Privacy Notice

Last Modified: June 27, 2024

At Lifetouch, our purpose is to help our customers capture, preserve, and share life’s important moments through professional and personal photography, and personalized products. We are committed to respecting your privacy.

This Privacy Notice (“Notice”) explains how Lifetouch, Prestige Photography by Lifetouch, and JCPenney Portraits by Lifetouch (“Lifetouch,” “we,” “our,” or “us”) collects and uses personal information, and the choices you can make. This Notice applies to your use of MyCollection.Lifetouch.com, Lifetouch.com, Lifetouch.ca, PrestigePortraits.com, JCPPortraits.com, PreschoolSmiles.com, and our other Lifetouch websites, applications and services that link to this Notice. This Notice also addresses information we collect from you when you schedule an appointment to be photographed, when you visit one of our photography studios or onsite photography locations to be photographed, when you make an order, and when you contact or interact with us (such as with one of our customer service representatives, or when you respond to a survey or enter a contest or sweepstakes that we administer).

Our Sites and Apps may be linked on other websites or may contain links to other websites. Our Privacy Notice only applies to our Sites and Apps, and we are not responsible for the privacy practices, security standards, or content of other sites. You should check the privacy policies of those sites before providing your personal information to them.

We encourage you to read this Privacy Notice in its entirety before using our services. By creating an online account, using our services, or making a purchase with us, you acknowledge and consent that you have read and agree to this Privacy Notice. Your use of our Sites and Apps is also subject to our Terms and Conditions.

If you are an educator, parent, or student, and Lifetouch is providing school photography services to your school or organization, please see our section titled For Pre K-12 Educators and Parents. This section explains how Lifetouch collects and uses student information for Picture Day, as well as in connection with websites, applications and online services offered by Lifetouch for the use and benefit of the schools and school districts for their administrative and educational purposes.


• What personal information do we collect? How do we use that information?

We collect various types of personal information when you use any of our websites, mobile sites, or mobile applications (our “Sites and Apps”); purchase any products or services from us; schedule an appointment to be photographed; visit or are photographed at one of our offices, studios, or on-site photography locations; engage with us, such as through one of our customer service representatives or on social media; sign up for notifications or register for customer rewards programs; access emails we send you; or complete a survey or enter a contest or sweepstakes that we sponsor. This information may be collected directly from you (for example, when you complete our forms or enter your information on our websites to make a purchase) or indirectly through your device or browser when you visit our Sites and Apps.

We use your information to fulfill product orders, to customize and improve the advertising and content you see, to offer suggestions for personalized products based on your content, to deliver marketing communications and promotional materials that you may be interested in, to contact you and provide customer service, to protect the security or integrity of our databases or websites, to detect and prevent fraud or illegal activity, to take precautions against liability, to detect and remediate violations of our Terms of Use or other misuse of our Sites and Apps, for internal operational purposes, and to develop and improve our products and services, including to train our algorithms, models, and products and services which may incorporate artificial intelligence or machine learning.

The following chart describes what categories of personal information we may collect, how we collect that information from you, the business purposes for which we generally use such information, and which types of trusted third-party service providers we may share that information with:

Information Type
Source
Purpose
Service Providers

Personal Identifiers


(customer name, postal address, phone number, e-mail address, social media handle, age, gender)
Provided directly by customer
·Maintaining and servicing your account
·Providing customer service
·Processing and fulfilling your orders
·Processing payments on your orders
·Fulfilling customer rewards
·Advertising and marketing our products to you
·Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
·Product creation and order fulfillment vendors
·Customer service providers
·Marketing and advertising services
·Appointment scheduling services
·Surveys, sweepstakes, and contest administrators
·Payment and chargeback processors
·Mailing and shipping services

Identity Verification Information


Provided directly by customer
·Identify verification as needed to authenticate status as parent or guardian.
·None

Household Information


(family member names, date of birth, and/or age)
Provided directly by customer
·Maintaining and servicing your account
·Processing and fulfilling your orders
·Fulfilling customer rewards
·Product creation and order fulfillment vendors
·Appointment scheduling services

User-Generated Content


(including photos and projects)
Provided directly by customer
·Processing and fulfilling your orders
·Providing customer service
·Providing you customized product recommendations
·Helping you tag and organize your photos
·Analytics to improve our products and services
·Product creation and order fulfillment vendors
·Marketing and advertising service providers

Payment information


(credit card information, billing and shipping addresses, checks)
Provided directly by customer
·Processing payments on your orders
·Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
·Customer service providers
·Payment and chargeback processors
·Fraud prevention and site security

Commercial Information


(purchase date, purchase totals, product types)
Provided directly by customer
·Providing customer service
·Processing and fulfilling your orders
·Processing payments on your orders
·Analytics to improve our products and services
·Advertising and marketing our products to you
·Product creation and order fulfillment vendors
·Customer service providers
·Payment and chargeback processors

Internet or Electronic Network Activity Information and Non-specific Location Information


(IP address, cookies, website browsing and interaction activity, other device or browser identifiers)
Collected indirectly from customer’s browser or device, and information obtained from third-party marketing partners
·Enhancing your user experience
·Analytics to improve our products and services
·Advertising and marketing our products to you
·Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
·Marketing and advertising service providers
·Website performance and analytics vendors
·Fraud prevention and site security

Website login credentials

Provided directly by customer
·Maintaining and servicing your account
·Providing customer service
·Processing and fulfilling your orders
·Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
·None

Inferences about customer preferences and characteristics

Inferred from information provided by customer, information collected indirectly from customer’s browser or device, and information obtained from third-party marketing partners
·Enhancing your user experience
·Analytics to improve our products and services
·Advertising and marketing our products to you
·Marketing and advertising service providers
·Website performance and analytics vendors

In addition to this personal information, from time to time we may collect additional information about you through your interactions with us or in other circumstances.

Social Media
If you log into your account with us through a social media site, we will also have access to certain information from that site, such as your name, account information, and profile photo, in accordance with the site’s account verification procedures. If you subsequently want to unlink your social media account, please contact customer service or use available tools on the site.

If you interact with content on our social media profiles (for example, if you “like” or share a post from our Facebook, Twitter, or Instagram accounts), those social media sites may share information about you with us, including your public profile, e-mail address and friend list. If you choose to “like” or share content, information about you may be publicly displayed on the social network, depending on your privacy settings. If you post information on a social media or another third-party service that references us or our products and services (e.g., via a Twitter hashtag), we may publish your post on our social media accounts or websites. For more information about the privacy practices of any social media sites that you may use to log in to your account or to interact with us, you should review the privacy Notice of that social media site and check your privacy settings through that site.

Information You Provide About Others
The content you choose to upload to our service, including your photos and the information you store in your address book, may include personal information of others. If you choose to share your photographs or other information with someone else through a feature we offer, we will use the personal information you provide (for example, the e-mail address of the recipient) to fulfill your request and for other purposes described in this Privacy Notice. Before you upload and/or share personal information of others through our service, please ensure that you have the consent of such persons to do so.

Professional Photography by Lifetouch
Lifetouch provides professional photography services to businesses, sports leagues, and other organizations across the United States and Canada. When an organization you (or your child) are affiliated with (for example, your child’s sports league, your university, or your employer) engages Lifetouch to photograph you (or your family members), that organization may provide information such as roster information about the people who will be photographed. We limit collection of information to what is necessary to support an outstanding Picture Day experience and for other related purposes authorized by your organization (such as creating a yearbook). We collect this information for purposes such as to match names to the pictures we take and for efficient distribution within the organization. We may also receive your email or mailing address in order to deliver Picture Day-related communications on behalf of your organization or for verification or other purposes approved by your organization. In those cases, we do not use your contact information for any other purpose unless you become our customer by purchasing our products, opt in to receive updates and promotional offers from us, or otherwise grant us permission.

We may also collect your information in order to incorporate it into other items that we are providing to your organization. For example, a directory that we produce for your employer or your university may have your contact information or other information about you. Your organization controls how much, or how little, information is used in producing these items, and your organization is solely responsible for obtaining any consents necessary for Lifetouch to provide its services and produce those items. If you have any questions about what information your organization shares with Lifetouch for Picture Day or for use in any products provided to your organization, please contact your organization directly.

If your child’s Pre K-12 school engages Lifetouch for school Picture Day, see the section titled For Pre K-12 Educators and Parents for more information.

Cookies
We and our service providers collect information about how you use our services – for example what web or mobile pages you have viewed – to administer our services, analyze trends, generate analytics, provide a better user experience, improve our products and services, detect and prevent fraud or security incidents and gather broad demographic information for aggregate use. Our Sites and Apps and emails use pixels, tags, web beacons, and similar tracking technologies (collectively referred to as “Cookies”) that are created when you use our online services and are stored on your computer or mobile device.

Cookies help us offer convenient features like storing the contents of your shopping cart until you are ready to check out, remembering your login and account settings, recognizing your browser when you visit, customizing your current and future visits, and providing you with information about products that interest you. Cookies help us personalize your experience and save time during checkout. We also use the information we collect to compile statistics about our visitors and their use of our site to monitor site traffic, develop marketing programs, and improve our website design and content.

We use the information collected by our third-party service providers using Cookies to analyze and track data, improve our services, determine the popularity of certain content, and better understand our users’ online activity. Our service providers may also show you advertisements for our products and services on other websites, and may combine this information with other information those service providers have gathered about your visits to those other websites so that the advertisements you receive are more likely to be of interest to you.

Other Sources
We may also obtain data that is publicly available or from third party sources, such as address verification services or third-party marketing database partners, to improve the accuracy of and add to what we know about our customers and prospective customers. We may combine this information with your personal information for the purposes described in this Notice. We also may collect information from other companies, organizations, or third-party partners. For example, we may receive information about you from a partner when we jointly offer services or when you elect to link your Lifetouch account with another company’s account.

Employment
In addition to information collected from our customers, we and our service providers also collect certain information from candidates who apply for a job with the Shutterfly family of brands to contact you about your application and evaluate your qualifications for the position, including your name, phone number, e-mail address, postal address, education information, employment information, information you provide in connection with your application, information you make available on your social media accounts, information that is available publicly, and information you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.


• How long do we retain the personal information we collect about you?

Lifetouch will retain your information only for as long as is necessary for the purposes set out in this Notice, for as long as your account is active (i.e., for the lifetime of your user account), or as needed to provide the Sites, Apps and associated services (Services) to you. If you no longer want Lifetouch to use your information to provide the Services to you, you may close your account. Lifetouch will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax laws), resolve disputes, perform and enforce our agreements, and as otherwise described in this Notice.


• How do we share your information with third parties?

We do not “sell” personal information in the ordinary sense of that term. That is, we don’t provide your personally identifiable information to third parties in exchange for money. We may share personal information in the following situations.

Service Providers
We sometimes use third-party service providers to act on our behalf, for example to help us deliver our services, fulfill your product orders, process payments, enhance and personalize your shopping experience with us, deliver our advertisements, and to provide professional, marketing, security, and information technology services. These service providers are only allowed to use your information in connection with the specific service they provide on our behalf.

Partners and Affiliates
Lifetouch is part of the Shutterfly family of companies and brands. We may share your information among our corporate affiliates and subsidiaries for purposes described in this Notice. This allows us to offer features such as the ability to use your Shutterfly account credentials across all of our Web properties and applications where available, and to seamlessly add your Lifetouch professional photos to your Shutterfly account. Your membership in other organizations and/or retail membership programs we partner with may entitle you to special offers on our Sites and Apps, in which case we share offer redemption information (which may include your information) with the partner as necessary to fulfill our contractual obligations. We also work with third party retail partners such as JCPenney when we operate professional photography studios within their stores, and if you are photographed in these studios, we will share your information with our retail partner. If Lifetouch photographs you or your child pursuant to a contract with a school, business, or other organization you are affiliated with, Lifetouch will share your information with that organization as necessary to fulfill its contractual obligations.

Business Headshots
If Lifetouch photographs you pursuant to a contract with your employer or other organization you are affiliated with, Lifetouch will share your information with that organization as necessary to fulfill its contractual obligations.

