Privacy Policy —

Contact: reko@rponton.com

Summary

Reko Ponton Photography (“we,” “us,” “our”) provides lifestyle photography services to schools & preschools, families, and businesses. We use private, access-code galleries and a modern online store for proofing and orders. This Privacy Policy explains what we collect, how we use and share information, how we protect it, and the choices and rights available to you.

Note for schools: When engaged by a school, we act as the school’s service provider/processor under the school’s direction. The school typically remains responsible for parent notices and consents under applicable student privacy laws. We do not use student information for advertising.

1) Information We Collect

We collect information in three main ways: you provide it, a school or organization provides it, or we collect it automatically when you use our services.

A. Information you or your organization provides

  • Contact & account info: name, email, phone number, role, organization/school, class/teacher.

  • Order details: recipient name, shipping address, ordered products, transaction totals, order history.

  • Images & session data: portraits and related session metadata (date, location, pose selections, favorites).

  • Communications: inquiries, support requests, survey responses, scheduling details.

  • Consent & releases: model releases, yearbook image selections, marketing permissions.

B. Information from schools/organizations (school services)

  • Rosters & identifiers: student name, grade, homeroom/teacher, student ID (if provided), access-code mapping.

  • Administrative notes: make-up/retake status, yearbook selections, delivery preferences.

C. Information collected automatically

  • Device & usage data: IP address, device type, browser, pages viewed, time on page, referring URLs.

  • Cookies & similar tech: used for authentication (access codes), remembering cart items, and analytics (see Cookies section).

D. Payment information

  • Handled by a third-party processor. We do not store full credit card numbers. Our processors collect payment card data directly and process it under their own privacy and security standards (e.g., PCI DSS).

2) How We Use Information

We use information to:

  • Provide and improve services: create and manage private galleries, fulfill orders, process payments, deliver prints/digitals, and support yearbook exports (PSPA).

  • Authenticate access: issue and validate unique access codes so families and staff only see their images.

  • Communicate: send service messages (proofs ready, order status, delivery updates), respond to inquiries, and provide scheduling/reminders.

  • School deliverables: generate PSPA yearbook files, class composites, ID cards/stickers (if contracted), and reports requested by the school.

  • Safety, security, and legal compliance: prevent fraud, secure our systems, enforce policies, and meet legal or regulatory obligations.

  • With consent: showcase images in marketing or portfolios only where we have appropriate permission (e.g., explicit parental consent or model release). For school portraits, we rely on school direction and your selections.

Legal bases (EU/EEA/UK where applicable): performance of a contract, legitimate interests (e.g., service quality, security), legal obligations, and consent where required.

3) How We Share Information

We share information only as needed to run our services or as required by law:

  • Service providers (processors): secure hosting, gallery and e-commerce platform, payment processing, print labs, shipping carriers, email/SMS tools, customer support and analytics.

  • Schools/organizations (school services): deliverables such as PSPA exports, class composites, and fulfillment reports, under the school’s direction.

  • Legal and safety: to comply with subpoenas or legal requests, enforce our agreements, or protect rights, safety, and property.

  • Business transfers: in a merger, acquisition, or asset sale, your information may transfer with notice as required by law.

We do not sell personal information. We do not share student information for cross-context behavioral advertising.

4) Children’s & Students’ Privacy

  • We work with schools and parents/guardians to photograph minors. We do not knowingly collect personal information directly from children under 13 without verifiable parental consent or a school’s authorization consistent with applicable law (e.g., COPPA in the U.S.).

  • For school services, we act as a service provider/processor under the school’s direction and policies.

  • Galleries are private and access-code protected; families see only their child’s images.

  • Contact us at reko@rponton.com to review or delete a child’s information subject to school approval or legal requirements.

5) Cookies & Similar Technologies

We use cookies and similar technologies to:

  • Authenticate access codes and keep you signed in to a private gallery or cart.

  • Enable core features (cart, checkout, order tracking).

  • Measure performance and improve the site (basic analytics).

You can manage cookies through your browser settings. Some features may not work properly if essential cookies are disabled. Where required by law, we present a cookie notice and honor your preferences.

6) Your Choices

  • Access codes & gallery privacy: Keep your code confidential. Contact us if you need a new code.

  • Marketing permissions: Opt in/out of optional marketing communications at any time (unsubscribe link). Service messages (e.g., order confirmations) will still be sent.

  • Yearbook image choice: Where enabled, you may select your preferred yearbook image within the ordering window.

  • Model releases: You control whether we may use images for portfolio/marketing; absence of consent means we don’t.

7) Your Rights

Your privacy rights depend on where you live. Subject to applicable law, you may have rights to:

  • Access, correct, or delete your personal information.

  • Request portability of certain information.

  • Restrict or object to certain processing.

  • Opt out of targeted advertising, sale, or sharing of personal information (we do not sell personal information and do not share student data for cross-context ads).

  • Appeal a rights request decision (in certain U.S. states).

How to exercise rights: Email reko@rponton.com with your request. We may need to verify your identity and (for school services) coordinate with your school. Authorized agent requests (e.g., California) must include proof of authority.

8) Data Retention

We retain information only as long as necessary for the purposes described above:

  • Galleries: retained for a limited period to allow families/clients to order and download; school galleries may follow school-directed timelines.

  • Orders & invoices: retained as required by tax/accounting laws.

  • Support & communications: retained to resolve issues and improve services.
    When information is no longer needed, we delete or de-identify it, unless a longer retention period is required by law or a school contract.

9) Security

We use administrative, technical, and physical safeguards designed to protect personal information (e.g., access controls, HTTPS encryption in transit, vendor due diligence). No method of transmission or storage is 100% secure. If we discover a security incident affecting your information, we will notify you and any applicable authorities as required by law.

10) International Users

Our services are primarily operated in the United States. If you access them from outside the U.S., your information may be transferred to, stored, and processed in the U.S. and other countries with different data protection laws. Where required, we implement appropriate transfer safeguards.

11) Third-Party Services & Links

Our website and galleries may link to third-party sites or use third-party features (e.g., payment processors, delivery partners). Your use of those services is governed by their terms and privacy policies. We encourage you to review them.

12) Role Clarification (Controller vs. Processor)

  • School services: We generally act as a service provider/processor to the school, which serves as the controller of student information. We process data only to provide contracted services and deliverables and do not use student data for unrelated purposes.

  • Family & business services: When you hire us directly, we act as the controller for your personal information and handle it per this Privacy Policy.

13) Changes to This Policy

We may update this Privacy Policy to reflect changes in our services or the law. We will post the updated date at the top and, where required, provide additional notice. Your continued use of our services after an update means you accept the revised policy.

14) Contact Us

Questions, requests, or complaints about this Privacy Policy or our practices can be directed to:
Email: reko@rponton.com

Important Notice

This policy is provided for general informational purposes and to support your compliance efforts. It does not constitute legal advice. Privacy laws vary by jurisdiction (e.g., FERPA/COPPA for U.S. schools, state privacy laws like CA/VA/CO/CT/UT, and GDPR/UK GDPR). Please have your attorney review and tailor this policy to your specific operations, vendors, and data flows.