Data Privacy

Securing Data & Images

Our web systems that contain data and images in private galleries are hosted with Hostek, a world class cloud hosting service. Their SSAE 1 Certification is a premium standard of data security recognized by the Auditing Standards Board of the American Institute of Certified Public Accountants for securing sensitive information such as social security numbers, private health information and contact information like addresses and phone numbers.

When reviewing hosting services, we chose Hostek in order to leverage a platform that is HIPPA compliant, PCI compliant and SSAE compliant to provide protection for students and families and instill confidence in our school partners.

Securing our own network in Pennsylvania is another important step in protecting data and images. In addition to our internal physical firewalls and Smart Network Routers, we also partner with Netizen CyberSecure Solutions. Netizen is a Pennsylvania company with an international footprint given their critical work with the Department of Defense.

We have partnered with Netizen for a risk and vulnerability assessment, network penetration testing and daily security monitoring.

WEbsite Privacy Policy

INFORMATION WE COLLECT

While you visit our Website, we may collect certain non-personally identifiable information such as the type of browser you are using, the type of operating system you are using, the domain name or internet protocol address of your Internet service provider, etc. This information is used by us to assess our Website performance and accessibility, and to make improvements to our service.

INFORMATION YOU PROVIDE TO US

We store information you provide to us, including:

● Your name
● Login information

We may also store information you provide to us about third parties, including:

● Student names
● Student ID number
● Age
● School
● Homeroom
● Birthdate
● Address

To the extent any information you provide to us is identifying of a Child, as defined in our Children’s Privacy Policy, you agree to adhere to the Christmas City Studio Children’s Privacy Policy. You further agree that upon receipt of a request in accordance with the Parental Control of Child Information section of our Children’s Privacy Policy, you will comply with such request, or promptly forward such request to your Provider, as that term is defined in our End User License Agreement.

HOW WE USE THE INFORMATION WE COLLECT

Christmas City Studio may use your personal information:

● To provide services or products you request;
● To provide services or products in connection with our agreement with a school or other organization

with which you are affiliated;
● To improve our products, services, this Website or other offerings and the functionality, quality and/or utility thereof;
● To communicate with you;

● To test, monitor, improve or develop measures that ensure the security, integrity and/or reliability of the Website, our products, or our services. Your personal information may be incorporated into products that Christmas City Studio provides to you and your associated school or other organization, such as, without limitation, the inclusion of your or your child’s name, photograph, school, homeroom designation or student ID number when producing student ID cards. You should notify your school or other organization if you wish to exclude your photo or other personal information from such products and services.

LIMITATIONS ON USE

Christmas City Studio will not use photographs in marketing or advertising materials
without first obtaining a photo release from the photo subject or, in the case of a minor,
the photo subject’s parent or legal guardian. Christmas City Studio will not sell, trade or
share your personal information with unaffiliated third parties. We may disclose
personal information to third parties that support our provision of services or delivery
of products to you in connection with that purpose.

WHEN YOUR INFORMATION IS AVAILABLE TO OTHERS

● We may share your personal information when necessary to perform, or in
connection with, our business function as the producer of school
identification cards. This may include, but is not limited to, confirming
accuracy of such information with authorized personnel of schools and/or
school districts.

● We may disclose personal information if permitted or required by law, for
example, in response to a court order or a subpoena. To the extent
permitted by applicable law, we also may disclose personal information
collected from children (i) in response to a law enforcement or public
agency’s (including schools or children services) request; (ii) if we believe
disclosure may prevent the instigation of a crime, facilitate an investigation
related to public safety or protect the safety of a child using our sites or
applications; (iii) to protect the security or integrity of our sites, applications,
and other technology, as well as the technology of our service providers; or
(iv) enable us to take precautions against liability.

INFORMATION FROM OR ABOUT CHILDREN

Christmas City Studio does not knowingly collect information from children under thirteen (13) years of age. For further information, please visit this Website’s Children’s Privacy Policy.

UPDATES TO THIS POLICY

Christmas City Studio may update this Privacy Policy from time to time, without notice. Your use of the Website constitutes your consent to our use of your information in accordance herewith. Therefore, you should review this Privacy Policy when you visit the Website. Updated versions of this Privacy Policy will be so identified with a revision
date.

cHILDREN'S pRIVACY pOLICY

This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”).

SCOPE

For the purposes of this Children’s Privacy Policy, and in accordance with COPPA, a child is any person under the age of thirteen (13) (a “Child” or “Children” as context dictates). This site is not intended for use by Children. However, in order to provide services to you and/or your Child, or your Child’s school, including the printing of school identification cards, Christmas City Studio requires certain information about Children, which information may be subject to this Children’s Privacy Policy.

INFORMATION COLLECTED FROM OR ABOUT CHILDREN

We may collect the information identified in our Privacy Policy.

WHEN INFORMATION FROM OR ABOUT CHILDREN IS AVAILABLE TO OTHERS

We may share a child’s personal information when necessary to perform, or in connection with, our business function as the producer of school identification cards. This may include, but is not limited to, confirming accuracy of such information with authorized personnel of schools and/or school districts.
We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

PARENTAL CONTROL OF CHILD INFORMATION

Parents or legal guardians can refuse to permit Christmas City Studio to collect further
personal information from their Children in association with this Website, and can
request that we delete from our records the personal information we have collected in
connection therewith.

Users shall make available to parents and legal guardians means for delivery of such
requests. A user in receipt of such request shall comply fully with that request or
immediately forward that request to the user’s Provider, as that term is defined in our
End User License Agreement, for compliance with the same.

UPDATES TO THIS POLICY

Christmas City Studio may update this Children’s Privacy Policy from time to time,
without notice. Your use of the Website constitutes your consent to our use of your
Child’s information in accordance herewith. Therefore, you should review this Children’s
Privacy Policy when you visit the Website. Updated versions of this Children’s Privacy
Policy will be so identified with a revision date.

qUESTIONS?

Contact us and we'll do our best to clarify any concerns you may have. A PDF of our Privacy Policy is available in the footer of our

website for your convivence.