GDPR Compliance

Last updated January 6, 2023

Photo Paper Direct Limited (together with Aterian, Inc. and its controlled affiliates, “PPD,” “we” or “us”). This Privacy Policy applies to data provided to PPD by its customers and other individuals who provide us with information. Customer data received by PPD includes information about individual purchases made by customers.

Overview and Definitions

For purposes of this Privacy Policy, certain terms have the following meanings: “Customer” means a purchaser of PPD’s product sold on an E-commerce channel. “Personal Information” means information that identifies an individual. “Sensitive Personal Information” means any information about a person that may relate to health or medical conditions, social security/social insurance numbers or national identifiers, credit card, bank account or other financial information, other information concerning trade union membership, sex life, political opinions, criminal charges or convictions, religious or philosophical beliefs, racial or ethnic origin, or other sensitive matters. “Website” means https://www.photopaperdirect.com.

COLLECTION AND USE OF PERSONAL INFORMATION

Information Provided to Us

We may collect and store Personal Information and/or Sensitive Information that is voluntarily provided to us by a Customer or other individual. When information is provided to us by a Customer or other individual, the person providing the information affirms that the person has the right to provide the information to us. Information we collect and store from Customers may include the Customer’s name, email address, phone number, as well as the quantity and price of specific goods purchased. We use this information to fulfill Customers’ orders of products, and may also use Customers’ emails and phone numbers for email and text messages communication, such as product and service updates, promotional offers, and other marketing communications. You agree that your name and email address may also be used for targeted online advertising purposes. You may opt-out of such processing of your personal data by clicking the unsubscribe link at the bottom of any of our emails or texts, or by emailing us at support@photopaperdirect.com. 

Correspondence

If a Customer or other individual contacts us via telephone, e-mail, fax, the postal service, our web page, through social media, or in any other way, we may retain the correspondence and the information it contains. This information may be used to respond to the inquiry, or for other business purposes. If a Customer or other individual communicates with us but wants to restrict the use of information provided to us, we ask that the Customer or other individual please write to us at the address listed at the end of this Privacy Policy or email us at support@photopaperdirect.com.

Information From Other Sources

We may combine information that a Customer or other individual provides to us with other information about an individual from other sources, such as vendors, service providers, business partners, and other third parties, transactions, and communications. We also may combine that information with data that is publicly available and data from third parties. This information may be used to provide an individual or Customer with the services they requested, and for other business purposes. If an individual or Customer does not wish to receive these notifications, we ask that the individual or Customer please write to us at the address listed at the end of this Privacy Policy or email us at support@photopaperdirect.com.

We also may receive information about Customers or other individuals from third party social platforms, such as Facebook, Instagram, TikTok, Twitter, or other platforms. When our Website is accessed or used through such a third party social platform, such use allows the third party social platform to collect information about the access to our Website, and allows us to access or collect information made available by the third-party website in accordance with its privacy policy. This information may be available from the Customer or other individual’s third party social platform profile or account, or from cookies or other tracking tools placed on the Customer or other individual’s device by the third-party platform. 

Information About Others

We may collect Personal Information about other people that a Customer or other individual provides to us, such as name, phone number, and email address. This information may be used to provide the requested services, or, with the consent of the other person, for other business purposes. 

Information Automatically Collected

During Website Visits

We automatically collect information about everyone who visits our Website. This includes log data that automatically records information about each visit, such as browser type, operating system, the URL of the page that referred the person visiting our Website, the different actions performed, and the IP address used to access pages on the Website. We use this information to administer the Website, analyze trends, provide an experience that is relevant to the person visiting our Website based on location of the IP address used to access the Website, gather information about visitor movements, help diagnose potential problems with our server, investigate actual or potential security incidents, and ensure the Website is working properly. We also automatically collect information related to operating system name and version, device manufacturer and model, device identifier, language, the name and version of the software application that is used to access our Website. We use this information for purposes such as ensuring that our Website functions properly and to understand usage of our Website.

We may assign a device accessing our Website with one or more cookies to facilitate access to our Website, and to personalize the online experience. A cookie is a small text file that is stored on a user’s computer or mobile device for record keeping purposes. Cookies can be either session cookies or persistent cookies. We may use both session cookies (which expire once an individual closes their browser) and persistent cookies (which stay on devices until the individual deletes them) to provide a more personal and interactive experience on our Website. These cookies may be delivered by us or by third parties.

