Privacy Policy

Privacy Policy

Effective Date:  January 1, 2020
Welcome to (the “Site”), operated by JCPenney Portraits by Lifetouch, a member of the Shutterfly family of brands (collectively "Lifetouch," "we," "our," or "us").   At Lifetouch, we are sensitive to the privacy concerns of the individuals we photograph and of visitors to our websites, and we want you to know that your privacy is important to us.
What does this Policy cover?
Unless we notify you otherwise in connection with a particular activity, this Privacy Policy explains how we collect and use information through the Site, and the choices you can make about the collection and use of your information.  This Policy also addresses information we collect from you when you schedule an appointment to be photographed, visit one of our studios or on-site photography locations to be photographed and to order products, contact one of our customer service representatives, sign up to receive special offers or respond to a survey or enter a contest or sweepstakes that we administer. 

What personal information do we collect? How do we use that information?
We collect various types of personal information when you purchase any products or services from us; schedule an appointment to be photographed; visit or are photographed at one of our studios, or on-site photography locations; contact one of our customer service representatives; register for customer rewards programs; or complete a survey or enter a contest or sweepstakes that we sponsor. This information may be collected directly from you (for example, when you complete our forms or enter your information on our websites to make a purchase) or indirectly through your device or browser when you visit our Site. 
We use your information to fulfill product orders, to deliver marketing communications and promotional materials that you may be interested in, to contact you and provide customer service, to protect the security or integrity of our databases or websites, to take precautions against liability, to detect and remediate violations of our Terms of Use or other misuse of our Site, to develop and improve our products and services, and for internal operational purposes.
The following chart describes what categories of personal information we may collect, how we collect that information from you, the business purposes for which we generally use such information, and which types of trusted third-party service providers we may share that information with:
Information Type Source Purpose Third-Party Sharing
Direct Identifiers (Customer Name, Postal Address, Phone Number, Email Address) Provided directly by customer
Maintaining and servicing your account
Providing customer service
Processing and fulfilling your orders
Processing payments on your orders
Fulfilling customer rewards
Advertising and marketing our products to you
Product creation and order fulfillment vendors
Customer service providers
Marketing and advertising services
Appointment scheduling services
Surveys, sweepstakes, and contest administrators
Payment and chargeback processors
Mailing and shipping services
Household Information
Family Members
Date of birth and/or age
Provided directly by customer
Maintaining and servicing your account
Processing and fulfilling your orders
Fulfilling customer rewards
Product creation and order fulfillment vendors
Appointment scheduling services
Payment information (credit card information (only last four digits are stored), checks) Provided directly by customer Processing payments on your orders
Customer service providers
Payment and chargeback processors
Purchase information (purchase date, purchase totals, product types) Provided directly by customer
Providing customer service
Processing and fulfilling your orders
Processing payments on your orders
Analytics to improve our products and services
Advertising and marketing our products to you
Product creation and order fulfillment vendors
Customer service providers
Payment and chargeback processors
Digital Identifiers (IP Address, Cookies, Website Browsing and Interaction Activity, Other Device or Browser Identifiers) Collected indirectly from customer’s browser or device
Enhancing your user experience
Analytics to improve our products and services
Advertising and marketing our products to you
Marketing and advertising service providers
Website performance and analytics vendors
We and our service providers collect information about how you use our services, for example what web or mobile pages you have viewed, to analyze trends, generate analytics, provide a better user experience, improve our products and services, detect and prevent fraud or security incidents and gather broad demographic information for aggregate use. The Site uses pixel tags, web beacons, and similar tracking technologies (collectively referred to as “Cookies”) that are created when you use our online services and are stored on your computer or mobile device. 
Cookies help us offer convenient features like recognizing your browser when you visit, customizing your current and future visits, and providing you with information about products that interest you. We also use the information we collect to compile statistics about our visitors and their use of our site to monitor site traffic, develop marketing programs, and improve our website design and content.
We use the information collected by our third-party service providers using Cookies to analyze and track data, improve our services, determine the popularity of certain content, and better understand our users’ online activity. Our service providers may also show you advertisements for our products and services on other websites, and may combine this information with other information those service providers have gathered about your visits to those other websites so that the advertisements you receive are more likely to be of interest to you.  
Other Sources
We may also obtain data that is publicly available or from third party sources, such as address verification services, to improve the accuracy of and add to what we know about our customers and prospective customers. We may combine this publicly available information with your personal information for the purposes described in this policy.  

