Effective Date: February 19, 2025

Fingerpaint Privacy Policy

Fingerpaint Marketing, Inc. and all its wholly owned subsidiaries (collectively, “Fingerpaint,” “Company,” “we,” “us,” “our”) provide this statement (the “Privacy Policy”) to describe how we collect, use, and disclose information about the individuals who visit our website at www.fingerpaint.com and other websites or online services we operate that link to this Privacy Policy (the “Site”).

In most instances Fingerpaint acts as a “data processor” or “service provider” to provide its services to third-party companies. As a result, you may have to contact the “controller” of information we maintain about you, or refer to those controllers’ own privacy policies, to learn about their information practices and what data rights may be available to you.

I. COLLECTION OF INFORMATION

We collect the following categories of information when you use our Site:

Information you provide directly to us.
- Contact Information and Identifiers, including name, email address, telephone or mobile phone number, address, company name, job title, business unit of interest, and information like username or password if you register on our Site in order to receive additional information.
- Correspondence you send to us, such as through contact forms, open text fields available on the Site, email, or other communications.
Information we collect automatically. We (and other entities) collect internet or other electronic network activity information, and other information automatically from the devices and browsers that you use relating to your interactions with us and our Site, including your device type, IP address, device and advertising identifiers, pages that you visit before and after using the Site, browsing history, and search history, the date and time of your visit, information about the links you click, pages you view, and other information about how you use the Site. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. Consistent with your mobile device or app permissions, we also collect geolocation information (including geolocation information derived from your GPS, Wi-Fi and Bluetooth signals, IP address, and other device information).

II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above for the following lawful bases of processing in the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland, and for the following business purposes in the United States:

With your consent (which may subsequently be withdrawn at any time by contacting us):
- To provide you with the information, products, and services that you request from us;
- To allow you to participate in interactive features of our Site, when you choose to do so;
- To manage accounts and to manage our relationship with you, including by responding to your inquiries;
- To promote and market our services, including by making suggestions and recommendations to you about things that are similar to those that you have inquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates;
For our legitimate interests:
- To notify you about changes to our terms or this Privacy Policy;
- To operate and improve our Site and services, including for analytics purposes, and to ensure that content is presented in the most relevant and effective manner for you and for your device;
- To administer our Site and services, including troubleshooting, data analytics, and testing;
- To keep our Site, services, business, and users safe and secure.
For compliance with our legal obligations:
- To comply with applicable laws and regulations, protect or exercise our legal rights or defend against legal claims, maintain the security and integrity of our Site, and carry out processing necessary in the context of a business reorganization or group restructuring exercise.

We may use information that has been de-identified or aggregated without limitation.

III. DISCLOSURE OF INFORMATION

We may disclose the information we collect with other parties, including the following:

Authorized third-party vendors and service providers. We disclose your information to third-party vendors and service providers that provide services to us for a variety of business purposes, such as customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, verifying customer information, research, data hosting, auditing, and other forms of data processing. We also may disclose your information to our legal or business advisors.
Corporate affiliates. We may disclose your information to our corporate affiliates or joint venture partners that we may have in the future.
Business transfers. We may disclose your information in connection with a substantial corporate transaction, such as the sale of a website, a service, or the Company; a merger; an acquisition; a consolidation; an asset sale; an initial public offering; or in the unlikely event of bankruptcy or as part of a bankruptcy proceeding.
Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, or as otherwise required by law, and to protect and defend the rights, interests, safety, and security of Fingerpaint, our affiliates, users, or the public.
With your consent. We may disclose information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

We may share information that has been de-identified or aggregated without limitation.

IV. COOKIES AND SIMILAR TECHNOLOGIES

When you access our Site, we and our third-party partners (such as data analytics providers) use cookies, pixel tags, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. For additional information, please reference our Cookie Policy.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

Google Analytics. We may work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. Fingerpaint uses Google Analytics to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

V. THIRD-PARTY LINKS AND TOOLS

The Site may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Site also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.

Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

VI. YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable laws in certain jurisdictions, to exercise certain privacy rights and choices with respect to information collected about you. If you are subject to the privacy laws of such jurisdictions, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you. Requests should be submitted as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.

