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 “Service” or “Services”).
We collect the following categories of information when you use our Services:
Information you provide directly 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.
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 |
|---|---|
| Performance of a contract with you Necessity to comply with a legal obligation |
| Necessity for our legitimate interests (for instance, to manage our services and grow our business) |
| |
| |
| Necessity for our legitimate interests (to grow our business) |
| 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) |
| 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 | |
| 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.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
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.
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:
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.
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.
California
Your Consumer Rights
Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as "personal data"), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the "CCPA") as amended by the California Privacy Rights Act, the Colorado Privacy Act ("CPA") and the Virginia Consumer Data Protection Act ("VCDPA"). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.
A. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
B. Correction. You can correct what personal data our Service database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
C. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
D. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
E. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
F. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
G. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
H. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, who chooses to exercise the rights listed above, you can:
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request. Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request. We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
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.
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.
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.
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.
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