We also work with other companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about interactions with us to present individuals who access our Website with opportunities to purchase products of PPD and its affiliates. Retargeting cookies also are used to present individuals who access our Website with PPD advertising on other websites based on their interaction on our Website and other websites.

Our Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google uses cookies to help us analyze how visitors use the Website. The information generated by the cookie about an individual’s use of the Website is generally transmitted to and stored on a Google server in the U.S. In case of activation of IP anonymization, Google will, however, truncate/anonymize the last eight-bit segment of an IP address beforehand within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the US and truncated there. On behalf of the operator of the Website, Google will use this information for the purpose of evaluating use of the Website, compiling reports on the Website activity, and providing the operator with other services relating to the Website and Internet use. Google will not associate an IP address with any other data held by Google.

An individual may manage and opt out of Google’s use of cookies by visiting Google’s Ads settings. However, please note that if this is done, the user may not be able to use the full functionality of the Website. Alternatively, an individual can opt out by visiting the Network Advertising Initiative opt-out page: http://www.networkadvertising.org/choices. Please note that if use of cookies is disabled, it may not be possible to use the full functionality of the Website.

For further information on terms of use and data protection/privacy, please see www.google.com/analytics/terms/us or www.google.com/analytics/learn/index.

Our Website interfaces with social media websites such as Facebook, Instagram, and Twitter and may uses social media plugins (such as the Facebook “Like” button) to facilitate social media functions. When our Website is visited, the operator of a social media plugin may set cookies or other tracking technology on the visitor’s browser, enabling that social media operator to recognize individuals who visit our Website. If a visitor to our Website is logged into a social media website while browsing on our Website or using, the social media plugins may allow the social media website to receive information about the visitor’s visit-including the pages that were viewed-and connect the visit to the visitor’s User Information, Personal Information, and Sensitive Personal Information. The social media plugins also allow the social media website to share information about a visitor’s activities on our Website with other users of their social media website. For example, Facebook social media plugins allow Facebook to show a visitor’s Likes and comments on our Website to the visitor’s Facebook friends. A visitor’s use of social media plugins is subject to each social media website’s privacy policy, so we encourage visitors to use care and thoughtfully read the privacy policy of each social media website that is used. We have no control over the information that social media websites or plugins collect, store, or use. Before connecting to our Website from a social media website or using a social media plugin on our Website, please be certain to understand the social media website’s privacy policy and how it may gather information about access to our Website, and what is viewed on our Website. Further information on opting out of Facebook ads is here.

Do Not Track

Some browsers have a “Do Not Track” feature that lets an individual tell websites that the individual does not want to have their online activities tracked. These features are not yet uniform, and we currently are not able to respond to those signals.

Sharing Information with Third Parties

We do not reveal Personal Information or Sensitive Personal Information to third parties except in the following circumstances:

• We may transfer information to our agents, third parties, or service providers to conduct our business, and to fulfill the purposes for which you provided such information. For example, third parties and service providers working with us may handle credit card processing, shipping, customer service, data management, e-mail distribution, fraud prevention, market research, information analysis, promotions management, social media marketing, and similar services. 
• We may use cloud service providers to host the Website and store data, and these service providers inform us that they apply security measures they consider adequate for the protection of the information within their system.

We may also transfer your information:

• in order to comply with the law, regulation, valid legal process (e.g., search warrant, subpoena or court order), or governmental or regulatory request; 
• to address disputes or claims; 
• to protect the security or integrity of the Website and PPD’s services; 
• to enforce an agreement; 
• to protect our rights, property or safety, or the rights, property or safety of our employees or others; 
• to address emergencies or acts of God; 
• in anticipation of and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of our business or operations; or
• when an individual whose data we hold requests or authorizes us to do so. 

Once we are directed to share data with a third party, that data is governed by the third party’s privacy policy. We also may share or sell de-identified data with partners and the public in a variety of ways, such as by providing research or reports. To the extent that we provide de-identified data, we perform appropriate procedures so that the data does not identify any individual and does not permit re-identification of any individual.

