Industries

  • Media and Entertainment
  • Visual Arts

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 8/26/2018
Next Certification Due Date: 4/24/2021
Data Collected: NON-HR

Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 8/26/2018
Next Certification Due Date: 4/24/2021
Data Collected: NON-HR

Purpose of Data Collection

Imgur processes no "personal data" as defined by Article 4(1) of the GDPR because Imgur collects no "personal data": Imgur has no way of using the data it collects to identify any individual in the EEA (or anywhere else). The reason Imgur joined the Privacy Shield program is that Imgur passes some of the data it collects along to third party "ad partners" (online advertising companies), which also process that data. Some of the anonymous data Imgur collects such as device ID or IP address could become "personal data" if Imgur's ad partners were able to match it up with other data in their possession so as to identify individuals within the EEA. Imgur shares data only with ad partners that are either GDPR-compliant or Privacy-Shield-compliant, and they, in turn, require Imgur to likewise be either GDPR- or Privacy-Shield- compliant. Imgur is an image hosting company that allows anonymous users to post funny or interesting photos or other images, and to comment on (and up- or downvote) other images that are posted. A brief glance at www.imgur.com is the best explanation in this regard. Imgur requires usernames, but does not request or collect personal names, addresses, or locations. To create a username, a user must provide a cell phone number, which Imgur never sees. Imgur does not store the mobile phone number but instead creates a one-way hash of it and associates the username only with the hash. The hash cannot later be used to identify the number; its purpose is to help prevent abuse while allowing users to stay anonymous: If a user gets banned for rules violations or illegal conduct and tries to set up a new account using the same cell number, that cell number will generate the same hash, which will be marked as "banned user" and no new account can be set up. Othewise, Imgur collects IP address, browser ID, date and time of login, device ID for mobile devices, page and image viewing statistics, and incoming and outgoing links. Imgur also logs the metadata associated with uploaded images but associates the metadata with images, not users. Imgur uses this anonymous data to analyze how its site and app are used so as to keep them optimized, to determine the popularity and usefulness of various features, to maintain the integrity of user accounts so that each user can see his or her posts and the upvotes, downvotes, and comments to them, and to enable users with usernames to access their posts, albums, and membership information. Imgur also uses such data to comply with copyright law (DMCA requirement to delete accounts of repeat infringers), to comply with 18 USC §2258A (reporting child pornography to NCMEC), and to respond to lawful requests by public authorities, including national security, courts, and law enforcement. Imgur also allows users to contact the company via email -- for example to send DMCA takedown notices -- but considers email addresses from users who contact Imgur to be business correspondence; Imgur does not pass email information along to advertisers. Third party advertisers (or their partners) may place and/or recognize cookies on devices used by Imgur users; such cookies collect data about which pages and ads the user views while the user is using the Imgur site or app. Advertiser cookies are used to generate customized ads for display on the user's device based on the anonymous information collected. No personal data is on, connected to, or derivable from, such cookies.

Privacy Policy

Non-HR Data

Document: Privacy Policy
Description:

Same privacy policy as previously submitted for self-certification, but with added update to comply with the California Consumer Privacy Act (CCPA).

Effective Date: 12/10/2019

Verification Method

Self-Assessment

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Imgur, Inc. at:

Robert Ellis
General Counsel
Imgur, Inc.
600 California Street Fl. 11
San Francisco, California 94108

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Imgur, Inc. to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Imgur, Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission