Effective February 7, 2022
- Visit our website at netlok.com
- Use Photolok®, Netlok’s image-based innovative identity and authentication software
- Engage with us in other related ways – including any sales, marketing, or events
- “Website”, we are referring to any website of ours that references or links to this policy
- “Services”, we are referring to our Website, and other related services, including any sales, marketing, or events
- “Photolok”, we are referring to Netlok’s innovative image-based, identity and authentication software
This policy contains:
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Personal Information you disclose to us.
Summary: We collect personal information that you provide us.
“Personal information” is data that can be used to identify or contact a single person. We collect personal information that you voluntarily provide us when you register to use Photolok, express an interest in obtaining information about us or our products and services, when you participate in activities on the Website or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us, the Website, use of Photolok, the choices you make, and the products and features you use. The personal information we collect may include the following:
Personal Account Information Provided by You. In creating your Photolok account, you will only be asked to provide and verify your first name, last name, text cell number, and email address. These four pieces of personal information are generally available and, most commonly, appear on business cards.
Payment Data. We may collect data necessary to process your payment if you sign on to services, such as your payment information number, and the security code associated with your payment instrument. All payment data is stored by Netlok’s payment processor.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected.
Summary: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Website or use Photolok.
We automatically collect certain information when you visit, use, or navigate the Website and use Photolok. The information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, location, information about how and when you use our Website or Photolok and other technical information. This information is primarily needed to maintain the security and operation of our Website and the Photolok service, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes log and usage information. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and the Photolok service and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information such as system activity, error reports, and hardware settings) and activity and interaction with Photolok services.
Summary: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our obligations, and/or your consent.
We use personal information collected via our Website and the Photolok service for a variety of business purposes described below. We process your personal information for the purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third-party account, we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
- To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested services.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of the Services.
- To protect our services. We may use your information as part of our efforts to keep our Website, Photolok, and other products safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
- To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage orders. We may use information to fulfill and manage your registration and payments made through the Website or other registration processes.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Request feedback. We may use your information to request feedback and to contact you about your use of our Website, Photolok, or any Netlok products.
- To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting testimonials, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
- For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, Photolok, other products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.
We do not sell or give away your information.
Summary: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a contract. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we have no ongoing legitimate need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Summary: We aim to protect your personal information through a system of organizational and security measures. It is your obligation to keep your photos protected and not share or show them with anyone.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process or maintain. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website and Photolok program/app is at your own risk. You should only access the Website and Photolok program/app within a secure environment.
It is critical, and a key part of the security system, and your obligation to keep the identity of your photos protected and ensure that they are not shared with or shown to anyone.
Summary: You may review, change, or terminate your account at any time.
If you a resident in the European Economic Area (EEA) or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
If you are a resident in Switzerland, the contact details for the data protection authorities are available here:
If you have questions or comments about your privacy rights, you may email us at:
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website, Photolok, and other products and services.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to end you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may click the link at the bottom of the communication.
Opting out of alerts: The Photolok Program/app includes a default setting that notifies you when someone has gained access to your account. While this feature is an important security component of the program/app, you can choose to disable that function by going to your settings page and unclick the “Send Photolok Alert” box in the Security Alert Choices section in the upper left part of the page.
Summary: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provide below.
If you are under 18 years of age, reside in California, and have a registered account with Photolok, you have the right to request removal of unwanted data not critical to the operation of your account. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.). Please send your requests to:
Note: If your account is operating under a Master Contract, we must inform the Master Contract Administrator before removing any data covered by the Master Contract. You may want to contact your Master Contract Administrator before making your request.
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
- Every individual who is in the State of California for other than a temporary or transitory purpose, and
- Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents”.
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
1. What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Information Collected? Type Collected Personal information categories listed in the California Customer Records statute Name, contact information, education, employment history and financial information Yes Name, email address, security questions Identifiers Contact details, such as real name, alias, postal address, telephone or mobile number, unique personal identifier Yes Mobile number, security questions Audio, electronic, visual, thermal, olfactory, or similar info Images and audio, video or call recordings created in collection with our business activities Yes Images Protected classification characteristics under California or federal law Gender and date of birth No None Commercial Information Transaction information, purchase history, financial details and payment information No None Biometric information Fingerprints and voiceprints No None Internet or other similar network activity Browsing history, search history, online behavior, interest data, interactions with our and other websites, applications, systems and advertisements No None Geolocation data Device location No None Professional or employment-related information Business contact detail in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us No None Education information Student records and directory information No None Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics No None
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our services and to respond to your inquiries.
2. How do we use and share personal information?
If you are using an authorized agent to exercise your right to op-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.
3. Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Netlok, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose since its founding. Netlok, LLC will not sell personal information in the future belonging to Website visitors, users, and other consumers.
4. Your rights with respect to personal data.
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information;
- The categories of personal information that we collect;
- The purposes for which the collected personal information is used;
- Whether we sell your personal information to third parties;
- The categories of personal information that we sold or disclosed for a business purpose;
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to non-discrimination for the exercise of a consumer’s privacy rights.
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purpose of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent to verify and provide information on your account as stated in the terms and conditions of the Master Contract.
Other privacy rights
- You may object to the processing of your personal data
- You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the data.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
- If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.
To exercise these rights, you can contact us by email at firstname.lastname@example.org , by calling Anthony Perez at 808-717-9898, by visiting www.netlok.com, or by referring to the contact details at the bottom of this document. If you have any complaint about how we handle your data, we would like to hear from you.
Summary: Yes, we will update this policy as necessary to stay compliant with relevant laws.
If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.
If you have questions or comments about this Policy, you may contact us by calling 408-909-9252, by email at email@example.com, or by mail to:
C/O Anthony Perez
1171 Crestline Drive
Santa Barbara, CA 93105
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To review, update, or delete your personal information, please send an email to: firstname.lastname@example.org.
If your membership is part of a Master Contract, please contact the Master Contract Administrator first because the Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.