Law Enforcement, Mergers, and Other Situations
We may be required to share your personal information in other, limited circumstances. For example, we may be required to share certain information to respond to a subpoena or similar judicial process, to comply with state, federal, or local laws, to protect the security or integrity of our databases or website, to take precautions against liability, in the event of a corporate reorganization or, to the extent required by law, to provide information to law enforcement agencies. If necessary, we may also share information with law enforcement without a subpoena or similar judicial process if doing so may help protect the personal safety of a customer, a photo subject, or members of the public. We reserve the right to report to the appropriate law enforcement or government agencies any information that we believe may be evidence of criminal activity or violation of any applicable law.

Additionally, your information may be transferred to another organization if, for example, we negotiate for or transfer the ownership or operation of the Sites and Apps because we have merged with or have been acquired by another organization, if we liquidate our assets, if there is a change in ownership control, or if there is a financing transaction. In those cases, the new company’s use of your information will still be subject to this Notice and the privacy preferences you have expressed to us.

We may also share Lifetouch school photographs with law enforcement in accordance with our SmileSafe® or Pictures2Protect® child safety programs. See the section titled For Pre K-12 Educators and Parents for more information about the SmileSafe and Pictures2Protect programs.


• Does our website collect information from children?

Our Sites and Apps are intended for use by general audiences and are not targeted directly at children under 16. If we become aware that a child under the age of 16 has provided personal information through our websites or apps, we will remove their personally identifiable information from our files. If a parent or guardian becomes aware that their child has provided such information through our websites or apps, the parent or guardian should contact us in writing at [email protected] so that we may respond appropriately.

Please see our section titled For Pre K-12 Educators and Parents for further information on how Lifetouch collects and uses student information for Picture Day, as well as in connection with websites, applications, and online services offered by Lifetouch for the use and benefit of the schools and school districts for their administrative and educational purposes.


• What options do you have to limit our collection and use of your personal information?

You have choices about how your information is collected and used. You can notify us of your preferences when you create an account with us, and if you would like to review, correct or delete your personal information on our Sites and Apps, you can do so via your account settings. There may be times when we are unable to fulfill your request – for example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we cannot separate your data), if we are prohibited by law from disclosing the information, or if we have a legal obligation to retain certain data. We may require additional personal information from you for the purposes of verifying your identity and rights.

Some jurisdictions provide additional legal rights, as described in our Supplemental Notices below.

Opting out of Marketing Communications
If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive, by changing your marketing preferences through your Account Settings, or by contacting us through the Contact Us page of any of our brands. We reserve the right to send you certain communications relating to the services we provide, such as service announcements and administrative messages (for example, communications related to a pending order, an unresolved customer service issue, or a Notice update). We do not offer you the ability to opt-out of receiving those communications.

Cookie Options
You have several options to manage cookies and trackers. If you don’t want our Sites and Apps to collect information using these technologies, you can change your web browser settings to reject Cookies from the site or to alert you before a cookie is placed on your computer. Each browser is different, so you should check your browser’s “Help” menu to learn how to change these preferences. Please note that cookie and tracker-based opt-outs only apply to the specific computer and browser on which the opt-out cookie is applied. If you clear cookies from your device or switch to a different browser, your opt-out will no longer be valid and you will need to opt out again where you want your choices to apply. If you accept a cookies or tracker, you can delete it at any time through your web browser. If you choose not to accept cookies or trackers used for analytics and site functionality, you will not be able to enjoy all the features available to our registered users

You may also manage the cookies and trackers we use on our Sites and Apps through the settings on Lifetouch’s Your Privacy page. If you make choices and return to our site from a different browser or machine, you will need to repeat these choices.

The Network Advertising Alliance (“NAI”) and the Digital Advertising Alliance (“DAA”) offer opt-out tools to help you manage your choices for participating companies that use Cookies for Interest-Based Advertising and cross-app advertising. For more information about these tools please visit: NAI Opt-Out Page and DAA Opt-Out Page. You can also opt out of Google cookies by installing Google Analytics’ opt-out browser add-on https://tools.google.com/dlpage/gaoptout, and/or the Google Advertising Cookie out-out browser add-on.

“Do Not Track” is a preference you can set in your web browser to let the sites you visit know that you do not want them collecting information about you. Our sites do not currently respond to all “Do Not Track” settings; however, we treat Global Privacy Control signals as requests to opt out of the “sale or sharing” of personal information pursuant to the California Privacy Rights Act.


