Privacy & Security

1. Introduction

   This Privacy Policy applies to Pictureframes.com (“we,” “our,” or “us”) as related to our services, which collectively include:

   • The use of our website pictureframes.com , as it may be modified, relocated and/or redirected from time to time;

   • The use and participation in social media messages and marketing campaigns, and

   • The use of our products and services.

   This Privacy Policy sets out the details relating to how we handle your personal information, whether collected online or offline, as:

   • A website visitor;

   • An end user of the application (“end user”);

   • A current or prospective client; and

   • A partner

2. Personal Information We Collect

   • 2.1 Information You Choose to Provide to Us

     WHEN

     We may ask you to provide personal information when:

     • You use the website to download articles, data sheets or eBooks.

     • You request a free trial or demo.

     • You refer a friend to us.

     • You connect with us directly via phone calls or video conferencing platforms.

     • We or your organization’s Client Account Administrators grant you access to the application.

     • You or your organization’s Client Account Administrators upload or enter your personal information into the application.

     • You participate in a marketing or sales promotion.

     • You attend trade events and other industry networking events.

     • You register or attend a webinar or other event.

     • You participate in programs we may offer from time to time.

     • You participate in chats.

     • You pay for our services.

     If you choose to provide us with a third-party’s personal information (the person’s name, email and company) when taking part in our referral program, you represent that you have the third-party’s permission to do so.

     WHAT

     • Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers; company name, job title, business email address and department; account information, for example: username and password

     • User Content, for example, content you submit when you contact customer service or otherwise contact Pictureframes.com. This may include recordings you create, including audio recordings or voicemail you submit in connection with customer service.

     • Communications Data, for example, during our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the call or text (SMS or MMS) message and phone numbers.

     • Commercial information, for example, records of products or services purchase and purchasing or consuming histories.

     • Internet or network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data

     • Geolocation data, such as information about your location (at country and city level only) collected from your IP address

     • Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law

     • Inferences, for example, Pictureframes.com might infer based on your purchase history that you would be interested in other products or services.

     • Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

   • 2.2 Information We Collect Automatically

     WHEN

     We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology.

     When you visit our Website, we send one or more “cookies” to your computer or other device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to improve the quality of the Website and services, including to store user preferences, to track user trends, and to provide relevant advertising to you.

     Pixel Tags: We may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of the Website. A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

     WHAT

     The information collected includes:

     • Access times

     • The pages you view

     • The links you click on

     • The search terms you enter

     • Actions you take in connection with any of the visited pages

     • Your device information such as IP address, location, browser type and language

     • The Uniform Resource Locator (URL) of the website that referred you to our website and

     • The URL you browse away from our pages if you click on an external link

     We may also collect information when you open email messages from us or click on links

     Tracking Across Time and Different Sites

     The Site tracks your online activities over time and across websites or online services on an individually identifiable basis. For example, we may serve you advertisements on other websites based on what appeared to interest you on our Site. We do allow third parties to use our Site to track your activities over time or across other websites.

   • 2.3 Other Categories Of Sources From Which We Collect Your Personal Information

     • Service providers for example analytics providers, IT, and system administration services
     • Affiliated companies for example, other companies in the Circle Graphics family of companies may share your personal information with us to help us provide you with products or services that meet your needs.
     • Marketing/advertising companies for example, from social media platforms, consumer research companies, and analytics or marketing/advertising companies.
     • Recording technologies installed by Company for example, voicemail and other audio recording technologies with consent to the extent required by law.

3. Purposes For Which We Use Your Personal Information

   We use your personal information to:

   • Deliver the contracted services and allow full use of the application functionality as purchased by the clients.

   • Deliver training and support to our application end users.

   • Carry out the transactions you have requested.

   • Process payments for application purchases.

   • Send communications to you through emails, calls, chats and video conferencing about:

     • New application features and upgrades.

     • Our services and offerings.

     • Event announcements.

     • Product notices and changes to our terms and policies.

     • Particular programs in which you have chosen to participate.

     • Promotional offers and surveys.

     • Scheduling demos and managing free trials.

   • Advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.

   • Carry out market research to understand how to improve our products and services and their delivery.

   • Create and manage marketing campaigns.

   • Create and manage marketing campaigns.

   • Generate sales leads and increase our market share.
   • Analyze user clicks and usage of the application and website to improve user experience and maximize usage of our services.
   • Manage our website and application to maintain and deliver the contracted functionality and services.
   • Enforce our website and application terms and/or separate contracts (if applicable) with you.
   • Prevent fraud and other prohibited or illegal activities.
   • Protect the security or integrity of the website, application, our business or services.
   • Protect our rights, property, or safety, as well as the rights, property, or safety of yours and others.
   • Report suspected criminal conduct to law enforcement and cooperate in investigations.
   • Exercise our rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
   • Ensure compliance with applicable laws and regulatory obligations.
   • As otherwise, as disclosed to you at the point of collection or as required or permitted by law.

   Please note that sometimes we may record the video conferencing call in which you participate to analyze and improve our staff’s communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page.

   We do not sell your information to any third party for monetary or other valuable consideration. We also do not disclose your personal information to third parties for cross-context behavioral advertising.

4. How We Disclose Personal Information

   Our Applications and Services

   If you are an end user of our applications, your personal information may be viewed by other users with access to the applications.

   Disclosure to Unaffiliated Third Parties

   We may disclose your information for a variety of reasons including, but not limited to, to prevent an emergency, to prevent harm to others, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order). In particular, if you have an account, we may disclose your information to a third party that alleges that you have infringed their intellectual property rights in any way. Similarly, if you allege that another user is infringing upon your intellectual property rights, we may disclose your information to that user.

   Disclosure to Service Providers and Online Partners

   We may contract with various service providers who help us provide, maintain, and improve the Website and the services. For example, we use a service provider to process payments made to us, and may subcontract out production, fulfillment, analytics, reporting or other operations. We also contract with several online partners to help manage, monitor and optimize our Website and services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website.

   Mobile Information Statement

   No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

   Disclosure of Non-Personal Information

   We may disclose your de-identified information, in aggregate form, to potential strategic partners, advertisers, investors, customers, and others. Deidentified information means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. We maintain de-identified information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.

   Internet Advertising

   We may use third party service providers to serve ads on our behalf across the Internet and sometimes on the Website. They may collect anonymous information about your visits to our Website, and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements for goods and services.

   Disclosure to Successors

   If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Website to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

   Your Consent

   In addition to the disclosure described elsewhere in this Privacy Policy, we will disclose personal information with companies, organizations, or individuals outside of Pictureframes.com when we have your consent to do so.

5. How We Secure Personal Information

   We are committed to protecting the security of all of the personal information we collect and use.

   We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to close your browser after you have completed your visit to the Site.

   Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal data.

6. How Long We Keep Your Personal Information

   We retain information as long as it is necessary to provide the services to you and our clients. We also retain your personal information for 12 months after our last interaction with you subject to any legal obligations to further retain such information.

   We may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law. We also retain this information for up to 12 months after our last interaction with you subject to any legal obligations to further retain such information.

   The information we retain will be handled in accordance with this Privacy Policy.
   Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data. This information may provide insights that are commercially valuable to Pictureframes.com, such as statistics of the use of the services.

7. Other Important Information

   We process data in Colorado, California, North Carolina and Missouri and rely on legally provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations. We provide the capability for the return, transfer and/or disposal of personal data in a secure manner.

   We will only collect and process your personal data where we have a lawful reason for its collection.

   When you visit our website and provide us with your personal information, we collect and use it with your consent.

   As an application end user, you consent to our collection of your personal information when you log in for the first time. However, your employer has control of the account and may upload and share additional personal information. Your employer’s responsibility is to ensure that collecting, using and sharing the personal information uploaded to the application complies with all applicable legislation.

   Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at privacy@circlegraphicsonline.com or contact us by mail at

   ATTN: Privacy Officer
   120 9th Avenue
   Longmont, CO 80501

   How to Select your Communications Preferences

   You may choose to receive or not receive marketing e-mail from us. Please click the “Unsubscribe” link, when available in the email we sent you to stop receiving marketing e-mail from us.

   Even if you opt-out of receiving marketing e-mail, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

   Childrens’ Online Privacy Protection Act Compliance

   No Information from Children Under Age 13 If you are under the age of 13, please do not attempt to register with us at the Website or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please email us at privacy@circlegraphicsonline.com or contact us by mail at

   ATTN: Privacy Officer
   120 9th Avenue
   Longmont, CO 80501

   Prospective users between the ages of 13 and 17 can only use the Website and services under their parents or legal guardian’s supervision. If you are between the ages of 13 and 17, you, your parent, or your legal guardian may request that we remove any of your information in our database and/or opt-out from receiving communications from us. If you wish to do so, please Contact Us, email us at privacy@circlegraphicsonline.com or contact us by mail at

   ATTN: Privacy Officer
   120 9th Avenue
   Longmont, CO 80501

8. Changes to this Privacy Policy

   We reserve the right to amend this Policy from time to time and will post such amendments on this page. Therefore, please check back to this page regularly so that you are always aware of our policies concerning information collection. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal data, we will provide a prominent notice of such changes and the effective date of the changes before making them.

9. Contact Information

   You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at privacy@circlegraphicsonline.com or contact us by mail at

   ATTN: Privacy Officer
   120 9th Avenue
   Longmont, CO 80501

Appendix

• A.1 For California Residents

  This section provides additional specific information for California residents as required by the California Privacy Rights Act of 2020 (“CPRA”).

  A.1.1 Notice at Collection

  We collect the personal information identified in Section 2.1 for the purposes identified in Section 3.0 and retains it for the period described in Section 6.0. We do not sell your personal information. We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

  A.1.2 Additional Information Regarding Disclosures Of Personal Information

  The CPRA requires that we provide you with the following information about disclosures of your personal information to third parties for “business purposes” as that term is defined in the CPRA during the twelve months preceding the last updated date of this Privacy Policy:

  Service Providers

  We disclosed your identifiers, commercial information, and internet or other electronic network activity described above to our service providers, including payment processing providers, customer relationship management platform providers, consultants, helpdesk service providers, and website analytics companies for the business purpose of performing services on our behalf.

