This Privacy Policy describes the privacy practices of FullPicture.io. (“Full Picture”, “we”, “us”, “our”) on our websites located at the domains Fullpicture.io.com as well as such other websites or mobile applications that we own or operate (individually and collectively, “Our Website” or the “FullPicture Website”).
As further discussed, below, data protection laws, regulations, and directives in certain jurisdictions distinguish between the rights and responsibilities of “Controller(s)” of personal information or data (“Information”), from those who are “Processor(s)” of such Information or data on the applicable controllers’ behalf. Full Picture is generally the controller of Information that it collects from and about the persons and entities who are visiting Our Website (“Full Picture Visitors”), and this Privacy Policy applies to Full Picture Visitors.We also provide certain services to commercial persons and entities (each, a “Client” and collectively, “Clients”), who, in turn, own and operate their own websites or mobile applications (“Client Site(s)”), and who wish to utilize our code, software and services and reports (the “Service(s)”) to analyze how third party visitors to their Client Sites (“Client Site Visitor(s)”) use, interact with, and engage their Client Sites. The applicable Clients are the Controllers of Information collected from their Client Site Visitors, whether or not such information is accessed, analyzed, or otherwise utilized by or on behalf of the Client via the Service (“Client Visitor Information”); Full Picture is not the Controller of such Client Visitor Information. This Privacy Policy applies to the use of Services by our Clients. However, this Privacy Policy does not apply to the Client Sites themselves, nor to any Client Visitor Information. For any questions regarding the privacy, security, or other practices or policies on the Client Sites, please contact the applicable Client.
Information Collected from Full Picture Visitors
We may receive and collect certain Information furnished by the visitor's browser or otherwise by their access device (“Device Information”), such as:
Browser
Operating System
Mobile Device (e.g., device identifier, mobile operating system, etc.)
IP address (stored in anonymized form)
Page Accessed
Geographic Location
Time of visit (by day, week, and duration)
Whether the visitor is a new or return visitor
Other such Information as may be delivered or shared by the applicable browser or access software or device.
Referral Information
We may also receive certain information regarding visitors from the prior website visited by such visitors (“Referral Information”).
For instance, If a Full Picture Visitor navigates to the Full Picture Website from another website, Full Picture may receive certain information from the referring website (i.e., the last website the visitor visited before visiting the Full Picture Website) as part of the Hypertext Transfer Protocol ("HTTP") request. For example, if a Full Picture Visitor navigates to the Full Picture Website from a search engine, Full Picture may receive information contained in the referring URL for the applicable search query, such as the terms the Full Picture Visitor was searching for before visiting the Full Picture Website.
Registration Information from Full Picture
When Full Picture Visitors register as Clients to use the Full Picture Service, register to use a trial version of the Full Picture Service, or request additional information about Full Picture, Full Picture may require Information, such as name, e-mail mailing address, phone number, financial information (e.g., credit card number, billing address), and/or proposed Client Site to be tracked, to process the registration or request ("Client Registration Information").Full Picture’s Use of Full Picture Visitor InformationFull Picture may use Information of Full Picture Visitors, including Device Information Referral Information of Full Picture Visitors and Client Registration Information, to:authenticate Client’s access to the Full Picture Site, trial versions, or Service;process and fulfill Client requests or purchases;register Client accounts;check the Full Picture Visitor’s qualifications for registration and/or to bill Full Picture Clients for the Services.Full Picture may also use Client Information to:provide Full Picture's products and Services, personalize and tailor your experience on the Full Picture Website;operate our business;understand how Clients are engaging with Full Picture Website and Service;request additional information necessary to process or fulfill an order;assess Client satisfaction with the Full Picture Service;inform Clients that an upgrade is available; or to contact Clients with information about Full Picture, including information about new or existing products and services or special offers. For example, we may periodically send promotional materials or notifications related to our products and Services to the email address associated with a registered account.Otherwise for our legitimate business interests.If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Full Picture may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”.
