Photobooth for Business Privacy Statement

This Photobooth For Business Privacy Statement was updated on May 22, 2018.

In the course of providing Photobooth for Business (“UFB”) services and related services to its corporate, non-profit organization and governmental customers (“Customers”), Photobooth will receive and have access to personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and Photobooth is a data processor. Photobooth’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between Photobooth and each of its Customers.

As a data processor, Photobooth will access, store and use the personal data of individual Users solely for the purpose of providing the UFB services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the UFB services. They do this by designating one or more UFB account administrators or group administrators (“Administrator”) who have the ability to customize the Customer account, manage individual User accounts, access the UFB Insights tool and related reporting features, access the UFB Administrator tools, and, when instructed by the Customer, populate the Customer account with Customer-provided courses. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the UFB services. Photobooth has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.

For avoidance of doubt, this Privacy Statement does not apply to:

  1. any processing of data for the purpose of marketing the UFB service to enterprise and corporate prospects;
  2. any other offerings available at Photobooth.com separate from the UFB services, for which the Photobooth Privacy Policy is applicable. A User may already have a account with Photobooth to access Photobooth’s marketplace educational content, and data processed as a result of the use of the Photobooth marketplace from a User account is governed by the Photobooth Privacy Policy.

In the event where Photobooth makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

Photobooth for Business Privacy Statement
  1. Information about Users collected and stored by Photobooth
  2. Purpose of User Data Processing
  3. Cookies and other Tracking Technologies
  4. Sharing User Information with Sub-Processors
  5. Processing of User Data outside of the EEA

1. Information about Users collected and stored by Photobooth

  1. When a User is given access to the UFB services by the Administrator, a User may set up an individual User account and Photobooth will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:
    • first name, last name, and email address required
    • photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)
    • other personal data, as allowed by the Customer
    A unique identifying number is assigned by Photobooth upon the creation of a User account.
  2. Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.
  3. Administrators may assign a User to a group membership
  4. Customers may select to integrate with UFB a Single Sign On (SSO) identity provider to enable Users to log in to UFB User accounts without the need to disclose passwords to Photobooth. In such case Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. In such case, SSO identity providers share with Photobooth a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.
  5. At the option of the Customer, the UFB service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, other students, and the Customer, by posting reviews on a course, sending messages to or chatting with others, posting questions or answers, or posting other content. Such public or shared content is stored by Photobooth and may be publicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where such content is posted.
  6. Photobooth stores information relating to the activities of Users as they use and interact with the UFB services, such as courses enrolled in and viewed (and information relating to these courses); interactions with instructors, teaching assistants, Administrators, and other Users; and progress within a course; as well as answers, essays and other items submitted by Users to satisfy the course requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.
  7. The UFB service enables Users to contact the Photobooth Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the UFB services or other users. Photobooth may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the Photobooth platform and communications with the Photobooth help desk team. Photobooth may request additional information from Users in order to resolve any issue reported by a User or by another user.
  8. When a User uses the UFB services, Photobooth collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).
  9. IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.
  10. If a Customer makes purchases via credit card, Photobooth collects certain data about the purchase (such as name and zip code) as necessary to process the order. Customers must provide certain payment and billing data directly to Photobooth’s payment processing partners, including name, credit card information, billing address, and zip code. For security, Photobooth does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

Photobooth processes the information collected about Users and Administrators for the purpose of providing the UFB services to its Customers, specifically:

  • Providing, administering, and facilitating access to the UFB services, for Customers and Users, and managing Customer or User account preferences
  • Fulfilling Customer’s instructions with respect to personal data of Users
  • Displaying and sending via email notifications to Users for:
    • Responding to User questions or concerns
    • Making notifications to Users at the request of the Customer
    • Sending Users administrative messages and information, including confirmation of account creation, course enrolment, course progress and notifications of responses from instructions to User questions
    • Providing information to Users about courses available to Users, available and new UFB service features; personalized course recommendations, which Users can opt out of at any time
    • Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page for the mobile application.
  • Enabling communications among Users and instructors or teaching assistants
  • Soliciting feedback to improve UFB User experience
  • Resolving User support requests or claims

Email Preferences

Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct Photobooth to configure email preference settings for all Users of a Customer.