• How do we keep your information secure?

Although no website, application, database, or system is completely secure or “hacker proof,” we have safeguards in place to protect against unauthorized access and disclosures of the personal information we control, including technical, physical, and administrative safeguards and security measures. Despite these measures, however, we cannot guarantee that our information security safeguards will never be compromised.


• How do we make updates to this Notice?

As we implement new technology and introduce new services or otherwise change our privacy practices, or in response to changes in applicable laws or regulations, we may modify this Notice and provide notice to you by posting updates on this page. Please check back periodically to view any updates. Changes to our Notice will become effective when posted. If we change this Privacy Notice in a material way, we will endeavor to promptly notify our customers. Your continued use of our websites, mobile applications, and/or other services following such notice acknowledges your acceptance of and consent to such updated terms.


• How can you contact us with questions about your privacy or this Notice?

For further information regarding this website privacy statement or related Lifetouch policies and procedures, please contact: [email protected].


• Your Photos

Lifetouch Professional Photography
The following frequently asked questions relate to Lifetouch professional photographs taken in portrait studios, schools, businesses and other organizations that Lifetouch serves.

Does Lifetouch use pictures of customers in advertisements?
Not without permission of the photo subject. Lifetouch is proud of its work as a professional photographer, and from time to time we request permission from our customers to display their photos as samples of our work. Lifetouch does not use its customers’ photographs in marketing or advertising materials to third parties without first obtaining a photo release from the photo subject (or, in the case of a minor, the photo subject’s parent or legal representative).

Does Lifetouch share my child’s school photos with my child’s school?
Yes – schools and preschools across the United States and Canada entrust Lifetouch to photograph students and staff as part of the time-honored tradition of Picture Day. Lifetouch provides those photos to the school for use in the school yearbook, student IDs, classroom seating charts and other school-related purposes. Lifetouch also offers the photographs for purchase by parents.

How long does Lifetouch keep photos? What are my options?
When Lifetouch is engaged by a school or other organization as its official photographer, the photos we capture for that organization are deleted in the ordinary course of business within a reasonable time after we have fulfilled our contractual obligations, with the exception of photos associated with customers who elect to purchase from us (Lifetouch Customers). If you are a Lifetouch Customer, our goal is to make the photos we create available to you for years to come, and we will endeavor to retain a digital copy of one or more of your current and future school photos for you to claim and archive in your Shutterfly account for as long as that account remains active. See https://www.shutterfly.com/photo-storage/ for more details. For example, if you purchase your child’s first grade school photo, and Lifetouch photographs your child the following year, we may associate that photo with you and make the digital image available to you to purchase and store in your Shutterfly account.

If you wish, you can take steps to have your photos deleted from our systems earlier, by contacting us at (800) 736-4753. We may require certain information from you to validate your request before deletion. Please be aware, however, that Lifetouch may deny your request and retain your photos under certain limited circumstances – for example, if we have a contractual commitment to a school or other organization you are affiliated with (such as providing yearbook photos or the yearbook itself), if doing so would violate a law or court order, or if it would be unreasonably burdensome. Also, please be aware that, if you shared your photo with other purchasers, your photo deletion request will not affect any photos retained in others’ photo libraries or those purchasers’ archiving preferences.

Do I need a Shutterfly account to purchase school photos?
No. You may purchase traditional printed school photos from Lifetouch for delivery to you through your child’s school. However, if you purchase a digital image or are eligible to receive a digital image through a promotion or loyalty program, you will need a Shutterfly account to claim such digital images. As a part of the Shutterfly family of brands, Lifetouch delivers all digital images to customers via the Shutterfly.com secure photo platform.