Use of Cookies by the Service
As described in our Cookie Policy, the Service may utilize first-party cookies (small text files that Full Picture stores locally on a Client Site Visitor’s device) on Client Sites for one or more of the following purposes: to help identify whether a Client Site Visitor is a first time visitor, or has visited previously (provided that we will not store identifiers that can be used to personally identify such Client Site Visitors); assess usage patterns and perform traffic analysis; identify preferences; diagnose problems with our Service; analyze trends; and otherwise administer Full Picture products and services. Cookies placed by Full Picture on the computers of Client Site Visitors do not include Personally Identifiable Information such as name, phone number, e-mail address or mailing address, nor does Full Picture link cookies to such Personally Identifiable Information on our servers or databases.For further information on our use of cookies, please see our Cookie Policy, which is incorporated in this Privacy Policy by this reference.
Information Collected by or on Behalf of Our Clients via the Service
Full Picture Clients use the Service to obtain information regarding how Client Site Visitors to their Client Sites are interacting with such Client Sites. This Service allows a Full Picture Client to evaluate and potentially modify its Client Site based on its findings regarding Client Site Visitors use and interaction with the Client Site. Please note that Full Picture itself uses the Full Picture Service to obtain insights into Full Picture Visitors' activities on http://www.fullpicture.io. Accordingly, Full Picture is the Controller of such Information regarding Full Picture Visitors.Types of Client Visitor Information. Full Picture Clients may use the Service to collect, store, and analyze Client Visitor Information, on the Client’s behalf as the Controller of such Client Visitor Information, on Full Picture's servers, as the Client’s Processor of such Client Visitor Information. Such Client Visitor Information is transmitted in encrypted form, and pursuant to applicable data transfer provisions further described below. The Service may process such Client Visitor Information on behalf of the Client, to perform analyses and produce reports for the Full Picture Client. The interactions that may be recorded or analyzed (“Recorded Interactions”) may include mouse scrolls and clicks by a Client Site Visitor; keystrokes entered by a Client Site Visitor; and/or pages viewed or visited by a Client Site Visitor, including the duration of such visits. Recorded Interactions may also include images of the Client Site that are recorded during the Client Site Visitor’s interactions with such Client Site, such as, by way of example, images of forms displayed or populated by the Client Site Visitor on the Client Site, or other multimedia content that may be posted by Client Site Visitors. Such Client Visitor Information may also include Device Information and/or Referral Information from the Client Site Visitor.
Our Clients' Use of Client Visitor Information
Each Client hereby:Directs Full Picture, only in accordance with applicable law to provide the Services as described herein and in the applicable terms of use (collectively, “Terms”);Represents, warrants, and covenants that it will abide by all applicable laws, rules, and regulations applicable to Client Site Visitors and Client Visitor Information, and ensure that any instructions to Full Picture are consistent with, and do not and will not constitute a violation of same;Represents, warrants, and covenants that it has obtained all consents required under applicable laws or regulations for the processing of Client Visitor Information under the Service as described hereunder and in the Terms and as otherwise instructed by the Client; andRepresents, warrants, and covenants that it has and will post an online privacy policy that provides each Client Visitor with notice of its practices regarding data collection, use, and disclosure (including the Client's use of Full Picture), provide a link to the Full Picture Privacy Policy, and provide a link to the Full Picture Opt-out, and that otherwise complies with all applicable laws.
Our Processing of Client Visitor Information
As the Processor of Client Visitor Information, we will process Client Visitor Information only in compliance with the applicable Client’s instructions regarding the processing of Client Visitor Information, including any applicable Terms, but subject to applicable laws and regulations regarding such Client Visitor Information, and as otherwise required by applicable law and regulations.