Security Measures

We are committed to taking reasonable efforts to secure the information that is provided to us, and we use a variety of security technologies and procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of data. Even though we take reasonable steps to secure your information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot fully guarantee the security of information that is provided to us. Questions about the security of information provided to us, including the security of our Website, should be directed to us by sending us an email or writing to us at the address listed below, indicating “Security Inquiry” in the subject line.

California Privacy Rights

This section applies only to California residents. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

California residents have the right to ask us one time each year if we have shared their personal information with third parties for direct marketing purposes. To make a request, please write to us at the address listed at the end of this Privacy Policy or email us at support@photopaperdirect.com, indicating “California Shine the Light Inquiry” in the subject line.

Additionally, you have the right to: 

• Request a copy of the Personal Information that we have collected about you during the past 12 months.
• Ask us to delete or correct the Personal Information that we have collected from you, subject to limitations set forth in the law.
• Opt-out of sale or sharing of your Personal Information. If you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your Personal Information with third parties for their direct marketing purposes.
• Limit the use and disclosure of your Sensitive Personal Information.
• Non-retaliation if you choose to exercise any of these rights. 

To exercise any of these rights, please write to us at the address listed at the end of this Privacy Policy or email us at support@photopaperdirect.com, and indicate “California Consumer Privacy Act Request” in the subject line. We may need to verify your identity and authority before we can respond to your request. 

Notice of Financial Incentives

We offer our customers a loyalty program that provides a discount for signing up to our email and SMS/text marketing list, and may also give individuals who have signed up to our email and SMS/text marketing lists access to future discounts and incentives. From time to time we may also provide other programs, such as sweepstakes, contests, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program rules, or by contacting us at the address listed at the end of this Privacy Policy or emailing us at support@photopaperdirect.com.

Notice to European Users 

Users who are located in the European Economic Area, Switzerland or the United Kingdom (collectively, “Europe”) can find additional information about their rights in this section.

For Customers and Website visitors outside of the United States, please be aware that your Personal Information will be transferred outside of Europe, and will be stored, and processed in the United States, where our servers are located and our central database is operated. Non-European countries do not have the same data protection laws as Europe. Please refer to the Security Measures section of this Privacy Policy for additional information on how to protect and secure the data you provide to us. Your consent to this Privacy Policy followed by your continued use of our Website and the submission of information to us represents your agreement to this transfer.

References to “Personal Information” in this privacy policy are equivalent to “personal data” governed by European data protection legislation. For purposes of European data protection legislation, the data controller for your Personal Information is Photo Paper Direct Limited, Unit 8 Shakespeare Industrial Estate, Shakespeare Street, Watford, Hertfordshire, WD24 5RR.

We only process personal data where we have a legal basis for doing so - to perform the contract with Customers, to comply with law, where we have a legitimate business reason to do so which is not overridden by your rights, or otherwise with your consent.

European data protection laws give you certain rights regarding your Personal Information. If you are located in Europe, you may ask us to take the following actions in relation to your Personal Information that we hold:

• Give you access to your Personal Information.
• Update or correct inaccuracies in your Personal Information.
• Delete your Personal Information where there is no legitimate business reason for us to continue to process it.
• Transfer a machine-readable copy of your Personal Information to you or a third party of your choice.
• Restrict the processing of your Personal Information.
• Object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights.
• Withdraw your consent where we are relying on your consent to process your Personal Information. 

You also have the right to lodge a complaint to your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html). 

You may submit these requests here. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Disclosure for Law Enforcement - Under certain circumstances, we may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

We may disclose your Personal Information in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend our rights or property
• To prevent or investigate possible wrongdoing in connection with our services
• To protect the personal safety of users of our services or the public
• To protect against legal liability

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is data collected automatically generated by the use of our Website or services. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services or we are legally obligated to retain this data for longer periods.

Cookie Policy

We may use "cookies" to track your preferences and activities on the Website and other websites controlled by PPD, its affiliates, and business partners. Cookies are small data files transferred to your computer's hard drive by a website. They keep a record of your preferences so that your subsequent visits to the website may be more efficient and/or customized.

Cookies may store a variety of information, including the number of times that you access a site, registration information, and the number of times that you view a particular page or item on the site. The use of cookies is a common practice adopted by most major websites so that companies and other organizations can better serve their customers.

