Pixlr

PRIVACY POLICY - USERS AND VISITORS

We hereby inform you on Our current privacy policies (including our Children’s Privacy Policy below) and practices applicable to the processing of your personal data (“Personal Data”) collected by 123RF Limited (“123RF”, “Our”, “We” or “Us”) through the websites, accounts.inmagine.com and pixlr.com (the “Website”).

Essential Information

123RF Limited is part of the Inmagine Group and the Website is being operated by Inmagine Group for the Sign Up of Pixlr’s users.

For any general queries you may contact Us at: info@pixlr.com.

What does this Privacy Policy cover?

This Privacy Policy generally describes, inter alia, the Personal Data We may collect from you, the processing of such Personal Data and your rights in relation thereto.

Information We may collect from you

The term Personal Data refers to the data you provide to Us through the Website and may vary depending on the type of relationship you have with Us. Personal Data include:

Browsing data

The information systems and software procedures used to operate this Website acquire personal data as part of their standard functioning. The transmission of such data is an inherent feature of Internet communication protocols. This data category includes, among other things, the IP addresses and/or the domain names of the computers and terminal equipment used by any user, the location of the devices, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.) and other parameters related to the users’ operating system and computer environment.

Registration profile

If you decide to create an account on the Website, you may be required to provide Us your Personal Data such as name, e-mail address, country and encrypted password with the submission of the registration form.

Financial information and billing details

If you purchase or subscribe any of Our products and/or services, you will also be required to provide Us Personal Data related to payments and billing, including card number, card holder name, card expiry date and CVC/CVV/CID. We do not store credit card details. Upon the completion of the purchase of Our products and/or services, We collect transaction details from the payment gateway provider only.

Details under the “Contact Us” section

When you contact Us through info@pixlr.com, creators@pixlr.com or legal@pixlr.com, you may be required to provide Us your Personal Data such as name, email address and, at your own discretion, other information you decide to share with Us, that We may collect from you.

Cookies

We use cookies and similar technologies or tools to collect information about your activities on Our Website, including to use social media features or services on Our Website which may enable you to connect with Our social media page or share any promotional activities with your friends and social networks. Detailed information on the cookies We use and the purpose for which We use them are set out in Our Cookie Policy.

How do We use your information and why?

Your Personal Data will be collected and processed for the following purposes:

Categories of data: Purposes of processing Legal basis:
Browsing data To extract statistical information on service usage (most visited pages, visitors by time/date, geographical areas of origin, etc.) and to check the functioning of the services. Legitimate interest of the data controller to analyse and improve the performance of its services and to prevent crimes and frauds
Registration/creation of the profile To process the creation of your account and profile on the Website and to provide or allow you to access certain areas, functions (e.g., processing the contents submitted by you and displaying your contents on Our Website) and features of Our Website. Consent
Biographical data, financial information and billing details To provide you with the products and/or services you purchased or subscribed to, as well as processing transactions and payments in connection therewith. Execution of the agreement
For administrative purposes connected with the performance of the commercial relationship with you or the fulfillment of legal requirements (e.g., accounting or tax requirements) or for complying with any requests from the competent authorities. Compliance with a legal obligation to which We are subject or, in the event there is no such legal obligation, Our legitimate interest to keep adequate records in connection with the execution of the commercial relationship
To share the Personal Data with the relevant holding company, subsidiaries and related companies of 123RF (“Group Companies”) (within/outside the European Economic Area (EEA)) for internal administrative and accounting purposes. Legitimate interest for transmitting Personal Data within the group of undertakings for internal administrative purposes, including the processing of customers’ Personal Data
Account and contact details To contact you with information about current or new products, commercial opportunities, promotions and services or events sponsored by us that may be deemed to be of interest to you, as well as to verify customer satisfaction and to carry out market researches, analysis and surveys, and also to allow you to participate into prize contests, rewards, trips and/or receive gifts. Consent/Processing in furtherance of Our legitimate interests (including, administering Our operations, promotions and providing you with requested product or service information
To respond to your queries and questions and to provide any information you require (e.g., information and suggestion about products) in the “Contact Us” section. Consent

The submission of your Personal Data is not mandatory. Any refusal to provide the consent will not have any effect other than Our inability to provide you the products and/or services. In such situation, We shall not be liable for any losses, liabilities and damages whatsoever and howsoever arising thereof.

At any time, you have the right to withdraw your consent.

