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PINNACLE PHOTO AGENCY LTD PRIVACY POLICY

PINNACLE PHOTO AGENCY LTD PRIVACY POLICY

1. Data controller and representative

Through its website (the "Website") and its desktop applications and mobile applications (the "Application"), Pinnacle Photo Agency Ltd implements the processing of personal data listed below. Philip Mingo([email protected]) is the designated representative of Pinnacle Photo Agency Ltd in EU in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of personal data (the "GDPR").

Please read carefully the following privacy policy, which provides you, as the user of the Website and/or Application (the "User" or "You"), with the relevant information regarding the various processing of personal data implemented by Pinnacle Photo Agency Ltd, in accordance with GDPR.

2. Data processing implemented by Pinnacle Photo Agency Ltd

2.1 Processing of personal data related to your visit to our website and the purchase and use of our products

When the User visits to our Website, or purchases a Pinnacle Photo Agency Ltd product through the Website or the Application, or use our products, Pinnacle Photo Agency Ltd implements a processing of personal data as follows:

2.1.1 Personal data collected

Regarding this processing, Pinnacle Photo Agency Ltd collects the following personal data through the collection forms in the ordering process or other processes.

2.1.2 Purpose and legal basis of the processing

Pinnacle Photo Agency Ltd uses the information we collect about you for the following purposes:

In order for Pinnacle Photo Agency Ltd to provide the User with the ordered product(s);

For the performance of a contract to which the User is party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for Pinnacle Photo Agency Ltd to identify and bill the User and to charge its bank card number;

For Verifying your identity and Providing customer service or support;

Analyse your use of our websites and products to better understand how they are being used so we can improve our services and the user experience and engage and retain users.

2.1.3 Recipients of the personal data

We may also transmit your personal information with companies that help us to run our business by processing personal information on behalf of us for the purposes identified above. Such companies include providers of payment processing services, server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers.

In addition, Pinnacle Photo Agency Ltd may disclose the User's personal data:

2.1.4 Transfer of personal data

Pinnacle Photo Agency Ltd may transfer the collected personal data to recipients who are located outside the European Union and such destinations may not have laws that protect the User's personal data to the same extent as in the European Union.

Pinnacle Photo Agency Ltd ensures that the User's personal data processed by Pinnacle Photo Agency Ltd or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

2.1.5 Duration of the storage

Pinnacle Photo Agency Ltd will store the collected personal data for the duration of the contract and 60 days after the termination of the contract. Beyond this duration, in order for Pinnacle Photo Agency Ltd to be able to demonstrate the existence of a right or a contract or a legal obligation, the relevant personal data will be stored through intermediary archives for a duration that will not exceed what is strictly necessary regarding the purpose of the storage and in accordance with the applicable legislation.

Regarding banking information, said information would be deleted once the payment has been processed and has become effective. Withdrawal time period could additionally apply. The number and

the expiration date of the credit card number (not the CVV security code) could be stored through intermediary archives for evidence purposes in case of a claim regarding the payment, for the duration provided by Article L. 133-24 of the French Monetary and Financial Code (13 months or 15 months in case of deferred charge card).

2.2 Processing of personal data related to comments areas

When the User decides to comment a Pinnacle Photo Agency Ltd product through the Website or the

Application, Pinnacle Photo Agency Ltd implements a processing of personal data as follows:

2.2.1 Personal data collected

Regarding this processing, Pinnacle Photo Agency Ltd collects the following personal data:

2.2.2 Purpose and legal basis of the processing

This processing is implemented by Pinnacle Photo Agency Ltd in order to improve its products and provide the consumers and potential consumers with better and transparent information about the Pinnacle Photo Agency Ltd and Pinnacle Photo Agency Ltd products. The User on a voluntary basis provides said comments and the related personal data so that the processing of the collected personal data relies on the User's consent.

Pinnacle Photo Agency Ltd may use the comments (with your relevant information) you post for marketing purpose in order for others to better understand and use our products.

2.2.3 Recipients of the personal data

Pinnacle Photo Agency Ltd may transmit the collected personal data to third party email delivery service providers, social medias, other marketing platforms and service providers.

2.2.4 Transfer of personal data

Pinnacle Photo Agency Ltd transfers the collected personal data to recipients who are located outside the European Union and such destinations may not have laws that protect the User’s personal data to the same extent as in the European Union.

Pinnacle Photo Agency Ltd ensures that the User's personal data processed by Pinnacle Photo Agency Ltd or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

2.2.5 Duration of the storage

Pinnacle Photo Agency Ltd will store the collected personal data for not more than 5 years after the collection.

