Effective Date: December 26, 2019
Information Sharing and Disclosure
Paper Culture defines Personal Information as any information about our users from which that person can be identified. It does not include data where the identity has been removed.
Paper Culture will not rent, sell, or share Personal Information about you or information that you have provided to us with other people or non-affiliated companies except to provide Paper Culture products or services that you have requested, when we otherwise have your permission, or under the following circumstances:
We provide the information to our trusted partners who work on behalf of or with Paper Culture under confidentiality agreements. Examples of trusted partners may include third parties that provision our products and services, process email delivery, provide business and technical analytics for our internal use, advertising and marketing partners, process payments, provide customer service, monitor our servers and user experience, etc. These third parties may also use your Personal Information to help Paper Culture communicate with you about offers from Paper Culture and our marketing partners. These third parties do not have any independent right to share this information.
We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
If Paper Culture becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice that Personal Information has been transferred.
We may share aggregated, non-Personal Information with third parties. Such information does not identify you individually.
Collection and Use of Information
In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we collect the information for the reasons described below. Here's a list of intent of data use.
Information you provide:
There are many ways that Paper Culture requests personal information including when you:
- Register for an account
- Sign up for a newsletter
- Enter a promotion or contest
- Sign up for a service or product
- Personalize a product or service
- Contact customer service
- Engage on Social Media
- Sign up or request information at a live event
- Dedicate the tree that we plant with every order
- Leave a review
- Provide financial information
When you register with Paper Culture or when you request certain services on our site, we ask you for Personal Information that will change over time, but could include information such as your name, address, addresses for your address book, email address, birth date, marriage date, marriage location, phone number, and billing information. We also discern Personal Information such as your IP address through the usage of our products. We may also merge or co-mingle anonymous or non-personally identifiable data about you, your offline and online behavior, and/or your computer, mobile or other device (including its geographic location), with your Registration Information and/or other Personally Identifiable data.
We use your Personal Information for the following purposes: to fulfill the products and services you request including the initial product customization, to better serve you relevant advertising and content you see, to help create machine learning models, to contact you for service or marketing related purposes, and to troubleshoot and improve our services. We regularly update a list of ad networks and other third parties we use in connection with serving you advertising and providing technical infrastructure.
We do not use the addresses or information of the people you add to your address book for any reason other than to send them the product or services you request.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent at any time.
Once you register with Paper Culture and provide your email or register to use our services, you are not anonymous to us. Also, we may combine this Personal Information with certain information, as further described below.
Paper Culture may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon usage of Paper Culture's applications or services. It persists and updates, but it is lost when the User deletes the Application or removes cookies. A reinstall generates or a new use of the Paper Culture application creates a new UUID.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. If you use any of these types of personal data on products you design or create, we will not be able to tell. We will treat all the personal data included in designs or products as ordinary personal data
Social Media: If you connect to the Platform using Facebook, Instagram, Snap, Twitter, Pinterest, or another social networking site (each a "Social Networking Site"), we will receive information that you authorize the Social Networking Site to share with us, which may include public and private profile information including but not limited to marital status, birthday, city, employment information, education information, interests, photos and videos, browsing activities, and email address. When we receive this information, it becomes Paper Culture account information for purposes of your use of Paper Culture. This information also constitutes Personal Information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site's privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Paper Culture account by adapting the privacy settings in your Social Networking Site account. If you come to Paper Culture through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.
Google Specific: We use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. If you would like to opt-out of Google Analytics monitoring your behavior on our sites please use this link .
Log Information: Like most websites, our servers automatically log information that your device and browser sends whenever you visit a website through a browser or an application. These server logs may include information such as your web request, IP address, browser type, browser language, date and time of your request, and one or more cookies that may uniquely identify your browser. We also log HTTP request information, including headers. We use this information to analyze trends, study usability of our websites, track usage patterns, gather broad demographic information for aggregate use, and they are essential to provide a better website experience. Once you register or sign-in, we will link this log information to your Personal Information on our servers.
In addition, we reserve the right to use the information we collect about your computer, mobile or other device (including its geographic location), which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information, analyze trends, track users’ movements around Paper Culture, and to otherwise administer the service. Geographic location information about you and/or your computer, mobile or other device may specifically be used to show you content and sponsored messaging based on geographic location.
Web Beacons: Like most websites, we use web beacons and other similar technologies, to track your use inside and outside of our websites. We may also include web beacons in promotional or other e-mail messages or newsletters to determine whether messages have been opened and acted upon. We use this information to customize our services for you, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities.
such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Machine Learning and Artificial Intelligence: Paper Culture uses both anonymous and Personal Information as data inputs into machine learning and artificial intelligence applications. This means that this data is used to teach our applications how to learn to automatically apply insights provided by data to improve some aspect of the business or user experience. Examples where machine learning and artificial intelligence are used include: automatic optimization of photo quality, automated bots for customer service, and automatic optimization of advertising and marketing programs.