Information We may share and data recipients

Your Personal Data is processed by Our personnel and, if necessary or functional to fulfilling the purposes indicated above, your Personal Data may be processed by third parties that may be appointed by Us as data processors.

The categories of recipients to whom your Personal Data may be disclosed to are as follows:

a. third parties such as (i) IT providers; (ii) financial institutions or payment gateway providers in connection with the processing of financial and payment information; (iii) marketing agencies to carry out marketing campaigns, surveys and promotions; (iv) legal, accounting, tax, labour consultants and other professionals; and (v) the Group Companies; and

b. public entities and authorities, for the purpose of fulfilling legal and regulatory obligations.

In the event We use third-party service providers to make Pixlr available, we ensure that they comply with applicable laws.

Under certain circumstances, your Personal Data may be transferred to other Group Companies outside to the European Economic Area (EEA). In such cases, We ensure that We have adopted appropriate safeguards, including binding corporate rules or standard data protection clauses adopted by the European Commission, in order to guarantee the data subjects with an adequate level of protection.

Retention of your Personal Data

Data are retained as long as necessary for the performance of the services provided by the Website and to comply with legal obligations (including, auditing or taxation purposes), to meet regulatory requirements, resolve disputes, maintain security, and/or to prevent frauds and abuse.

In relation to Personal Data of your profile, We will retain the same as long as your account with Us is still active. If you choose to close the account or if your account is closed, We will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed and your Personal Data and information will be deleted within thirty (30) days thereafter . This is without prejudice to Our right to retain the information (such as username and transaction details) to comply with legal obligations, prevent frauds and protect Our legal interest.

In case you have given your consent to receive information on Our marketing activities, your Personal Data will be retained for a commercially reasonable period, and for as long as necessary to fulfill the purpoises for which the Personal Data and information was collected and as permitted or required by law.

Security

We treat the security for all information submitted or provided by you to Us seriously and is of importance to Us. We will take reasonable steps to protect or secure this data, including Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing and etc). You are also advised not to disclose and secure your own username and password.

Your Rights

You have the right to obtain from Us confirmation whether your Personal Data are being processed by Us, and, in said circumstances, you have the right to request access to and rectification or erasure of the same or restriction of processing, on payment of a prescribed fee, and to object to the processing at any time, as well as under certain circumstances the right to data portability. With respect to the data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of said data.

If you have subscribed to or opted-in to receive Our marketing communications you can opt-out at any time through the “Settings” section, requesting that your Personal Data not be used for marketing purposes.

You may exercise any of the above rights by contacting Us at info@pixlr.com.

In the event of a breach of applicable EEA data protection laws you have also the right to file a complaint with the competent data protection authority.

Links to Third Party Website(s)

Our Website or any products/services being rendered to you may contain links to other websites that are not operated by Us and whose privacy practices may differ from Us. If you click on a third-party link, you may be directed to the thirdparty website. Any submission of your Personal Data to any of those third-party websites will be governed by the relevant third-parties’ privacy policies. We have no control and shall not assume any responsibilities howsoever arising thereof and We strongly advise you to carefully read the privacy policies prior to the disclosure of any information.

Advertising

We may, from time to time, partner with a third party to display Our or a third party’s advertisement(s) on Our Website or engaging third party to manage Our advertising on Our Website. For more detailed information, please refer to Our Cookie Policy.

Mobile Applications or Mobile Website

We may provide Our products or services to you via our mobile applications or mobile website that is designed to be used on mobile computing devices (the “Applications”). You may be required to log in to Our mobile applications or mobile website with your username and password in order to allow you to associate with the user account you have created on Our Website. The processing of Personal Data information therein will also be governed in accordance with this Privacy Policy and Our Cookie Policy.

In addition to the above, you may opt-out of personalised advertising by adjusting the settings on your mobile device.

Please be aware that such an opt-out will disable all personalised ads on applications which use IDFA and Google Android Advertising ID. This does not mean you will not see advertisement. You will see advertisements that are not personalised to you.

Contact Us

If you: (i) have any questions, queries, inquiries or comments on Our Privacy Policy; (ii) have any concerns about how We process your Personal Data; (iii) would like to opt out of direct marketing activities; (iv) would like Us to update information or preferences you have provided to Us; or (v) have any other issues relating to this Privacy Policy, you may get in touch with us at info@pixlr.com.

Changes to this Privacy Policy

We will keep this Privacy Policy under regular review, and We may update this Privacy Policy from time to time. The updated version shall apply and supersede all previous versions. Hence, it is advisable that you check this Privacy Policy on a regular basis.

