This website and our Picture Day services are provided by Lifetouch Canada Inc. (“Lifetouch Canada”). Along with its U.S. parent corporation Lifetouch Inc. and its subsidiaries (collectively, “Lifetouch”), Lifetouch is a trusted provider of photographic products and services to communities, schools, churches, day care centers and families throughout the United States and Canada. At Lifetouch, we are sensitive to the privacy concerns of the communities we serve, and want to ensure they understand the ways we collect, use and protect the personal information that they provide to us.
This policy explains our information practices pertaining to this website and Lifetouch Canada’s school photography business, and the choices you, as a Lifetouch customer or a visitor to this site, can make about the collection and use of your information. It also explains how Lifetouch uses the limited personal information provided to it by schools in order to conduct Picture Day.
What personal information does Lifetouch Canada collect in the course of its business operations? How is that information used?
We limit the use, disclosure and retention of your personal information. We only collect personally identifiable information about you if you specifically provide it to us. This includes, for example, the information you provide when you schedule an appointment, visit one of our photography studios, place an order, contact customer service, register for a service, respond to a survey or enter a contest or sweepstakes. The personal information you provide us may also include information about others, such as when you use a website feature to share your images with friends and family. We use this information you share with us only for the purposes for which it was collected, including:
- to provide the products, services or benefits you request;
- to respond to your questions and concerns;
- to develop and improve our products and services;
- to improve the content of our site and its usefulness to you; and
- to communicate with you about our products, services, promotions and special offers.
Picture Day Information
The Picture Day tradition is an important part of a child’s school experience and Lifetouch is proud to have been involved in this tradition since 1936. In preparation for Picture Day, Lifetouch collects certain directory-type information from the school (“School Data”); the School Data we collect depends upon the specific services and deliverables Lifetouch is providing to that particular school. We limit collection to only that which is necessary for an authorized school purpose. Typically, we collect basic roster and classroom information in advance of Picture Day to ensure a perfect name-image match for each portrait and for efficient distribution within the school (in other words, Lifetouch needs to know what class a child is in so we can identify the photos for the school to distribute to the appropriate teacher). If permitted, we collect parents’ email addresses from the school in order to deliver Picture Day-related communications. In such cases, we do not retain or use such information for any other purpose unless the parent affirmatively opts in to receive updates and promotional offers from Lifetouch. On Picture Day, we photograph each child who participates in Picture Day with his or her class in accordance with the school’s requirements.
Lifetouch uses School Data solely as necessary to create, offer and deliver student images and school administrative services to the school and families of the students. We generally use the School Data in the following ways:
- To produce and deliver to schools the portrait-based products and services needed for the school’s administrative purposes and/or for use in the school yearbook (the “School Service Items”);
- To deliver Picture Day notices on behalf of the school and provide parents of students photographed opportunities to purchase our photographs; and
- To produce and deliver Pictures 2 Protect® child safety cards to parents of participating schools, as outlined more fully below.
In addition, School Data may be incorporated into School Service Items. For example, if Lifetouch is producing student ID cards, we need the student ID number along with the student image to do the job. Schools ultimately decide how much, or how little, information is used in producing School Service Items and their approach to sharing this information with us will be set out in their own privacy policies.
Consent to use personal information.
By using this website, participating in Picture Day or transacting business with Lifetouch, you consent to our collection, use and disclosure of the personal information you provide to us as described in this Privacy Statement, or as otherwise permitted by law.
In conjunction with the school, we publicize Picture Day in advance of the actual days we attend at the school to take photos. Schools may also independently publicize this. If a student appears on Picture Day to have their photo taken, we assume that the appropriate consent has been obtained. If you do not want your child to participate in Picture Day, please contact the school and make your wishes known.
If we have taken your child’s photo in error, you may contact us directly (see below) and we will securely delete the child’s image from our systems. We may require you to confirm your school’s approval first, if deleting the image would impact our ability to produce a School Service Item per the school’s specifications.
Please understand that if we do not take a photo of a child, or otherwise delete the photo of a child, you will not be able to participate in the child protection “Pictures 2 Protect Program” outlined more fully below.
How long does Lifetouch keep the personal information it collects?
Lifetouch retains School Data only as necessary and permissible to promote the sale of portraits to parents, to retrieve the images to supply picture orders for the current school year and to support the school for an approved administrative purpose, after which time the data is securely destroyed. This time period varies according to individual school requirements. Typically, Lifetouch retains School Data and student images for approximately 12-18 months following Picture Day, unless the school requires a different retention period or an individual child’s parent or guardian requests that the image be deleted earlier.
Customers who purchase images and/or establish a website account for viewing, sharing and ordering photos should check the image retention policy or Terms of Service for the applicable studio or website. If you are a customer or website account owner, you may contact us directly (see below) at any time to initiate account deletion. We reserve the right to condition our compliance with your request on proof of your identity and/or relationship to the subject(s) whose images are stored.
When might we provide other parties with your personal information?
Lifetouch will not sell or license your personal information to others.
If you choose to share personal information with Lifetouch Canada through this website or by transacting business with us, we may share it within Lifetouch. The Lifetouch enterprise operates throughout Canada and the United States, and we may transfer your personal information to a Lifetouch location in the United States or process your personal information in the United States. As a result, your personal information may be subject to the laws of that jurisdiction, which may be different from Canadian laws. We may also share this information with third party service providers who provide support services to us or help us with our marketing programs. If so, these parties are only authorized to use the information solely in conjunction with the specific service they provide to or on behalf of Lifetouch.