Local Device Storage: Paper Culture will at times place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (“Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to control the display of ads, to track usage patterns, the movements of individual users, and your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer Paper Culture. For example, if you register on any part of Paper Culture and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your personally identifiable information, which may be shared with our parent, subsidiaries, and affiliates and other companies.
Information collected by third parties: We may allow third parties to display advertisements on our websites. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness. Our website does not provide any Personal Information to these third parties. While we cannot stop third parties from advertising to you, you can opt out of receiving ads from members of the Network Advertising Initiative that are tailored to your web preferences and usage patterns, by visiting the Network Advertising Initiative opt out page.
We maintain a list of third parties who collect information on our site to provide services that Paper Culture has requested here.
Tell a Friend Programs: If you choose to use our tell-a-friend or similar service, we will ask you for information needed to send the message, such as your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. We store this information to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact us at [email protected] to request that we remove this information from our servers.
California Consumer Protection Act:
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.
Right to Know
If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
• The specific pieces of personal information we have about you;
• The categories of personal information we collected, sold, or disclosed for a business purpose about you within the last 12 months;
• The categories of sources from which the personal information was collected;
• The purposes for which the information was collected or sold; and
• The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. To submit a request to receive your report you may email [email protected], fill out our web form, call toll free at 1-877-772-8588, or mail your request to Paper Culture Privacy Officer, 475 El Camino Real Ste 202, Millbrae, CA 94030, USA. If we need additional information to verify your identity, we will contact you to request that information, which may include personal information about you or information about your past purchases or use of Paper Culture's products or services. If we deny your request, even if only in part, we will explain the reason in our response.
Right to Data Portability:
Data portability is the ability to move data from one company to another (for instance, when you transfer your mobile phone service to another carrier). While this right is not very applicable to Paper Culture's current business, we will provide you with an electronic file with your most basic account information, should you request it. To submit a request to get a record of the information we store you may email [email protected], fill out our web form, call toll free at 1-877-772-8588, or mail your request to Paper Culture Privacy Officer, 475 El Camino Real Ste 202, Millbrae, CA 94030, USA.
Right to Delete:
If you are a California resident, you may submit a verifiable request for us to delete the personal information we have collected about you except those that are required for legal and accounting purposes such as the paying of tax on previous transactions. The deletion of a Paper Culture account is permanent and cannot be reversed. We may retain personal information necessary to: (a) protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) necessary for us, or others, to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so we can provide our services to you. To submit a request to delete information you may email [email protected], fill out our web form, call toll free at 1-877-772-8588, or mail your request to Paper Culture Privacy Officer, 475 El Camino Real Ste 202, Millbrae, CA 94030, USA. If we need additional information to verify your identity, we will contact you to request that information. If we deny your request, even if only we will explain the reason in our response.
Right to Opt-Out:
California residents may opt out of the “sale” of their personal information, as defined by the CCPA. This does not include when:
• You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information;
• We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information;
• Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
• We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.
Right to be Free from Discrimination:
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
California Shine the Light Law
Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with unaffiliated third parties for their own direct marketing purposes.
Do Not Track
Your Public Feedback
We may provide areas on our websites where you can post information about yourself and post Feedback and Reviews of products and designers. Such Feedback and Reviews are governed by our Terms of Service. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose Personal Information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so it is very important that you do not put personally identifiable or other private information in your posts. Once you have posted information, you will not be able to edit or delete such information.
Paper Culture does not target its website to children, and we will not knowingly collect personally identifiable information from children without obtaining prior verifiable parental consent. If we become aware that a registered user is under the age of 18 and has registered without prior verifiable parental consent, we will remove their personally identifiable information from our files.
Our center of operation is in the United States. Your transactions are processed in US Dollars on servers in the United States. As such, all data is held in accordance with United States laws and procedures which differ from those in other regions of the world, such as the European Union. By using this service, you acknowledge that you understand and agree to these data policies.
Transfer of Information
Confidentiality and Security
We use a secure server (SSL) to encrypt all of your credit card and payment information and we have other physical, electronic, and procedural safeguards to protect the security and confidentiality of the Personal Information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you. There are legal reasons why we cannot delete certain information like transaction information due to the need to keep accurate tax records;
The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you. Due to the processing intensive nature of such a request we do request up to 40 days to provide this data. We aspire to provide it more quickly than that;
The right to data portability – that’s a right for you to ask us for a copy of your personal data in a downloadable format;
The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you including but not limited to a government issued photo identification and confirmation of access to your account. This information is necessary to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Access to Your Account Information and Preferences
You have the right and ability to edit your Paper Culture member account information, including your marketing preferences, at any time. To do so email us at [email protected] with your email address and contact information. Alternatively, you can write to ATTN: Privacy; Paper Culture LLC; 475 El Camino Real Suite 202; Millbrae, CA 94030; or you can call us from the United States at: 1-877-772-8588 or internationally at 1-650-249-0800.
We reserve the right to send you certain communications relating to the Paper Culture service, such as service announcements and administrative messages, that are considered part of your Paper Culture account membership, and all account holders will continue to receive those messages.