Full Picture Disclaimers
Regarding Personally Identifying Information of Client Site Visitors.Full Picture's Service is not designed to knowingly collect or extract from Client Visitor Information (including any Recorded Interactions or Device Information received from Client Sites through the Service) information that could be used to personally identify Client Site Visitors, such as a Client Site Visitor’s name, address or phone number ("Personally Identifiable Information") when a Client Site Visitor visits a Client Site that uses the Full Picture Service. In particular, Full Picture does not attempt to identify, decipher, access, or associate Personally Identifying Information regarding a Client Site Visitor from any Recorded Interactions or Device Information, provided that Full Picture may receive Referral Information, as noted above. Full Picture includes tools to enable Clients to preempt the collection of or remove sensitive data from the Full Picture Service, to be set by the applicable Clients as the Data Controllers.
Full Picture Does Not Collect Visitor Information Across Multiple Sites
Full Picture does not collect or aggregate information about visitor behavior on multiple, different websites.
Retention and Deletion of Client Visitor Information
Full Picture will retain Client Visitor Information in accordance with the applicable Client’s instructions, including any applicable Terms and as required by applicable law. Client agrees and acknowledges that the deletion of Client Visitor Information may affect the delivery or performance of the Service. Full Picture will comply with such instructions to delete Client Visitor Information as soon as reasonably practicable and within a maximum period of 180 days, unless applicable laws require retention. Full Picture may retain Client Registration Information as long as necessary for the purposes described in this Privacy Policy and the other Terms. This may include keeping Client Registration Information after the account has been deactivated as needed for Full Picture to pursue legitimate business interests, record keeping procedures, legal compliance, preservation of rights, security purposes, and enforcement of legal and contractual rights.Client agrees and acknowledges that it will be responsible for exporting any Client Visitor Information or Client Registration Information that it wishes to retain following the termination of the Terms.
Full Picture's Sharing and Disclosure of Full Picture Visitor Information and Client Visitor Information
This section describes the manner and extent to which Full Picture may share and disclose Information. Notwithstanding anything to the contrary below or elsewhere herein, as between a Client and Full Picture, the Client is solely responsible for its policies and practices for the sharing and disclosure of Client Visitor Information as the Controller of such Information.Full Picture’s Default Policy Regarding Sharing of Client Visitor Information. Except to the limited extent described otherwise in this Privacy Policy, Full Picture never sells or shares any Client Visitor Information with individuals or companies other than the specific Client from whose Client Site Full Picture collected the Client Visitor Information. This Client Visitor Information is provided to Clients in the form of aggregated reports and/or statistics that identify the collective behavior of Client Visitors to the Client's Site. Clients will also have access to Recorded Interactions through the Service.Full Picture’s Default Policy Regarding Sharing of Client’s Personally Identifiable Information. With the exception of the limited circumstances discussed elsewhere in this Privacy Policy, Full Picture does not provide Clients' Personally Identifiable Information to third parties for any purpose.Disclosure Pursuant to the Client’s Instructions. Full Picture will share and disclose Client Visitor Data in accordance with the applicable Client’s instructions, including any applicable Terms, and otherwise in compliance with but subject to applicable laws and regulations.Subprocessors. We may utilize affiliates or third parties as subprocessors of the Information, to support the Services, and otherwise to support the conduct of our business, to provide, by way of example, service such as computing and storage services. We will use subprocessors subject to contracts that are substantially as protective of Personally Identifiable Information as those contained herein, and, to the extent applicable, in compliance with Article 28(3) of the General Data Protection Regulation. For further information regarding our use of subprocessors, please contact us at privacy@fullpicture.io.Our Affiliates. We may share Information hereunder with our corporate affiliates provided that such affiliates are obligated, contractually or otherwise under applicable laws, to be bound by our obligations with respect to such Information.Change of Control. If Full Picture, or substantially all of its assets, is acquired by another company or successor entity, the Information hereunder will be one of the assets transferred or acquired by the purchaser or successor. You acknowledge that such transfers may occur, and that any purchaser of or successor to Full Picture or its assets may continue to collect, use and disclose your Information as set forth in this policy.Payment Processors. Like many companies that accept payment by credit card, Full Picture relies on third-party payment processors to process financial payments. When you make payments to Full Picture to obtain or use Full Picture's products or services, Full Picture may share Personally Identifiable Information, such as your name, address, and credit card information, with qualified third parties in order to process your order.Law Enforcement/Legal Process. Full Picture reserves the right to disclose any Information (including Personally Identifiable Information): (1) to comply with any law, regulation, or legal request, if and to the extent that we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process; (2) to enforce, apply, or investigate breaches of the Terms or other agreements; or (3) protect the rights, property, user experience, or safety of Full Picture, our employees, our users, our Clients, or others.Aggregated, Anonymized, Pseudonymized, or De-identified Information. We may disclose or use aggregated, anonymized, pseudonymized, or otherwise de-identified Information for any purpose.