What is the SmileSafe® – A Lifetouch Program child safety program?
Lifetouch provides complimentary SmileSafe photo ID cards to the families of each Pre K-12 student photographed in participating schools, at no extra cost and regardless of whether the family has purchased photographs. We work in collaboration with the National Center for Missing and Exploited Children (NCMEC), the United States’ leading experts in child protection. If a child is missing, the parent or guardian of that child can request through NCMEC that a Lifetouch photograph of their child be provided to aid search efforts. Lifetouch does not share its photographs with law enforcement unless a parent or guardian has expressly requested us do so in accordance with our SmileSafe child safety program or on an exceptional basis pursuant to legal process. Lifetouch will respond on a 24/7 basis to aid search efforts. As of the date this Notice was last updated, Lifetouch has assisted with more than 2,000 searches and has contributed to the successful recovery of 56 children from 24 states as a direct result of the SmileSafe child safety program. Click here for more information about this exceptional child safety program.


• For PreK-12 Educators and Parents

Since 1936, Lifetouch has been a trusted provider of school services, providing photography services to schools and families across the United States and Canada. Lifetouch photographs children by agreement with the schools we work with. We offer time-honored Picture Day products to the families of children we photograph while fulfilling a necessary role at no charge to the school.

In preparation for Picture Day, Lifetouch requires certain information from your child’s school record, such as name, grade and homeroom teacher name. Below are a number of Frequently Asked Questions (“FAQs”) regarding the information that Lifetouch needs in order to provide its photography services. These FAQs are intended to provide answers to questions that you may have about Lifetouch’s use of such information and to demonstrate Lifetouch’s commitment to your child’s privacy and security.

What student personal data does Lifetouch receive from schools?
The information we need for Picture Day depends upon the specific services and deliverables Lifetouch is providing your school. We limit the information we collect to only that which is necessary for Picture Day and related authorized school purposes. We collect the information in advance of Picture Day to match names to the pictures we take and for efficient distribution within the school. We may receive your email or mailing address in order to deliver Picture Day-related communications on behalf of the school. In such cases, we do not retain or use your contact information for any other purpose unless you opt in to receive updates and promotional offers from us.

In addition, the information may be incorporated into other items that we are providing to your school. For example, if Lifetouch is producing student ID cards, we need the student ID number to do the job. Our yearbook image product includes images of students sorted by name, grade and other classifying data per your school’s requirements. Schools ultimately decide how much, or how little, information is used in producing School Service Items. Lifetouch does not have access to sensitive information from your child’s record, such as grades or attendance data.

How does Lifetouch use the information it receives from schools?
As part of our agreement with your child’s school, Lifetouch provides various services that support the school’s administrative needs, which may include student ID cards for lunch, library, and transportation purposes, and digital images for the school to use for student recognition, awards, teacher tools, yearbooks, memory books, and class composites. These services are provided throughout the school year. Lifetouch uses the information that it collects solely as necessary to produce such items for the school, to deliver Picture Day-related notices on behalf of your school, and to provide you opportunities to purchase your child’s school pictures.

**Lifetouch does not sell student data collected from your child’s school to third parties for their marketing purposes, nor do we use such data in ways that are unrelated to the purposes authorized by the school. Lifetouch will not sell student photos or yearbooks to a third party for resale.**

What are my options as a parent?
In its role as official school photographer, Lifetouch photographs all students who appear at the camera on Picture Day, and we rely on your child’s school or district to obtain any parental consents necessary for us to do the work they engaged us for. Our photographers reasonably presume that they are permitted to photograph each individual who appears at the camera for that purpose. If you are a parent who does not want your child to participate in your school’s Picture Day, you must pre-arrange with the school not to have your child photographed.

Lifetouch acknowledges its obligations as a service provider to your school for student and staff photography pursuant to the federal Family Educational Rights and Privacy Act (“FERPA”). Your school retains the authority to control Lifetouch’s use of the information it provides to Lifetouch and to require its return or destruction at any time. We will honor a parent’s image deletion request, subject to verification and authorization of the school when deletion would impact our ability to deliver an item or service requested by the school.

If you choose to purchase your child’s school photos from Lifetouch, the personal information you provide to us will be treated as customer information and used as described in our Privacy Notice.

Note to Schools and Parents about Lifetouch Pre K-12 Applications
Some Lifetouch-provided websites, applications and online services are designed for the use and benefit of the schools and school districts for administrative and educational purposes and used by or at the direction of teachers or other school or district employees (each a “Lifetouch Pre K-12 Application”). Lifetouch Pre K-12 Applications include the Lifetouch Portal™ for school administrators, our Lifetouch Yearbooks applications and online tools, and other applications or services to support Picture Day and other school-approved purposes.