Do you share my information with third parties?

We do not sell, license or share the personal information we collect with unaffiliated third parties for their marketing purposes.  We may share personal information in the following situations.
Service Providers
We sometimes use third-party service providers to act on our behalf, for example to help us fulfill your product orders, process payments, enhance and personalize your shopping experience with us, or to deliver our advertisements. Our service providers may receive your name and contact information, payment information, photos and other content you upload to our Site, information about purchases you’ve made, cookies and other device identifiers, IP address, and website browsing and interaction activity. These service providers are only allowed to use your information in connection with the specific service they provide on our behalf.
Partners and Affiliates
JCPenney Portraits by Lifetouch is a licensed department within JCPenney stores, and we share certain information about you with J.C. Penney Company Inc. for purposes described in this Policy. 
If you purchase digital images (or another product that qualifies you to receive digital images) in-studio from JCPenney Portraits by Lifetouch, we may make your digital image available for you to archive in your account or transfer to another website or mobile app we or one of our affiliated companies operate (each an “Affiliated Site”); and if you elect to do that, you are authorizing us to transfer your photos and personal information to the Affiliated Site.  In such case, you will need an account with that Affiliated Site to claim your image, and your use of the Affiliated Site will be governed by the terms of service and privacy policy of that site. 
Business Headshots
If Lifetouch photographs you pursuant to a contract with your employer or other organization you are affiliated with, Lifetouch will share your information with that organization as necessary to fulfill its contractual obligations. 
Law Enforcement, Mergers, and Other Situations
We may be required to share your personal information in other, limited circumstances. For example, we may be required to share certain information to respond to a subpoena or similar judicial process, to comply with state, federal or local laws, to protect the security or integrity of our databases or website, to take precautions against liability, in the event of a corporate reorganization or, to the extent required by law, to provide information to law enforcement agencies. Your information may be transferred to another organization if, for example, we transfer the ownership or operation of the Site because we have merged with or have been acquired by another organization, or if we liquidate our assets. In those cases, the new company’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us. 
The Site is intended for use by general audiences.  We do not knowingly collect personal information from children under the age of 13. If a child has provided personal information through the Site, we ask that a parent or guardian contact the Site in writing at 11000 Viking Drive, Suite 400, Eden Prairie, MN 55344, Attention: Privacy Office or [email protected] and we will respond accordingly.

What options do you have to limit our collection and use of your personal information?

You have choices about how your information is collected and used.  
Opting out of Marketing Communications
If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive, by changing your marketing preferences through your Account Settings, or by contacting us through the Contact Us page of any of our brands. We reserve the right to send you certain communications relating to the services we provide, such as service announcements and administrative messages (for example, communications related to a pending order, an unresolved customer service issue, or a policy update). We do not offer you the ability to opt-out of receiving those communications.
Cookie Options
If you don’t want our Site to collect information using Cookies, you can change your web browser settings to reject Cookies from the site or to alert you before a cookie is placed on your computer. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please note that cookie-based opt-outs only apply to the specific computer and browser on which the opt-out cookie is applied. If you accept a cookie, you can delete it at any time through your web browser. If you choose not to accept Cookies, though, you will not be able to enjoy all the features available to our registered users.
The Network Advertising Alliance (“NAI”) and the Digital Advertising Alliance (“DAA”) offer opt-out tools to help you manage your choices for participating companies that use Cookies for Interest-Based Advertising and cross-app advertising. For more information about these tools please visit: NAI Opt-Out Page and DAA Opt-Out Page. You can also opt out of Google cookies by installing Google Analytics’ opt-out browser add-on, and/or the Google Advertising Cookie out-out browser add-on.
“Do Not Track” is a preference you can set in your web browser to let the sites you visit know that you do not want them collecting information about you. Our sites do not currently respond to “Do Not Track” settings.
If you are a resident of California, please click here to learn more about your rights.