Most browsers are designed to accept cookies, but they can be easily modified to block cookies; see your browser's settings or help files for details. You can also opt out of our use of cookies by clicking Here. Please note that without cookies, some of our website's functions will not be available or you will lose some of the benefits of the site.

Cookie Declaration

We may use "cookies" to track your preferences and activities on the Website and other websites controlled by PPD, its affiliates, and business partners. The types of cookies we use are: 

• Strictly necessary cookies allow core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies.
• Functionality cookies are used to remember visitor information on the website, e.g. language, time zone, enhanced content.
• Targeting cookies are used to identify visitors between different websites, e.g. content partners, banner networks. Those cookies may be used by companies to build a profile of visitor interests or show relevant ads on other websites.
• Performance cookies are used to see how visitors use the website, e.g. analytics cookies. Those cookies cannot be used to directly identify a certain visitor.
• Unclassified cookies are cookies that do not belong to any other category or are in the process of categorization. 

Children

Our services are not intended for use by or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. We may provide links to third-party websites that allow children under the age of 13 to register for use of the website, or are targeted at children under 13. In such instances, the third-parties are responsible for ensuring that their websites comply with applicable laws, regulations, and rules.

Visiting Our Website From Outside the United States

For Website visitors outside of the United States, please be aware that information about your visit may be transferred to, stored, and processed in the U.S., where our servers are located and our central database is operated. Please be aware that the data protection and other laws of the U.S. might not be as comprehensive as those in your country. By visiting our Website, you agree that your information may be transferred to our facilities and those third parties with whom we share it, as described in this Privacy Policy.

Inapplicability of Privacy Policies of Any Linked Websites or Other Third Parties

This Privacy Policy only addresses our use and disclosure of information. It does not address, and we are not responsible for, the privacy or security practices of any third parties, including our third-party service providers (including cloud service providers and any other third party operating any software application or website to which our Website contains a link. The inclusion of a link on the Website does not imply endorsement of the linked software application or website by us. We encourage visitors to carefully read the Privacy Policies of other websites you visit.

Choices and Access

Visitors to our Website have choices about how we use and disclose your Personal Information and Sensitive Personal Information in connection with marketing efforts. You may unsubscribe from our other marketing communications by writing to us at the address listed at the end of this Privacy Policy or emailing us at support@photopaperdirect.com. For California residents, please consult the “Your Privacy Rights” section above for additional considerations.

If you have previously opted in to the use and sharing of your information for marketing purposes, and wish to change your preferences, you may do so by writing to us at the address listed at the end of this Privacy Policy or emailing us at support@photopaperdirect.com. 

Please note that if we receive your opt out request after having shared your information with a third party for direct marketing purposes or having otherwise transferred or disposed of your information, we may not have the ability to control the use of such information by any third party. If you opt out of receiving marketing-related messages from us, we still may send you service-related communications.

Data Retention

We will retain your Personal Information and Sensitive Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information and Sensitive Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain automatically collected usage data for internal analysis purposes. This data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our business, or we are legally obligated to retain this data for longer time periods.

How You Can Access and Change Your Information

You can update or correct your information, or remove it from our system by writing to us at the address listed at the end of this Privacy Policy or emailing us at support@photopaperdirect.com. If for some reason access is denied, we will provide an explanation of why access has been denied.

Conditions of Use

By using our services and accessing our Website, you agree to the terms and conditions contained in this Privacy Policy and/ any other agreement we might have with you. If you do not agree to any of these terms and conditions, you should not use our services or access our Website.

No Guarantee

No data transmission over the Internet or electronic storage can be guaranteed to be 100% secure. Accordingly, and despite our efforts, we cannot guarantee or warrant the security of any information transmitted to us, or to or from our online products or services. For questions about this Privacy Policy, please write to us at the address listed at the end of this Privacy Policy or email us at support@photopaperdirect.com.

Changes to the Privacy Policy

As PPD, its products, and its services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, and may do so by posting a new version online.

Contact Information 

In addition to the means of contact described above, you can contact us for any further information or requests relating to this Privacy Policy at the following address: 

Photo Paper Direct Limited 

Unit 8 Shakespeare Industrial Estate

Shakespeare Street

Watford, Hertfordshire WD24 5RR.

Email: support@photopaperdirect.com