With respect to Lifetouch Pre K-12 Applications, Lifetouch will:

• not collect or use student personal data beyond what is needed to effectively support authorized school purposes;
• not sell or rent student personal data;
• not use or share student personal data for advertising or similar commercial purposes, such as behavioral targeting of advertisements to students;
• not build a personal profile of a student, other than for supporting authorized educational or school purposes or as authorized by the parent, guardian, or student of appropriate age;
• require that our vendors with whom student personal data is shared to deliver the school service, if any, are obligated to implement these same commitments for student personal data.

If you are an authorized user of a Lifetouch Pre K-12 Application, please refer to the Terms of Service linked to from that service or contact us through your Lifetouch school account representative for further information. A school, through its authorized representative, may elect to allow students to contribute to the school yearbook using a Lifetouch Yearbooks application. In accordance with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA, 15 U.S.C. § 6501 et seq.), we do not knowingly solicit, or accept personally identifiable information from users known to be under thirteen (13) years of age without the consent of their educational institution or the child’s parent or guardian. We may, in the course of providing services to educational institutions, collect information directly from students in support of and with the consent of the educational institution.


• Supplemental Notice to Residents of CA, CO, CT, MT, OR, TX, UT, or VA

Depending on where you reside, you may also have additional legal rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases. Consistent with applicable laws, this Supplemental Notice provides a way to exercise such rights for residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia.

For information about what categories of personal information we may collect from our customers, the sources of that information, the purposes for collecting and using that information, and what types of third party service providers we may share that information with, please see our section titled What personal information do we collect? How do we use that information?

The laws of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia grant some or all of the following rights to consumers who reside in those states:

•The right to request information about personal information that we have collected about that customer in the 12 months preceding the customer’s request (including the categories of information collected, the source of that information, the business purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of personal information collected about that particular customer);
•The right to receive requested information in a readily-usable format if provided electronically;
•The right to request that we delete any personal information about the consumer that we have collected (although we may be entitled to retain some information for certain purposes);
•The right to opt-out of “sales” of personal information to third parties, the sharing of personal information with third parties for targeted advertising purposes, and/or the processing of personal information for targeted advertising purposes;
•The right to update or correct any personal information which is out of date or incorrect; and
•The right to be free from discrimination based on your exercise of your privacy rights.

To exercise your rights pursuant to this Supplemental Notice with respect to Lifetouch, Prestige Portraits, or JCPenney Portraits by Lifetouch, please call (888) 288-2214 or request online at the appropriate site below. Note that use of our online data privacy tools will resolve your requests more quickly than phone or email requests.

• Lifetouch: https://lifetouch.com/additionaldataoptions
• Prestige Portraits: https://prestigeportraits.com/additionaldataoptions
• JCPenney Portraits by Lifetouch: https://jcpportraits.com/additionaldataoptions

We cannot respond to your request to access or delete information unless we are able to both verify your identity or authority to make the request and confirm the personal information relates to you and/or your household. If you have an account on any of our Sites and Apps, we will verify your identity by having you log in to your account. If you do not have an account on our Sites and Apps, we will attempt to verify your request by asking you to provide identifying information that we will match to information in our files. We will only use information you provide in your request for the purpose of verifying your identity or authority to make the request. You can also designate an authorized agent to make a request on your behalf. Your agent will need to provide a Power of Attorney authorizing the agent to act on your behalf, or will need to complete the same verification procedures that would be required for a request submitted by you directly, and provide information that allows us to verify your authorization. If you would like to appeal a decision related to a request to exercise your rights under this Supplemental Notice, please contact us at the phone numbers, online forms, or email address listed above.

We may deny deletion requests in whole or in part as permitted or required by applicable law. We do not charge a different price or rate or provide a different level or quality of goods or services based on your exercising your privacy rights. We do not “sell” personal information in the ordinary sense of that term. That is, we don’t provide your personally identifiable information to third parties in exchange for money. But under California law, sharing information with third parties for targeted advertising purposes may be considered a “sale” of personal information. Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia have the ability to opt out of such sharing using the methods above-listed.


• Supplemental Notice to Residents of California

If you are a California resident under the age of 18, and a registered user of any site where this Notice is posted, you may request and obtain removal of content or information you have publicly posted on such site. To make such a request, please send an email with the subject line “California Minor Content Removal Request” to [email protected]. Please specify in your request which website or application your request relates to and the specific information or content that you would like removed. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another visitor to our websites.

If you are a former Lifetouch employee and would like to exercise your rights with respect to your personal data we collected in the course of your employment, please send an email with the subject line “California Former Employee Data Request” to [email protected].

In 2023, Lifetouch received and completed 5 verified deletion request and 4 verified access requests from customers in all locations. Lifetouch received and completed 0 verified requests to opt-out of sale/sharing. Lifetouch received 0 requests to correct as customers can correct their data within their account. The CCPA requirements related to requests to limit do not apply to Lifetouch as we do not use customers’ sensitive personal information in the manner regulated by the CCPA. Lifetouch did not deny any verified requests. Lifetouch responded to data subject rights requests within 20 days on average.

We may offer various financial incentives and benefits (such as free shipping, discounts, and other special offers) to customers who interact with us in our Sites and Apps and provide personal information. We offer such financial incentives and benefits for business purposes such as increasing engagement and sales or raising brand awareness, and participation is voluntary. We do not assign monetary or other value to personal information, but the value of such personal information is reasonably related to the estimated value of the financial incentive offered when the information was collected. Lifetouch reserves the right to withdraw or modify the financial incentives we offer at any time.


• Supplemental Notice to Residents of Nevada

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties.  This right applies even if their personal information is not currently being sold.  If you are a Nevada consumer and wish to exercise this right, please send an email with the subject line “Nevada Resident Do Not Sell Request” to [email protected]


• Supplemental Notice to Residents of Canada

You have choices about how your information is collected and used. The Senior Director, Head of Privacy responsible for privacy compliance can be contacted at [email protected]

The laws of Canada grant some or all of the following rights to consumers who reside there:

• The right to access your personal information held by us. There may be times when we are unable to fulfil your request – for example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we cannot separate your data), if we are prohibited by law from disclosing the information, or if we have a legal obligation to retain certain data. We may require additional personal information from you for the purposes of verifying your identity and rights. If we refuse, we will tell you why.
• If you are able to successfully demonstrate the inaccuracy or incompleteness of your personal information, we will amend the information as required (this could include the correction, deletion, or addition of information). Where appropriate, the amended information will be transmitted to third parties having access to the information in question. If you would like to review, correct, or delete your account information on our Sites and Apps, you can do so by logging in to your account or by contacting us directly at [email protected]
• Where our processing is based on consent, you can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Upon receipt of any withdrawal, we will information you of the implications of such withdrawal (for instance, we may not be able to provide some or all our products or services).

To exercise your rights under this Supplemental Notice, please contact us at [email protected]

We use an opt-in standard for promotional e-mail, phone, and text messages. If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive, by changing your marketing preferences through your Account Settings, or by contacting us through the Contact Us page of any of our brands. We reserve the right to send you certain communications relating to the services we provide, such as service announcements and administrative messages (for example, communications related to a pending order, an unresolved customer service issue, or a Privacy Notice update). We do not offer you the ability to opt-out of receiving those communications.

To opt-out of other forms of marketing (such as postal marketing), please contact us at [email protected]

By using our Sites and Apps, you acknowledge and consent that your information may be transferred to, stored, or processed in another province in Canada or in the United States. Please see the Supplemental Notice to Visitors from outside the United States for further information.

For further information regarding Lifetouch Canada’s privacy policies, please contact [email protected] or write us at Privacy Office, Lifetouch Canada Inc., 1410 Mountain Ave, Suite 1, Winnipeg, MB R2X 0A4.


• Supplemental Notice of International Data Transfers

Our Sites and Apps are hosted globally, including in the United States, Canada, and Germany. By using our Sites and Apps, you acknowledge and consent that your information may be transferred to, stored, and processed in another country than your own in accordance with this Privacy Notice and applicable laws. Please be aware that international privacy laws, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside.