(Last updated March 6th, 2020)
All personal data collected from this site complies with the principles of the EU GDPR data protection act and the California Consumer Protection Act CCPA. By accessing this site you agree to the terms of this privacy policy and consent to the collection, processing, use or transfer of data as set out in this policy.
For the purpose of the processing personal data, we may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of CSV USA, Inc.. In such cases, we shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of and applicable European Union legislation. Shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, we shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
This privacy policy covers CSV USA, Inc. and its subsidiaries including (collectively, "CSV USA, Inc.," "we" "us" or "our"). CSV USA, Inc. and Papzzy.com is an online platform for photographers, where photographers will register and upload photos of clients on the platform including assigning a specific code for all clients. If you are a professional photographer or just an amateur photographer who wants to start selling your work to build reputation then papzzy.com is for you.
By using our website or the CSV USA, Inc. Mobile Application, you signify acceptance to the terms of this Privacy Policy. Where your acceptance via clicking on [ACCEPT] when this policy is displayed to you, is considered as your official consent to process your personal information, your consent to the collection, use, and disclosure of your personal information as described further below. We may request you to provide additional disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.
If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of CSV USA, Inc. website and its related services.
“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
CSV USA, Inc. may collect two (2) types of information about you: personal and non-personal.
According to the federal personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to CSV USA, Inc. is considered personal information it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you. If information cannot be related to an identifiable individual it is considered anonymous. Whenever possible, CSV USA, Inc. works with anonymous information. This privacy statement does not apply to anonymous information.
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). CSV USA, Inc. may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
While you are able to visit the CSV USA, Inc. site and remain anonymous, CSV USA, Inc. or its third party service providers may still collect non-personal information about your use of the CSV USA, Inc. materials (e.g. Your internet browser, operating system, ip address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:
You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.
Information you provided directly: When you sign up for an account or use the Services, you provide account and transaction related information through your account. These may include your profile information, Client’s name, email and photos, your communication preferences. For Clients, these may include billing/shipping information provided when purchasing from a gallery.
Information from your use of the site and Services: When you visit the website or use the Services, we collect information of your activity and usage from your interaction with the site. These may include your IP address, browser and device information, timestamps of your interactions on the site. These information is mainly collected automatically using cookies or other similar technology. You can read more about our Cookie Policy here.
Information from other sources: We may collect information from other services such as third party service providers, payment processors, or advertising services. These may include device and location information, limited information on your card used for payment, prior visits to our website, or whether you opened an email campaign.
We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, and basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our cookie policy.
We receive and store certain types of information automatically, such as whenever you interact with or use CSV USA, Inc. website. This information helps us address customer support issues, improve the performance of CSV USA, Inc. platform, providing you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
For example, we may automatically receive and record the following information on our server logs:
We may also use identifiers to recognize you when you access our website or App via an external link, such as a link appearing on a third party site
We may use your data for the following purposes:
We may use algorithms and other automated means to implement any of the above.
If you have provided your consent by accepting Targeting Cookies on the site, we may use Google AdWords (remarketing and Similar Audience features) and Facebook Ads. You can review the CSV USA, Inc. cookie policy which includes details on how to customize your cookie settings.
Google AdWords enables Google, through the use of cookies, to identify the fact that you have visited the website and App, to identify aspects of your usage of the site and combine that with what it knows about your usage of other website in the Google ad network.
We use these services to advertise to visitors of Google ad network Apps who have previously visited our website and app or who Google deems to have shared interests with visitors of our website or App. Google’s collection and use of your personal data is covered by the Google privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page.
We share data with third parties as follows: With your consent we may share your data with third parties where we have obtained your express consent to do so. You may revoke these consents.
CSV USA, Inc. may occasionally send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
As noted above, you may limit advertising tracking using advertising identifiers through your mobile device’s privacy settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
Legal Bases for Processing your Information:
For individuals who are located in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where the processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect CSV USA, Inc. IM App or your, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
We enable you to make numerous choices about your data:
CSV USA, Inc. complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. We do not knowingly request to collect personal information required for CSV USA, Inc. user account from any person under the age of 13.
Please notify us if you know of any individuals under the age of 16 using our Premium Services so we can take action to prevent access to our Services.
As part of providing the Services to you, your personal information might be transferred, stored or processed in a country other than where you are located. CSV USA, Inc. will ensure the transfers will be completed in compliance with mechanisms that is recognized under the relevant Data Protection Legislation as providing an adequate level of protection for data transfers. Specifically for residents of the EEA, we will ensure the data transfer is completed in accordance to the Standard Contractual Clauses (EU Model Clauses) and U.S. Personal Information Protection and Electronic Documents Act (PIPEDA).