Retention of Personal Data

Photobooth will retain the data of Users for as long as instructed by the Customer. Photobooth will delete certain or all personal data relating to Users upon request of the Customer. Photobooth may retain aggregated or anonymized data as set forth below.

Use of aggregated data

In addition, User data is aggregated with other Photobooth marketplace user data to enable Photobooth to improve its products and services and develop new products and services, including:

  • Reviewing and analyzing User browser and wireless device technical information
  • Reviewing user activity across UFB and the Photobooth marketplace (for example, Photobooth analyzes trends and User traffic and and usage information to identify which courses are most popular)
  • Facilitating the technical functioning of the UFB services and Photobooth marketplace, including to troubleshoot and resolve issues, secure the UFB services, and prevent fraud and abuse
  • Developing a personalized course content recommendation engine
When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

3. Cookies and other Tracking Technologies

Like many online platforms, Photobooth and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Photobooth to understand how Users interact with the UFB services. Photobooth and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about User activities. Photobooth uses both session cookies and persistent cookies.

  • A session cookie is used to identify a particular visit to the UFB services and collect information about interaction with the UFB service. These cookies expire after a short time, or when the User closes their web browser after using the UFB service. Photobooth uses these cookies to identify a User during a single browsing session, such as when you log into the UFB services. This helps Photobooth improve the UFB service as well as improve the Users’ browsing experience.
  • A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. Photobooth uses these cookies to identify and recognize a specific User over a longer period of time. They allow Photobooth to:
    1. analyze the usage of the UFB services (e.g. what links Users click on) in order to improve our UFB offering
    2. test different versions of the UFB services to see which particular features or content Users prefer to optimize the UFB services
    3. provide a more personalized experience to Users with more relevant content and course recommendations and
    4. allow Users to more easily log in to use the UFB services. Persistent cookies include:
      • preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized
      • authentication and security cookies to enable a User to log in or stay logged in and access the UFB service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorised usage of User accounts.
      • functional cookies to make the experience of using the UFB service better, like remembering the sound volume level selected by the User.

Photobooth uses tracking technology to: (i) determine if a certain page was visited (e.g. the landing page of an advertisement for UFB services that is displayed on third party sites) or whether an email sent by Photobooth was opened or clicked on by a User; and (ii) to customize the learning experience of individual Users by recommending specific courses and other content.

Cookie list

Photobooth will retain the data of Users for as long as instructed by the Customer. Photobooth will delete certain or all personal data relating to Users upon request of the Customer. Photobooth may retain aggregated or anonymized data as set forth below.

Service Name Expiration Purpose
Photobooth *
* Additional cookies may be added, and would have the same functionalities as the ones listed
__udmyvst [session] For analytics and testing
__udmy_2_v57r 1 year For analytics and testing
__udmyvstr 1 year For analytics and testing
access_token 1 month For user authentication
client_id 1 month For user authentication
csrftoken 1 year For user authentication
dj_session_id 1 month For user authentication
seen 30 minutes For experience improvement and customization
ud_firstvisit 1 year For experience improvement and customization
ud_rule_vars 2 years For experience improvement and customization
mute 1 month For experience improvement and customization
playbackspeed 1 month For experience improvement and customization
quality_* 1 month For experience improvement and customization
volume 1 month For experience improvement and customization
ufb_acc 1 year For experience improvement and customization
EUCookieMessageShown10 yearsFor experience improvement and customization
EUCookieMessageState15 daysFor experience improvement and customization
eva[session]For experience improvement and customization
__udmy_evid[session]For experience improvement and customization
Google Analytics _ga 2 years For analytics
_gid 24 hours For analytics
_gat 1 minute For analytics
_gat_instructor 1 minute For analytics
_gat_UA-12366301-43 1 minute For analytics
SiftScience _ssid13 yearsFor security
Intercom intercom-lou-* 1 year For experience improvement and customization
intercom-session-* 7 days For experience improvement and customization
Marketo _mkto_trk 2 years Email and course promotion analytics
Optimizely optimizelyEndUserId 10 years For analytics and testing
optimizelyBuckets 10 years For analytics and testing
optimizelySegments 10 years For analytics and testing
PerimeterX _px2 5 days For security
_px3 5 days For security
_pxvid 5 days For security
Zendesk _help_center_session [session] User support authentication and experience
_zendesk_authenticated [session] User support authentication and experience
_zendesk_shared_session 8 hours User support authentication and experience
_zendesk_cookie 20 years User support authentication and experience
_zendesk_session [session] User support authentication and experience