2.3 Processing of personal data related to newsletters and advertising emails

The User may want to subscribe to Pinnacle Photo Agency Ltd.\’s newsletter in order to be provided with information and news regarding Pinnacle Photo Agency Ltd products. In this case, Pinnacle Photo Agency Ltd implements a processing of personal data as follows:

2.3.1 Personal data collected

Regarding this processing, Pinnacle Photo Agency Ltd only collects your provided information such as the User’s email address, name or nickname, country, preferred product, and your operation to the promotion emails.

2.3.2 Purpose and legal basis of the processing

Pinnacle Photo Agency Ltd implements the processing of personal data in order to provide consumers and potential consumers with information and news regarding Pinnacle Photo Agency Ltd products. The subscription to Pinnacle Photo Agency Ltd.’s newsletter and the related provision of personal data is made on a voluntary basis so that the processing of the collected personal data relies on the User's consent.

2.3.3 Recipients of the personal data

Pinnacle Photo Agency Ltd may transmit the collected personal data to providers of email delivery service and other service providers such as data analysis providers and server providers.

2.3.4 Transfer of personal data

Pinnacle Photo Agency Ltd transfers the collected personal data to recipients who are located outside the European Union and such destinations may not have laws that protect the User's personal data to the same extent as in the European Union.

Pinnacle Photo Agency Ltd ensures that the User's personal data processed by Pinnacle Photo Agency Ltd or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

2.3.5 Duration of the storage

Pinnacle Photo Agency Ltd will store the collected personal data for 3 years from their collection or from the last contact from the User (whichever is later).

At the end of this 3- years time period, Pinnacle Photo Agency Ltd may contact the User in order to know if the User wishes to keep receiving commercial information from Pinnacle Photo Agency Ltd.

In case Pinnacle Photo Agency Ltd would not receive any positive and explicit answer from the User, the personal data would be deleted or archived in accordance with the applicable legislation.

2.4 Cookies and trackers

When the User consults the Website and/or the Application, Pinnacle Photo Agency Ltd implements cookies and other trackers on the User's device.

For additional information on cookies and trackers, please read Pinnacle Photo Agency Ltd.’s cookies policy

3. User's rights

To the extent required by the law of your jurisdiction, you may have below rights. Before you exercise below rights, you may consult your legal counsel if the laws of your jurisdiction stipulate below rights.

Rights

Content

The right to be informed

The User has the right to be provided with clear, transparent and easily understandable information about how Pinnacle Photo Agency Ltd collects and uses personal data and its rights. This is the reason why Pinnacle Photo Agency Ltd is providing the User with the information in this privacy policy.

The right of access

The User has the right to obtain access to its personal data (if Pinnacle Photo Agency Ltd is processing it), and other certain information (similar to that provided in this privacy policy).

The right to rectification

The User is entitled to have its personal data corrected if it is inaccurate or incomplete.

The right to erasure

This "the right to be forgotten" enables the User to request the deletion or removal of its personal data where there’s no compelling reason for Pinnacle Photo Agency Ltd to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

Under certain circumstances, the User has the rights to block or suppress further use of its personal data.

The right to data portability

The User has the rights to receive its personal data provided to Pinnacle Photo Agency Ltd in a structured, commonly used and machine readable format and has the right to transmit those data to another controller.

The right to object to processing

The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data.

The right to lodge a complaint

The User has the right to lodge a complaint about the way Pinnacle Photo Agency Ltd handles or processes its personal data with its national supervisory authority (in France, the CNIL).

The right to withdraw consent

If the user has given its consent for a specific processing of its personal data implemented by Pinnacle Photo Agency Ltd, the User has the right to withdraw its consent at any time. In case the User does so, it does not mean that anything Pinnacle Photo Agency Ltd has done with the Users personal data with its consent up to that point is unlawful).

The right to define instructions

The User has the right to define general or specific instructions regarding storage, deletion and use of its personal data after death.

4. Revision of this Privacy Policy

Occasionally, we may change this privacy policy (or other documents related to privacy policy) to allow Pinnacle Photo Agency Ltd to use or share your personal data in a different way. If we do, the links to the policy on our websites (which are generally found in the footer of the website) will indicate that the policy has been changed. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective 30 days after posting. We encourage you to periodically review the privacy policy for the latest information on our privacy practices.

5. Contacting Pinnacle Photo Agency Ltd

If the User needs to contact Pinnacle Photo Agency Ltd for any reason (including to exercise any of its rights in relation to data protection as set out above) please contact [email protected]

Pinnacle Photo Agency Ltd will act on the User's requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case Pinnacle Photo Agency Ltd may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.