Fingerpaint Privacy Policy

Effective Date: June 30, 2022

Fingerpaint Marketing, Inc. and all its wholly owned subsidiaries (collectively, “Fingerpaint,” “Company,” “we,” “us,” “our”) are committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you. It applies to the websites and online services that we operate and that link to this Privacy Policy (the “Services”).


I. COLLECTION OF INFORMATION

We collect the following categories of information when you use our Services:


  • Information you provide directly to us.

    • Contact Information, including name, email address, telephone or mobile phone number, or address.
    • Registration Information, including information like username or password if you register on our website in order to receive additional information.
    • Correspondence you send to us.

  • Information we collect automatically. We collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type, IP address, device and advertising identifiers, pages that you visit before and after using the Services, browsing history, and search history, the date and time of your visit, information about the links you click, pages you view, and other information about how you use the Services. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. Consistent with your mobile device or app permissions, we also collect geolocation information (including geolocation information derived from your GPS, Wi-Fi and Bluetooth signals, IP address, and other device information).


We may not be able to provide you with requested services if you do not provide certain types of personal information necessary for the service. Please contact us at the details below if you have any questions about our services and the necessary personal information.


We may aggregate or de-identify the information described above. Aggregated or de-identified data are not subject to this Privacy Policy.


II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above for the following business purposes:

Purpose/Activity European Economic Area (EEA) lawful basis for processing, including basis of legitimate interest
  • To provide you with the information, products, and services that you request from us;
Performance of a contract with you
Necessity to comply with a legal obligation
  • To allow you to participate in interactive features of our Services, when you choose to do so;
Necessity for our legitimate interests (for instance, to manage our services and grow our business)
  • To manage accounts and to manage our relationship with you, including providing you with the information, products, and services that you request from us; and
  • To notify you about changes to our terms or Privacy Policy.
  • To make suggestions and recommendations to you about things that are similar to those that you have inquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates.
Necessity for our legitimate interests (to grow our business)
  • To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device.
Necessity for our legitimate interests (to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
  • To administer our Services, including troubleshooting, data analytics, and testing; to keep our Services, business, and users safe and secure.
Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud)
Necessity to comply with a legal obligation
  • To comply with applicable laws and regulations; to protect or exercise our legal rights or defend against legal claims; to carry out processing necessary in the context of a business reorganization or group restructuring exercise.
Necessity to comply with a legal obligation
Necessity for our legitimate interests (to keep business records; to manage our business)

Where legally required and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information or share information with third parties), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.


Where we need to collect information by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may cancel a product or service you have with us.


III. DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.


  • Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, verifying customer information, research, data hosting, auditing, and data processing.

  • Corporate affiliates. We may share your information with our corporate affiliates.

  • Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, a consolidation, an asset sale, an initial public offering, or in the unlikely event of bankruptcy.

  • Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Fingerpaint, our affiliates, users, or the public.

  • With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

Fingerpaint does not sell your information to third parties. Fingerpaint does permit third parties to collect the information described above through our Services and discloses such information with third parties for business purposes as described in this Privacy Policy. The information practices of these third parties are not covered by this Privacy Policy.


IV. COOKIES AND SIMILAR TECHNOLOGIES

When you use our Services, we and our third-party partners (such as data analytics providers) use cookies, pixel tags, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. For additional information, please reference our Cookie Policy.


The following types of cookies are used on our Services:


  • Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.

  • Preference cookies – These cookies store information such as your preferred country and language selection, login data, and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country/language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.

  • Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.

  • Content/advertising cookies – These cookies gather information about your use of our Services so we may improve your experience. They remember that you’ve visited our Services and help us understand usage of our Services.

Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit do-not-track signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted or whether they even are aware of them. We currently do not take action in response to these signals.


You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the help section). If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you, and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt-out selection in your browser.


For additional information on how Google processes your information and what choices you may have, visit their site here.


V. YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable law, to request more information about our information practices or to object to or request restriction of processing of your information and to request access to, correction of, and deletion of your information. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we will first verify your identity, which may require you to verify personal information that we already have or to provide additional information. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, contact us.


You may also unsubscribe from any email communications you receive from us by clicking the unsubscribe link within the email or by contacting us and requesting to be removed from our marketing list.


We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you. Any difference in the Services is related to the value provided.


You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.


VI. INTERNATIONAL TRANSFERS

By using the Services and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction. To the extent you are a resident of a country other than the United States, you acknowledge that your personal information may be transferred to the United States for processing by us in accordance with this Privacy Policy.


Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA, including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality, and the Company implements measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below.


VII. CHILDREN

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.


VIII. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.


We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data are reliable for their intended use and are accurate, complete, and current. You should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.


IX. CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. Where required by applicable law, we will provide you with notice of updates to the Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.


X. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please contact us:


Fingerpaint Marketing, Inc.

395 Broadway,

Saratoga Springs, NY 12866

Email address: privacy@fingerpaint.com