PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (CCPA)

This Privacy Notice (hereinafter the “California Privacy Notice” or “Notice”) supplements the information contained in Photo2painting (Giotto Group Inc.) privacy policy (the “Privacy Policy “). It applies to Users (as defined in Privacy Policy) residing in the State of California (“California consumers”), who are entitled to certain rights and protections concerning their Personal Information under the California Consumer Privacy Act of 2018 (the “CCPA”).

As required under the CCPA, we will update this Notice every 12 months. The last revision date will be reflected in the “Last Updated” heading located at the top of this Notice.

The terms “personal information”, “business purpose”, “commercial purpose”, “sale,” and “service provider” as used in this Notice have the meanings ascribed to them in the CCPA. Capitalized terms used but not defined in this Privacy Notice will have meanings in the Privacy Policy. If there is any conflict or inconsistency between the terms of this Notice and the Privacy Policy, the terms of this Notice will govern.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT FROM CALIFORNIA CONSUMERS

In the preceding 12 months, we have collected the following categories and types of personal information from California consumers and intend to continue doing so subject to the requirements under the CCPA:

• Identifiers, such as name, email addresses, and billing and shipping addresses for online purchases.
• Customer characteristics, which includes the categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including physical characteristics, payment information and, for employment candidates, education and employment history.
• Commercial information, including purchasing habits, such as the products you have ordered or considered (i.e., placed in your basket but never ultimately purchased), as well as your purchasing history.
• Technical identifies, such as the internet and other similar network activities, such as browsing history and cookie history.
• Geolocation data.
• Audio and visual information, such as pictures you may have uploaded to our site and recorded customer services calls.
• Inferences are drawn from the above information to create consumer profiles reflecting particular preferences and behaviors and customized content/offerings.

Please see the “What Information We Collect” section in our Privacy Policy for more information about the types of personal information we collect.

2. BUSINESS OR COMMERCIAL PURPOSE FOR COLLECTING, SHARING AND SELLING INFORMATION.

We collect and share your personal information for the following business and commercial purposes: to authenticate you when you use our websites, to provide customer support, to audit our products and services, to detect security incidents, to debug and fix errors associated with our websites, research, activities to maintain the quality of our websites and products and services, to encourage and enable purchases such as through our various promotions, to provide personalized marketing offers and programs, to enroll you in our newsletter subscription program, and other commercial transactions that occur from time to time.

We do not make your data publicly available, we do not act as data brokers and we do not trade in your data. However, certain standard generally accepted business practices may be deemed as “Sale” of data under the CCPA, such as when we utilize third-party service providers that provide us with services while they retain certain rights to use your data for their own business needs (e.g., Google Analytics, Facebook, fraud detection services, our online marketing service providers, etc.).

If you are a California customer, you have a right under the new definition of “sale”, to request to opt-out of certain data transfers and sharing of personal activities which we operate. Please refer to section 3 – “Your California Consumer Rights” below, for information on how you can exercise your rights.

For more details on how and to whom we share your data please refer to “Sharing your personal information” in our Privacy Policy and to our Cookies Policy .

3. YOUR CALIFORNIA CONSUMER RIGHTS.

California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in 12 months.

You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and “sold” about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months.

If you are a California consumer, you also have the right to request deletion of your personal information (subject to certain exceptions), to opt-out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights (unless permitted by applicable law, such as if the differences are reasonably related to your information).

Our websites do not sell (as “sell” is traditionally defined) your personal information. That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money. However, under California Privacy Notice, sharing information for advertising purposes may be considered a “sale” of “personal information.” Therefore, if you’ve visited our digital properties within the past 12 months, under the CCPA, personal information about you may have been “sold” to our advertising or other partners for their own use. California residents have the right to opt-out of the “sale” of personal information, and we’ve made it easy for anyone to stop the information transfers that might be considered such a “sale” from our website or mobile app.

California consumers may make a rights request by submitting a respective request to info@photo2painting.com. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal data, which may include your email address and name.

Additionally, California consumers may opt-out of the “sale” of information as described above by changing their Privacy Preferences.

Please note that by opting out of the sharing of your personal information considered as sale as defined by CCPA:

• You may still see some tailored advertising that third parties may have previously collected unless you opt-out of all interest-based advertising (see our Cookies Policy or visit www.aboutads.info/choices)
• We will still share your personal information with our service providers to provide the services on our websites.
• These settings may not persist if you clear your cookies, switch devices or switch browsers. If you access our websites from other browsers or devicesappliances, you will also need to select each browser and device. If you delete or clear cookies, you’ll need to click the button again the next time you visit. If you delete or clear your cookies, that will delete our opt-out cookie, and you will need to opt-out again. If you have previously requested that we do not sell your personal information, your request remains in effect until you tell us otherwise.