Transfer of Data Abroad; International Users
If you are visiting the Our Website or a Client Site from a country other than the United States of America the various communications will necessarily result in the transfer of information across international boundaries. By visiting the Our Website or the Client Site, as applicable, you consent to the processing and transfer of your data as set out in this Privacy Policy. By using the Our Website or the Client Site, as applicable, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.If we transfer Personally Identifying Information from a Client Site in the European Economic Area (“EEA”) to other countries not deemed adequate under applicable data protection law, we will do so in compliance with either: European Union Model Clauses. Full Picture will offer to enter into the European Union Model Clauses, also known as Standard Contractual Clauses, with the Client. To enter into such clauses, please contact us at privacy@fullpicture.io.
Security and Protection of Visitor Information and Client Information
Full Picture implements security mechanisms to protect Visitor Information and Client Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Examples of these security mechanisms include limited and password-protected access, firewalls, and SSL encryption to protect transmission of data, as further described above and in our Terms of Use. For additional questions or information regarding our security standards, please contact us at privacy@fullpicture.io.
Policy Concerning Children Under Age of 16
Full Picture does not knowingly or intentionally collect Personally Identifiable Information from children under 16. If we learn that we have Personally Identifiable Information of a child under age 16, we will remove it. If you believe we have Personally Identifiable Information about a child under the age of 16, please notify us at privacy@fullpicture.io.
Changes to Our Privacy Policy
Full Picture retains the discretion to amend or modify this policy from time to time. Use and disclosure of Information we obtain is subject to the later of: (1) the policy in effect at the time such visitor Information or Client Information is collected or (2) any subsequent policy to which you agree or of which you have notice, if you elect to use Full Picture or a Full Picture Client Site (including the Full Picture Website) following such acceptance or notice. If we make material changes in the way we use or disclose Personally Identifiable Information, we will notify you through one or more of the following means: a direct communication to your Full Picture account, a communication to the e-mail address associated with your account, or a clear and prominent announcement on the Full Picture Website. Your continued access to or use of Full Picture or websites that use Full Picture following notice of material changes to this Privacy Policy shall constitute consent to any amendments and/or modifications.
For More Information / Your Information Rights
Privacy Officer / Notices. Full Picture welcomes any questions or comments about this Privacy Policy or our privacy practices, including regarding any disclosure of third party information for direct marketing purposes. Any such comments or questions should be submitted via e-mail to: privacy@fullpicture.io.Access to Personally Identifiable Information or other Information Stored at Full Picture at any time, a Full Picture Client or Full Picture Visitor may access and/or modify their Personally Identifiable Information or other Information stored by Full Picture on their behalf, to enable them to access, rectify and restrict processing of their respective Information, and allow them to export their Information, by accessing their Full Picture account and contacting us at privacy@fullpicture.io.California Information Rights. Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once per calendar year certain disclosures about the personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of personal information, and the names and addresses of those businesses with which we shared personal information, for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2019 sharing activities). To make such a request, please send an email to privacy@fullpicture.io with a subject line of “Request for California Privacy Information.” Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Do-Not-Track Signals
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Our practices with respect to such signals are set forth in https://www.fullpicture.io/opt-out.