How do we keep your information secure?

Although no website, application, database or system is completely secure or “hacker proof,” we have safeguards in place to protect against unauthorized access and disclosures of the personal information we control, including technical, physical and administrative safeguards and security measures. Despite these measures, however, we cannot guarantee that our information security safeguards will never be compromised.
Our Site may be linked on other websites or may contain links to other websites. Our Privacy Policy only applies to our Site, and we are not responsible for the privacy practices, security standards, or content of other sites. You should check the privacy policies of those sites before providing your personal information to them. 

How do we make updates to this policy?

By using the Site, you consent to our use of your information as described in this Policy. As we implement new technology and introduce new services, or in response to changes in applicable laws or regulations, we will update the Policy, so we encourage you to review it often. We reserve the right to change our Online Privacy Policy at any time without advance notice. We will identify an updated version of this Policy with a revised effective date. Changes to our Policy will become effective when posted. If these changes materially affect how we use personal information collected from you prior to the date of the revised Policy, then we will obtain your consent to the revised Policy before applying it to that personal information.

How can you contact us with questions about your privacy or this Policy?

For further information regarding this website privacy statement or related Lifetouch policies and procedures, please contact: Privacy Office, Lifetouch, 11000 Viking Drive, Eden Prairie, MN 55344; email: [email protected].

Supplemental Notice to California Residents

Effective Date: January 1, 2020
If you are a California resident, California law may apply to how we collect and use your personal information, and what rights you have in some circumstances. The following terms supplement our Privacy Policy and explain the rights of California residents pursuant to the California Consumer Privacy Act of 2018 (CCPA, Cal. Civ. Code § 1798.100 et seq.). 
For information about what categories of personal information we may collect from our customers, the sources of that information, the purposes for collecting and using that information, and what types of third party service providers we may share that information with, please see our section titled What personal information do you collect? How do you use that information? 
California residents have the following rights:
  • The right to request information about personal information that we have collected about that customer in the 12 months preceding the customer’s request (including the categories of information collected, the source of that information, the business purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of personal information collected about that particular customer); 
  • The right to receive requested information in a readily-usable format if provided electronically;
  • The right to request that we delete any personal information about the consumer that we have collected (although we may be entitled to retain some information for certain purposes);
  • The right to opt-out of “sales” of personal information to third parties, if applicable; and 
  • The right to freely exercise your rights without being denied goods or services. 
We cannot respond to your request to access or delete information unless we are able to both verify your identity or authority to make the request and confirm the personal information relates to you and/or your household. If you have an account on any of our Sites, we will verify your identity by having you log in to your account. If you do not have an account on our Sites, we will attempt to verify your request by asking you to provide identifying information that we will match to information in our files. We will only use information you provide in your request for the purpose of verifying your identity or authority to make the request. You can also designate an authorized agent to make a request on your behalf. Your agent will need to provide a Power of Attorney authorizing the agent to act on your behalf, or will need to complete the same verification procedures that would be required for a request submitted by you directly, and provide information that allows us to verify your authorization.
We may deny deletion requests in whole or in part as permitted or required by applicable law.   We do not charge a different price or rate or provide a different level or quality of goods or services based on your exercising your CCPA rights. We do not sell personal information. 
To exercise your rights under California law with respect to one of more of our brands, please contact us as follows:
Call us at (888) 288-2214 or request online at
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on such site.  To make such a request, please send an email with the subject line “California Minor Content Removal Request” to [email protected].  Please specify in your request which website or application your request relates to and the specific information or content that you would like removed.