CHILDREN’S PRIVACY POLICY (PIXLR FOR EDUCATION)

This Children’s Privacy Policy explains Our information collection, use, consent practices, disclosure and retention with respect to personal data (“Personal Data”) provided by the child (“Child” or “Children”) through the websites of accounts.inmagine.com and pixlr.com (the “Website”).

This Children’s Privacy Policy is in accordance with the United States Children’s Online Privacy Protection Act (“COPPA”) and the European Union’s General Data Protection Regulation (“GDPR”), and outlines our practices in the United States and the European Union regarding Children’s Personal Data.

Essential Information

For the purposes of processing of the Personal Data relating to Children on the Website, the relevant Inmagine Group entity acting as data controller is 123RF Limited. “Our”, “We” or “Us” in this Children’s Privacy Policy shall mean 123RF Limited.

For any general queries you may contact Us at: education@pixlr.com.

Personal Data We May Collect from the Child

The term Personal Data refers to the data the Child provides to Us through the Website including:

Browsing Data

The information systems and software procedures used to operate this Website which acquire Personal Data as part of their standard functioning. The transmission of such Personal Data is an inherent feature of Internet communication protocols. This Personal Data category includes, among other things, the IP addresses and/or the domain names of the computers and terminal equipment used by the Child, the location of the devices, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.) and other parameters related to the Child’s operating system and computer environment.

Registration Profile

If a Child decides to create an account on the Website, We require the Child to provide Us the following information such as name, school name, location, level of education, e-mail address, country and a password which shall be encrypted.

Photos and Content

Our service involves photo editing products and the Child may include photographs of themselves (or other individuals) onto the product and stored locally within the web browser. We do not upload nor store any photographs or content nor make any of the content accessible to the public.

How We Collect the Personal Data

We use cookies and similar technologies or tools to collect information about the Child’s activities on Our Website, including using social media features or services on Our Website which may enable the Child to connect with Our social media page or share any promotional activities with their friends and social networks. Detailed information on the cookies We use and the purpose for which We use them are set out in Our Cookie Policy (https://pixlr.com/cookie-policy).

How We Use the Personal Data

The Personal Data will be collected and processed for the purposes as stated in Our Pixlr Privacy Policy as stated above. We will not use the Personal Data for any purposes other than those authorised under the Pixlr Privacy Policy.

How do We Get Consent from Teachers and School Administrators for School-Based Activities

We allow teachers and school administrators to consent instead of parent(s) or legal guardian(s) for the collection of Personal Data from the Child with respect to their school-based activities.

How Teachers and School Administrators Access, Change or Delete the Personal Data of the Child

Teachers and school administrators may at any time access or make changes to the Child’s account or personal information the We have collected online from the Child.

At any time, teachers and school administrators can also refuse to permit Us to collect further Personal Data from the Child, and can request that We delete from Our records the Personal Data We have collected in connection with that account.

Teachers and school administrators can request access to, change and/or delete the Child’s Personal Data by contacting Us at education@pixlr.com. For the Child’s protection, We may need to verify the identity of the teacher or school administrator before implementing any request of access, change or deletion of the Personal Data of the Child.

How Teachers or School Administrators Raise Other Questions or Concerns

If teachers or school administrators have any questions or concerns about the Child’s use or the Website, We encourage the teachers or school administrators to contact Us at education@pixlr.com.

Disclosure of the Personal Data and Data Recipients

We will only disclose the Personal Data in accordance with Our Pixlr Privacy Policy as stated above. We will not disclose the Personal Data for any purposes other than those authorised under the Pixlr Privacy Policy.

Retention of The Personal Data

The Child’s Personal Data will be retained in accordance with Our Pixlr Privacy Policy as stated above.

If the Child chooses to close the account or if the account is closed, We will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed and the Personal Data and information will be deleted within thirty (30) days thereafter.

Security

We treat the security of all Personal Data submitted or provided by the Child to Us seriously and of utmost importance. We shall take reasonable steps to protect or secure the Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing and etc). Children are advised to not disclose and to keep secure their own username and password at all times.

Contact Us

If the Child and/or the teacher or administrator may have any other issues relating to this Children’s Privacy Policy, the Child and/or the teacher or administrator may get in touch with us at education@pixlr.com.

Changes to this Children’s Privacy Policy

We will keep this Children’s Privacy Policy under regular review, and may update this Children’s Privacy Policy from time to time. The updated version shall apply and supersede all previous versions.

Last updated: 9 October 2020