User Preferences with respect to cookies and other tracking technologies

A User can set his or her web browser to notify about the placement of new cookies, limit the type of cookies or reject cookies altogether; if enabled, a User may not be able to use some or all of the features of the UFB services (for example, may not be able to log in). General information about cookies and how to disable them can be found at www.allaboutcookies.org.

Various browsers may offer their own management tools for removing HTML5 LSOs. Users can manage Flash LSOs here. To manage flash cookies, visit the Adobe website and make changes at the Global Privacy Settings Panel.

Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

4. Sharing User Information with Sub-Processors

In order to provide the UFB services to its Customers, Photobooth shares data regarding Users with a number of third party service providers. These companies are contractually required to use User data solely as directed by Photobooth for the purpose of providing services to Photobooth.

  • Instructors who upload courses on the Photobooth platform and made available through the UFB services as well as their teaching assistants, who may receive names and account profile information of Users, to enable them to respond to user questions and feedback.
  • Other service providers of Customer, as instructed by Customer.
  • To perform its services, Photobooth leases servers from data centers operated by Equinix and located in Virginia and California in the United States. Photobooth also contracts with Amazon Web Services (AWS) for hosting services, and certain content and User data relating to UFB is hosted via AWS’s cloud hosting solutions.
  • Photobooth’s help center platform vendor (Zendesk as of the effective date of this Privacy Statement) hosts and stores all communications between Administrators or Users and the Photobooth support team. Zendesk is contractually required to store and process User related data solely as directed by Photobooth for the purpose of providing services to Photobooth. Photobooth also partners with Intercom, a chat messaging tool for support to Users and Administrators and for collecting their feedback, as well as in-app messages such as feature announcements or onboarding for new users.
  • Photobooth shares User information with third party companies that perform email services to enable Photobooth to send email communications to Users and to manage email preference settings of Users.
  • Administrators of existing Customers are able to access our list of current sub-processors on the left sidebar of this page while logged in to Photobooth for Business.
  • Photobooth shares User information with third party companies that perform data analysis services to enable Photobooth to better understand how Users use the UFB service. These companies include Chartio, Google Analytics and Hotjar. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser by clicking here, and may also use Mixpanel’s opt out by clicking here.

Any other sharing of User data is subject to the consent and instructions of Customer.

5. Processing of User Data outside of the EEA

All data processing described in this Privacy Statement occurs in the United States, Ireland and, for R&D purposes, Turkey. If personal data processed by Photobooth originates from a User or Administrator in the EEA, Photobooth will ensure, that such processing will only take place if: (a) the non-EEA country in question ensures an adequate level of data protection; (b) the transfer is made pursuant to a Data Processing Agreement (“DPA”) executed between Photobooth and the Customer and subject to the standard contractual clauses designed to facilitate transfers of personal data from the EEA to all third countries that have been adopted by the European Commission (known as the, “Model Clauses”), which have been incorporated into the DPA.