Privacy Policy

Pemberton Portraits operates the website pembertonportraits.com. We create custom pet portraits for dog and cat owners (the "Services"). This Privacy Policy describes how we collect, use, and disclose your personal information when you visit, use, or make a purchase through the Services, or otherwise communicate with us.

For the purpose of applicable data protection laws, we are the data controller of your personal information. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your personal information.

By using the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your information as described here.

When we use the term "personal information," we mean information that identifies or can reasonably be linked to you. Depending on how you interact with the Services, we may collect the following categories:

• Contact details — your name, billing address, shipping address, phone number, and email address.
• Financial information — payment card information, financial account details, transaction details, form of payment, and payment confirmation. Card numbers are handled by our payment processor and not stored by us.
• Pet information — your pet's name and the photos you upload to create a portrait.
• Transaction information — the items you view, add to cart, purchase, return, exchange, or cancel, and your past transactions.
• Communications with us — the information you include when contacting us (for example, in a customer support email).
• Device information — your device, browser, or network connection, your IP address, and other unique identifiers.
• Usage information — how and when you interact with or navigate the Services.
• Session data — we create an anonymous session for every visitor so you can continue where you left off without signing up. This session is stored in your browser and linked to your activity on our site.

• Directly from you — when you use the Services, provide information at checkout, upload a pet photo, or communicate with us.
• Automatically through the Services — from your device when you use our products or visit our website, and through cookies and similar technologies.
• From our service providers — when we engage them to enable certain technology (for example, our payment processor and our analytics providers) and they collect or process personal information on our behalf.

• Provide, tailor, and improve the Services. To perform our contract with you: process your payments, fulfill your orders, generate your portrait, deliver digital downloads, arrange shipping, handle returns or exchanges, remember your preferences, and create a smoother shopping experience.
• Marketing and advertising. To send marketing and promotional communications (for example, occasional emails) and to show you online advertisements for our products on other websites, including based on items you previously viewed, added to cart, or purchased.
• Security and fraud prevention. To provide a secure payment and shopping experience, detect and investigate possible fraudulent, illegal, or malicious activity, protect public safety, and secure our Services.
• Communicating with you. To provide customer support, respond to your inquiries, and maintain our business relationship with you.
• Legal reasons. To comply with applicable law, respond to valid legal process (including requests from law enforcement), investigate or participate in civil discovery, potential or actual litigation, or enforce our terms or policies.

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy:

• With service providers who perform services on our behalf, such as payment processing, data hosting, analytics, customer support, fulfillment, and shipping.
• With business and marketing partners to advertise to you. Our business and marketing partners use your information in accordance with their own privacy notices.
• When you direct or consent to disclosure of certain information to third parties, such as when we ship your order to a carrier.
• With our affiliates or otherwise within our corporate group.
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants, and similar requests), to enforce our terms, or to protect our rights and the rights of our users.

We use the following services, each of which may collect data according to their own privacy policies:

• Supabase — hosts session data, pet information, and generated portraits. Data is stored on servers in the United States.
• Shopify — our current payment processor. See "Payment processing" below.
• Google Analytics (GA4) — tracks aggregate usage patterns (pages visited, time on site, general location). You can opt out via the Google Analytics Opt-out Browser Add-on.
• Microsoft Clarity — records anonymized session replays and heatmaps to help us improve the site. No payment or password data is recorded.
• Meta Pixel (Facebook/Instagram) — measures the effectiveness of our advertising on Meta platforms. If you have an account on those platforms, Meta may link your visit to your profile. You can manage this via Meta Ad Preferences.
• Pinterest Tag — measures conversions from Pinterest advertising. Governed by the Pinterest Privacy Policy.

Our website is not hosted by Shopify. We currently use Shopify only as our payment processor to handle checkout and payment. When you place an order, the billing and payment information you submit at checkout is transmitted to Shopify to process the transaction. Shopify receives and processes this information in accordance with its own Privacy Policy. We do not store or handle credit card numbers ourselves.

Because payment providers may be located outside your country of residence, payment information may be transferred, stored, and processed internationally. We may change or replace our payment processor at any time.

We use cookies and similar browser storage to keep your session alive between visits and to support the analytics and advertising services listed above. You can disable cookies in your browser settings. Doing so may prevent session resumption and some site features from working correctly.

The Services may provide links to websites or other online platforms operated by third parties. If you follow links to sites that are not affiliated with or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites. Our inclusion of such links does not, by itself, imply any endorsement of those platforms or their owners or operators.

We take reasonable steps to protect your personal information. However, no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." Any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on the type of data and our purpose for holding it. Pet photos and session data are retained for as long as your session is active. Generated portraits linked to a completed purchase are retained to support download delivery and order history. Order records are retained as required for accounting and legal obligations. If you would like your data deleted, contact us and we will remove it within 30 days to the extent permitted by law.

Depending on where you live, you may have some or all of the following rights in relation to your personal information. These rights are not absolute and may be subject to exceptions and conditions under applicable law.

• Right to access / know — request access to the personal information we hold about you.
• Right to delete — request that we delete personal information we maintain about you.
• Right to correct — request that we correct inaccurate personal information we maintain about you.
• Right of portability — receive a copy of the personal information we hold about you, or ask us to transfer it to a third party, in certain circumstances.
• Right to opt out of sale, sharing, or targeted advertising — opt out of the "sale" or "share" of your personal information or of processing for targeted advertising, as defined in applicable privacy laws. If you visit our website with the Global Privacy Control opt-out preference signal enabled, we will automatically treat this as an opt-out request for the device and browser you use. To learn more about Global Privacy Control, visit globalprivacycontrol.org.
• Managing communication preferences — opt out of promotional emails at any time using the unsubscribe link in our emails. Non-promotional emails (such as order confirmations) will still be sent.

If you reside in the UK or European Economic Area, and subject to exceptions and limitations under local law, you may also exercise the following rights:

• Objection and restriction of processing — ask us to stop or restrict our processing of personal information for certain purposes.
• Withdrawal of consent — where we rely on your consent, you have the right to withdraw it. Withdrawing consent does not affect the lawfulness of any processing based on your consent before its withdrawal.

To exercise any of these rights, contact us using the details at the bottom of this policy. We will not discriminate against you for exercising any of these rights. We may need to verify your identity before processing your request. You may also designate an authorized agent to act on your behalf, subject to proof of authorization. We will respond to your request in a timely manner as required under applicable law.

If you have complaints about how we process your personal information, please contact us using the contact details provided below. Depending on where you live, you may have the right to appeal our decision by contacting us, or to lodge a complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here. For the UK, you may contact the Information Commissioner's Office at ico.org.uk.

We may transfer, store, and process your personal information outside the country you live in, including in countries that may have different data protection laws.

If we transfer your personal information out of the European Economic Area or the United Kingdom, we will rely on recognized transfer mechanisms such as the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant UK authority, unless the transfer is to a country that has been determined to provide an adequate level of protection.

The Services are not intended for children, and we do not knowingly collect personal information from children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their personal information, please contact us using the details below to request its deletion. As of the effective date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as defined in applicable law) personal information of individuals under 16 years of age.

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on this website, update the "Last updated" date, and provide notice as required by applicable law.

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at bella.soluna.ltd@gmail.com or write to us at:

Pemberton Portraits
16-48 Cambridge Road
ENG, IG11 8SX
United Kingdom

For the purpose of applicable data protection laws, we are the data controller of your personal information.