Personal Information We Collect and Disclose. In the preceding 12 months, Fingerpaint collected and disclosed the categories of personal information identified above in the “Collection of Information” section of this Privacy Policy to the categories of recipients of personal information identified in the “Disclosure of Information” section of this Privacy Policy.

We do not “sell” or “share” your “personal information,” or engage in “targeted advertising,” as those terms are defined under applicable law. We do not process opt-out preference signals because we do not engage in this activity.

Categories of Sources. We collect personal information from the following categories of sources:

You;
Our affiliates and joint venture partners;
Our business partners; and
Our service providers.

Our Purposes for Processing Personal Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described above in the “Use of Information and Purpose of Data Processing” section of this Privacy Policy.

We may use and share de-identified information to the extent permitted by applicable law. When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our deidentification processes satisfy the requirements of applicable law.

Your Rights. Residents of certain jurisdictions have rights with respect to the personal information collected by Fingerpaint. You may be able to exercise the following rights regarding our personal information, subject to certain exceptions and limitations and subject to our verification of your identity in accordance with applicable law.

Right to Confirm Processing. You may have the right to confirm whether we are processing personal information about you.
Access / Right to Know. You may have the right to know the categories and specific pieces of personal information we collect, use, and disclose about you; the categories of sources from which we collected personal information about you; our purposes for collecting personal information about you; the categories of personal information about you that we have disclosed for a business purpose; and the categories of third parties with which we have disclosed personal information. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Right to Restrict Processing. You may have the right to restrict certain types of personal information processing where allowed by applicable law.
Portability. Upon request and when possible, you may have the right to receive a portable and readily usable copy of the personal information we have collected about you, to the extent feasible.
Correction. You may have the right to correct inaccuracies in the personal information we have collected about you by accessing your account directly or by contacting us.
Deletion / Erasure. You may have the right to request that we delete the personal information we have collected about you, subject to certain exceptions set forth in applicable law.
Choice Regarding Sensitive Information. Depending on your jurisdiction, you can:
- Limit our use and disclosure of certain “sensitive” personal information to uses and disclosures that are necessary to perform our services or provide goods or services reasonably expected by the average consumer;
- Opt-out of our processing of certain “sensitive” personal information; or
- Withdraw consent for such processing if you previously gave it.
Non-Discrimination. You may have the right not to receive discriminatory treatment for the exercise of the above privacy rights.

Exercising your rights. To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

Submit a request via our webform here https://www.fingerpaint.com/privacy-form
Submit a request via email at privacy@fingerpaint.com

Authorized Agents and Privacy Rights Requests. Depending on your jurisdiction, you may designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

Verification. To help protect your privacy and maintain security, we may take steps to verify your identity before processing certain privacy rights requests. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

Lodging a Complaint. Depending on your jurisdiction, you may be permitted to lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.

Other Choices. You may also unsubscribe from any email communications you receive from us by clicking the unsubscribe link within the email or by contacting us and requesting to be removed from our marketing list.

VI. INTERNATIONAL TRANSFERS

By using the Site and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction. To the extent you are a resident of a country other than the United States, you acknowledge that your personal information may be transferred to the United States for processing by us in accordance with this Privacy Policy.

Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA, UK, or Switzerland, including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality, and the Company implements measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below.

VII. CHILDREN

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law. Additionally, we do not knowingly sell or share personal information of individuals under 16.

VIII. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws, or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or to satisfy and similar essential purposes. To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of information, the purposes for which we process information, and whether we can achieve those purposes through other means, and the applicable legal requirements. Once the retention period expires and if not otherwise required to retain information by law, we will delete or de-identify personal information.

We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data are reliable for their intended use and are accurate, complete, and current. You should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

IX. CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. Where required by applicable law, we will provide you with notice of updates to the Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Site to stay informed of our privacy practices.

X. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please contact us:

Fingerpaint Marketing, Inc.
18 Division St
Suite 212
Saratoga Springs, NY 12866
Email address: privacy@fingerpaint.com