Our Estonian based company, CSV USA, Inc. OÜ, is the publisher of CSV USA, Inc. website, confirms its compliance with the EU-US Privacy Shield Framework. We are committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.
CSV USA, Inc. does its best to process personal information it receives under the standards of Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party that is not also certified under the EU-US Privacy Shield Framework, CSV USA, Inc. will enter into a written agreement that the third party provides at least the same level of privacy safeguard as required under those Frameworks, and assures the same level of protection for the personal information as required under applicable data protection laws.
Worldwide data subjects with inquiries or complaints relating to CSV USA, Inc. Privacy Shield internal policy should first contact CSV USA, Inc. by filling the CONTACT US form provided in www.pappzycom. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, i.e. the International Centre for Dispute Resolution ("ICDR").
CSV USA, Inc. adheres to the seven privacy shield principles of notice, choice, and accountability for onward transfer, security, data integrity, access, and recourse, enforcement and liability as they relate to personal data. CSV USA, Inc. verifies compliance to the principles through self-assessment. The privacy policy covering human resources data can be accessed on our intranet app site by all employees.
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
CSV USA, Inc. takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) CSV USA, Inc.’ data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where CSV USA, Inc. stores personal information. All CSV USA, Inc. employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of personal information.
The CSV USA, Inc. contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, CSV USA, Inc. may use third parties to provide components of the CSV USA, Inc. contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of CSV USA, Inc. (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such App; and (c) does not make any warranties or representations about the contents, products or services offered on such App or the security of any information you provide to them
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, CSV USA, Inc. do not monitor or take any action with respect to these signals or other mechanisms.
By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).
We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available.
Our data centers and those of our partners utilize modern physical security measures to prevent unauthorized access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is CSV USA, Inc.’ policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United States (or other countries) based upon the following legal frameworks:
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
If you are an EU resident and CSV USA, Inc. is processing, and/or transmitting your personal data, then you - as an “EU data subject” – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):
Right to Object: you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us info@papzzy.com. You can also change your marketing preferences
You can also exercise the rights listed above at any time by contacting us at info@papzzy.com.
If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, his email is info@papzzy.com
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at info@papzzy.com. We will process your request within a reasonable time after receipt.
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to info@papzzy.com. Please note that if you opt out in this manner, certain aspects of the App and platform may no longer be available to you. We will process your request within a reasonable time after receipt.
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance ("EDAA"). You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. EU residents who have provided their consent to our use of cookies and similar technologies can use the EDAA’s opt out tool
California residents are entitled to ask us for a notice identifying the categories of Personal
Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: info@papzzy.com
If you are a resident of the European Economic Area, please see the section below headed “Additional Information for users in the European Economic Area” for further information about your privacy rights.
If you are a California resident who has provided us with your Personal Information during the creation of or during the course of establishing a relationship that is primarily for personal, family, or household purposes, you may, once per calendar year, request information regarding our disclosure of certain categories of your Personal Information. Specifically, pursuant to California Civil Code 1798.83 (the “Shine the Light” law), we will provide you a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. You must submit your request to us either by our e-mail address
Where you believe that we have not complied with our obligations under this Privacy Notice, or the applicable law, you may have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have and CSV USA, Inc. will respond in line with our complaints procedure – our contact details are set out in the contact us section below.
We want to deal with your concerns fairly, effectively and promptly. However, some complaints are more complex than others and may take some time to investigate.
In order to assist in the speedy resolution of any complaint you may have, it’s important that we understand your complaint fully. Sometimes this means we may ask you to address your concerns to us in writing. This can be either by email or post to the addresses. We have established internal procedures for investigating any complaint, which may also involve experienced members of staff from CSV USA, Inc. Companies considering or investigation the complaint. Where appropriate, the complaint will be dealt with by someone who was not directly involved in the matter which is the subject of your complaint. The member of staff will either have authority to settle your complaint or will have ready access to someone who has the authority. Our response will fully address the subject matter of your complaint and, if appropriate, will offer redress. If you phone us during our investigation and the member of staff handling your complaint is not available, then another member of our team will try to assist you.
Unless applicable data protection laws require responses within shorter timescales, we will try to resolve any privacy complaints you have within 15 business days of receiving your complaint and in exceptional circumstances, within 35 business days (and we will let you know if this is the case).
As noted above, if you are not satisfied with our reply/outcome, or otherwise with the handling of the complaint, you may have the right to lodge a claim before a relevant Data Protection Authority or the courts.
The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the app cannot guarantee that such precautions would render the Site and its servers immune to security breaches.
CSV USA, Inc. continually strives to implement new technologies and processes to better protect you, your privacy and your use of the CSV USA, Inc. service. As a result, changes to this privacy policy may be made by CSV USA, Inc. from time to time. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure, as such measures are described in this privacy policy.
If you have any questions about this privacy policy please contact us at info@papzzy.com