  Affiliated Companies

  We have disclosed your identifiers, commercial information, and internet or other electronic network activity described above to other companies within the Circle Graphic family of companies for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality of a service.

  We have no actual knowledge that we sell or share the personal information of consumers who are under 16 years of age.

  Sales and Sharing:

  As is common practice among businesses operating online, we may allow third parties to receive information about you via cookies for purposes of analyzing and optimizing our services, supporting live chat, to personalize your online experience by providing advertisements that are more relevant to you, and for statistical research and analytics. We do not “sell” your Personal Information as most people would understand that term, meaning that we do not disclose your Personal Information to any third party in exchange for a monetary payment. However, as is common practice among businesses operating online, we may allow third parties to receive information about you via cookies for purposes of analyzing and optimizing our services, to personalize your online experience by providing advertisements that are more relevant to you, and for statistical research and analytics. These activities may be defined as a “sale” of Personal Information, or as a disclosure of Personal Information to third parties for cross-context behavioral advertising (“sharing”), under the CPRA.

  In the last 12 months, we have disclosed Identifiers, including without limitation name, physical address, e-mail address; Geolocation, and Internet or Other Electronic Network Activity Information, to analytics providers and advertising platforms, and such disclosure may be considered a “sale” or “sharing” of personal information. We disclosed this information in order to enable marketing to you and to deliver targeted advertising on the Site and in other interactions that you have with Pictureframes.com while online.

  e have no actual knowledge that we have sold or “shared” the personal information of children under 16, in the last 12 months and we have no intention to do so.

  Sales of Personal Information:

  Company discloses personal information to third parties for analytical, marketing, and advertising services, which may constitute sales of personal information, as follows:

  Categories of Personal Information	Categories of Third-Party Recipients
  Identifiers	Advertising Networks – to provide advertising better suited to your interests
  Internet Activity Information	Analytics Providers – to better understand our website visitors
  Commercial Information	Advertising Platforms – to provide advertising better suited to your interests
  Geolocation	Advertising Platforms – to provide advertising better suited to your interests
  Audio and Inferences	Analytics Providers – to better understand our website visitors

  Sharing of Personal Information

  Company “shares” personal information with third parties as follows in order to provide you with information about products and services that may be of interest to you:

  Categories of Personal Information	Categories of Third-Party Recipients
  Identifiers	Advertising Networks – to provide advertising better suited to your interests
  Internet Activity Information	Analytics Providers – to better understand our website visitors
  Commercial Information	Advertising Platforms – to provide advertising better suited to your interests
  Geolocation	Advertising Platforms – to provide advertising better suited to your interests
  Audio and Inferences	Analytics Providers – to better understand our website visitors

  A.1.3 California Privacy Rights

  As a California resident, you may be able to exercise the following rights under the CPRA in relation to your personal information that we have collected (subject to certain limitations and exceptions at law):

  • Right to Know: The right to submit a verifiable request to know any or all of the following information relating to your personal information:

    • The specific pieces of personal information we have collected about you

    • The categories of personal information we have collected about you

    • The categories of sources of the personal information

    • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed

    • The business or commercial purposes for collecting, selling or sharing the personal information.

  • Right to Delete: The right to submit a verifiable request for the deletion of personal information we have collected from you, subject to certain exceptions.

  In addition to the rights mentioned above, the CPRA grants California residents with the following additional rights:

  • Right to Correct: The right to request for correction of inaccurate personal information, considering the nature of the personal information and purposes of the processing of the information.

  • Right to Opt-out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information to third par-ties for cross-context behavioral advertising.

  Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

  You also have the right to be free of discrimination for exercising these rights.

  A.1.4 How to Exercise Your California Consumer Rights

  To exercise any of your right mentioned above, please submit a request by contacting us at privacy@circlegraphicsonline.com or contact us by mail at

  ATTN: Privacy Officer
  120 9th Avenue
  Longmont, CO 80501

  We will need to verify your identity before processing your request.

  In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Depending on the risk entailed by the request (i.e., a request for specific pieces of personal information), we may need additional personal information from you to be able to identify you. We will notify you.

  We may decline a request to exercise the right to know, correct, or delete if we cannot verify your identity to a sufficient level of certainty or locate your information in our systems, or as permitted by law.

  We endeavor to respond to a privacy rights request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing. If you submit your privacy rights request electronically, we will deliver our written response to the verified email associated with the request. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  A.1.5 Authorized Agents

  You may choose to designate an authorized agent to make a request on your behalf. The authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. Unless you have provided a power of attorney under the California Probate Code, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.

  Right to Appeal – California

  If we do not take action on your Privacy Rights Request within the 45 days response period, or in the event of an extension, within the maximum 90-day response period, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision.