authorization, or to exercise or defend the legal rights of Splashlight; and
- To fulfill any other business or commercial purposes disclosed to you.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your personal information, please see the section “Your Privacy Rights and Choices” below.
- 4. How We Share Your Personal Information
We only share your personal information if it is necessary to do so in order to provide our services to you or enhance our relationship with you. Whenever we share your personal information with a third party provider we ensure that this is done so in accordance with applicable laws. The types of entities to whom we disclose and have disclosed information with in the last twelve (12) months, are as follows:
- Affiliates. We may share your personal information with our affiliates for internal business purposes. For example, for customer support, marketing, or technical operations;
- Third-party service providers. Our service providers may process your information in connection with their work on our behalf and are contractually prohibited from retaining, using, or disclosing your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other commercial purposes;
- Vendors and other third parties. We may share information with vendors and other third parties for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your personal information. For more information on advertising, see the “Analytics and Advertising” section below;
- Merger or acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business;
- Security and compelled disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the service rules or policies, or the rights of other parties or to investigate any suspected conduct which Splashlight deems improper. We may also share your information to protect the rights, property, life, health, security and safety of us, the service or any other party; and
- Consent. To any other person you have consented to us to share personal information with.
Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with other parties or affiliates except as prohibited by applicable law. For information on your rights and choices regarding how we share your personal information, please see the section “Your Privacy Rights and Choices” below.
- 5. Social Media and Technology Integrations
Our Services and Communications may contain content from and hyperlinks to websites, locations, platforms, and services operated, owned, and maintained by third parties. In addition, we may integrate technologies operated or controlled by other parties into parts of our Services and Communications. For example, our Services and Communications may contain hyperlink(s) to websites, social media platforms, and other services not operated or controlled by us. These other parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use one of their features, both we and the applicable other party may have access to and use information associated with your use of that feature. If you publicly reference our Services and Communications on a social network (e.g., by using a hashtag associated with Splashlight in a tweet or post), we may use your reference on or in connection with our Services and Communications.
The information collected and stored by third parties, whether through our Services and Communications, or another parties’ service or device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. Splashlight is not responsible for and makes no representations regarding the privacy practices of third parties. You should carefully read their own privacy policies before providing any information to such parties.
- 6. Analytics and Advertising
Our Services and Communications also contain Tracking Technologies, some which are operated by vendors or other parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Services and Communications, compile statistic reports on the service’s activity, and provide other services relating to Services and Communications activity and internet usage. Similarly advertisers, and other parties may use Tracking Technologies on our service and other services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on other websites or devices after you have left the Service.
For further information on Tracking Technologies and your rights and choices regarding them, please see “Personal Information Collected Automatically” above and “Your Privacy Rights and Choices” below.
- 7. Security
We take reasonable steps to help protect the security of your personal information. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of personal information, we have put into place physical, electronic, and managerial procedures. However, due to the inherent open nature of the Internet, we cannot guarantee the security of your personal information.
- 8. Information Pertaining to Children
Our Services and Communications are not intended for users under the age of 13, and we do not knowingly collecting personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA“) in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with personal information, that child’s parent or guardian should email us at firstname.lastname@example.org. We do not knowingly “sell,” as that term is defined under the California Consumer Privacy Act (“CCPA”), the personal information of minors under 16 years old who are California residents.
- 9. Additional Disclosures for California Consumers
In particular, the categories of personal information we collect and the sources from which we collect it are described in detail in the section entitled “Personal Information Collection” above. The business and commercial purposes for which we collect this information are described in the section entitled “How We Use Your Personal Information”. The categories of third parties to whom we “disclose” this personal information for a business purpose are described in the section entitled “How We Share Your Personal Information”.
Splashlight does not sell information as the terms “sale” or “sell” are traditionally understood (i.e. for money). However, making a California resident’s personal information (including IP addresses and cookies IDs) available to third parties as described above may broadly be considered a “sale” under the CCPA, given its broad definition of “sale.” The definition is broad enough to include the sharing of personal information with third parties for any form of benefit, even if no money changes hands. According to this broad definition, in the year before this section was last updated, we have shared the following categories of personal information with third parties: identifiers (like your IP address) and other electronic network activity (such as browsing history) with our advertising and analytics partners. We have shared these categories of personal information with the third parties listed in the section entitled “How We Share Your Personal Information”.
In this circumstance we rely on the CCPA marketing exemption allowing us to: (i) store marketing information on third party systems, provided applicable terms are in place with our service provider; (ii) provide opt-outs from marketing communications, as opposed to requiring an opt-in; and (iii) follow applicable cookie consents on our website.
California Do Not Track Notice
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
California’s Shine the Light law
If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. To request the above information, please e-mail us at email@example.com or write to us at firstname.lastname@example.org with a reference to “CA Disclosure Information” and include your name, street address, city, state, and ZIP code. Please note that Splashlight is not required to respond to requests made by means other than through the provided e-mail address or mail address.
- 10. Your Privacy Rights and Choices
Splashlight provides ways for you to access and delete your personal information as well as exercise other rights that give you certain control over your personal information.
A. All Users
- Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We make every effort to promptly process all unsubscribe requests. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or for other transactional, non-marketing related reasons.
- Website cookies. You may modify your cookie preferences in respect of cookies that are used on our Splashlight website. For further information please see Splashlight’s Website & Cookie Notice.
B. California Privacy Rights (California Residents)
This section applies only to California consumers. The CCPA provides California residents with the additional rights listed below. To exercise these rights, please reach out to us at email@example.com with your request.
- Right to Know. You have the right to request access to, or a copy of the personal information we have collected, used, disclosed and sold about you over the past twelve (12) months, including:
- The categories of personal information we have collected, used, disclosed and sold about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information;
- The categories of third parties with whom we have shared your personal information; and
- The specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same), subject to certain limitations under applicable law.
- Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising your rights under California law.
If you are a California resident seeking to exercise your CCPA rights, or if you are an authorized agent wishing to exercise CCPA rights on behalf of someone else, please contact us via email at firstname.lastname@example.org. Please include your full name and email address along with why you are writing so that we can process your request in a timely manner.
Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent (as applicable) have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.
- 12. Contact Us
- 13. Splashlight Group Entities
We have set out below the Splashlight Group Entities that we share personal information with.
Splashlight, LLC, a New York limited liability company with offices located at 75 Varick Street, New York, NY 10013, USA.
Splashlight Photographic & Digital Studios, LLC, a Delaware limited liability company with offices located at 75 Varick Street, New York, NY 10013, USA.
Splashlight Canada Studios Limited, a Canadian company with a registered office located at 3665 Boulevard Poirier Saint Laurent, Quebec, H4R 3J4, Canada.
Splashlight Technologies, LLC, a Delaware limited liability company with offices located at 75 Varick Street, New York, NY 10013, USA.