In the event that Lifetouch, any of its affiliated companies, brands or substantially all of their assets are acquired by an unrelated third party, your personal information may be one of the transferred assets. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.
In addition, there may be some other, limited circumstances in which we may disclose the personal information – for example, in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
How does Lifetouch safeguard personal information?
Lifetouch has implemented safeguards reasonably designed to protect against unauthorized access and disclosures of all personal information under its control, including appropriate technical, physical and administrative safeguards and security measures. A comprehensive set of IT policies based on ISO 27001/2 governs information systems practices and procedures throughout the Lifetouch enterprise. As a Level 2 merchant transacting over one million credit card transactions per year, Lifetouch is subject to annual third party certification of its compliance with the stringent Payment Card Industry Data Security Standard.
What is the Pictures 2 Protect® Program? Do you share student photos with law enforcement?
Lifetouch does not share student photos with law enforcement unless a parent or guardian has expressly requested us do so in accordance with this program or on an exceptional basis as explained above in the section titled When might we provide other parties with your personal information?
Lifetouch Canada provides two complimentary Pictures 2 Protect photo ID cards annually to the families of each elementary, middle, and high school student photographed in participating schools, at no extra cost and regardless of whether the family has purchased portraits.
We work in collaboration with the Canadian Centre for Child Protection, one of Canada’s leading experts in child protection. If a child is missing, the parent or guardian of that child can request through the Canadian Centre for Child Protection that a Lifetouch portrait of their child be provided to aid search efforts. Lifetouch will respond on a 24/7 basis to aid search efforts. This private, secured system requires parent permission and law enforcement verification prior to image release by Lifetouch. Once released, the images can help authorities start an accurate, on-site search the moment a child is missing.
Parents or guardians have complete control over whether or not to share a child’s Pictures 2 Protect image with law enforcement.
We want to keep your personal information up-to-date, accurate and relevant for its intended use. We rely on you to let us know if your address, telephone number or other information you provide us changes, so that we may provide you with the best possible service.
Other information we collect through this website
In addition to personal information you provide through our website, Lifetouch.ca uses technologies that let us know what type of browser you are using, the website from which you enter Lifetouch.ca, and the pages you view as you tour our site. This technology does not identify you personally – it simply helps us compile statistics about our visitors and their use of our site. We use these statistics and share them with third parties to improve our website design and content and in connection with marketing programs.
A “cookie” is a small data file stored by your web browser on your computer’s hard drive. Cookies are necessary to use the site. A cookie allows our web server to balance customer traffic on our website to enhance performance of the service. If you disable your cookies, you may not be able to visit our site. After you end your session, the cookie from the web server will remain on your computer until you manually delete it. No personal information is stored on this cookie. Accepting cookies through your web browser is your personal choice. However, if you choose not to accept cookies, you may not be able to take full advantage of this website’s features.
If you do not wish to receive promotional information as a result of using the Lifetouch.ca website, what should you do?
Our goal is to inform you about our products and services, including special promotions and coupons. We use an opt-in standard for promotional e-mail, phone and text messages. If you are contacted and do not wish to receive further information or contacts, you may “unsubscribe” at any time by contacting us to indicate you do not want further promotional information or contacts. If contacted by mail, return the mail to sender. If contacted by e-mail, the email will include an “unsubscribe” feature. If telephoned, notify the person telephoning you that you do not want additional contacts. We will act promptly to honour your request. Please be aware that, even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes. Some examples are contacts for customer service, order updates, schedule changes and appointment reminders.
You have the right to access, update and correct inaccuracies in your personal information in our custody or control. To access your personal information, a request must be submitted in writing to us (see contact information below). We will respond to your request for access or information in a reasonable time. 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 are unable to separate your data), or if we are prohibited by law from disclosing the information. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
We do not knowingly collect through our website the personally identifiable information from children under the age of 13. If we discover that a child has provided Lifetouch.ca with personally identifiable information through our website, we will do our best to delete it. If you are the parent or guardian of a child who has provided such information to us, we ask that you contact Lifetouch in writing at 1395 Inkster Boulevard, Winnipeg, MB R2X 1P6 Attention Privacy Officer and we will do our best to delete the child’s personal information from our files.
No control of third party sites
Please be aware that websites that link to Lifetouch.ca may collect personally identifiable information about you. You should consult the other sites’ privacy policies as we have no control over information that is submitted to, or collected by, these third parties.
As we implement new technology and introduce new services, we will update this page, so we encourage you to review it often. We reserve the right to change our Privacy Statement at any time without advance notice. Should any new online policy go into effect, we will post it on this site, and the policy will apply to all personal information collected.
For further information
For further information regarding Lifetouch Canada’s privacy policies, please contact: Privacy Officer, Lifetouch Canada, 1395 Inkster Boulevard, Winnipeg, MB R2X 1P6; Tel: (204) 633-1395; Fax: (204) 694-5226; email: firstname.lastname@example.org.
Last Revised December 2015
© 2015 Lifetouch Inc. All Rights Reserved.