We don't collect any of your information without your permission. Period.
However, that statement bears the following implications:
We (ShutterPilot LLC) do not use any of the information collected to market our product and services or those of any third parties. We may, however, occasionally notify you of updates to your account or this service, or other communications that fall under the umbrella of “transactional” communications.
We do not perform any automated recognition on any of the photos uploaded to ShutterPilot Photo Hub. We do perform some automated processing solely to ensure appropriateness of content and may use additional pieces of information we have gathered to improve our algorithms, but all inputs, stored models, and results are effectively anonymized.
If you have questions or concerns on this policy, or would like to obtain a copy of your information, please send an email to firstname.lastname@example.org with the subject “Personal Information Request”.
Per the COPPA regulations, ShutterPilot Photo Hub is not considered an online service that is “directed to children”, and in fact requires users to be 13 or over to comply with our Terms of Service.
However, operators of photo booths (which could be considered “online services”) may allow children under the age of 13 to use the photo booths. ShutterPilot LLC provides mechanisms for these operators to comply with applicable law.
These photo booths may use software developed by ShutterPilot or by other software vendors. In either case, it is the responsibility of the photo booth operator to ensure that parental consent has been obtained prior to childrens’ use of the photo booth through the appropriate disclaimers and privacy policies.
These photo booths may collect any of the following types of personal information protected by COPPA:
ShutterPilot makes no assumptions that any personal information is in any way correlated and uses contact information collected in conjunction with a photo solely to deliver the recorded photo to the recipient (“internal operations”). (For example, a photo of a child could be emailed to his or her parent's email address.)
ShutterPilot Photo Hub does provide the capability to share photos to social media (considered “disclosure” of “personal information” under COPPA); however, this functionality is available only to users 13 and above or children whose parents have affirmed consent.
The photo booth operator, as the collector of personal information, may be required to comply with COPPA. ShutterPilot provides a service on behalf of the operator and the consumer; therefore ShutterPilot treats all collected data with industry best-practice security and privacy protection processes and policies to enable all users to comply with all relevant privacy requirements and expectations.
A parent may request the removal of information collected from his or her child upon request. To ensure privacy is maintained, ShutterPilot my require additional validation prior to allowing the review and/or deletion of personal information in accordance with relevant laws and regulations. To initiate a COPPA review, please send email to email@example.com with “COPPA” in the subject.
In addition to situations where a child is the sole actor, there are some additional scenarios not specifically described by COPPA, which we interpret as follows: