Privacy Policy

Last updated: October 30, 2023

This Privacy Policy outlines who we are, how we process (i.e. collect, record, organize, structure, store, modify or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destroy) personal information about you, and how you can exercise your privacy rights. We are Pixcham International j.s.a., a company established under the laws of Slovak Republic, with registered seat at: Námestie svätého Egídia 42/97, 05801 Poprad, Slovak Republic ( “Pixcham”, “we“, “our“ or “us“ ), a developer and a publisher of the Pixcham application that is made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our mobile application (“Application”), and through website we manage, including http://www.pixcham.com (“Website”) (Application and Website together as “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

Pixcham operates the Application that provides a fast, beautiful and fun way for you to share selfie photos, tags and other related content (“User Content”) through our content-sharing platform within the Application and allows you to play selfie Challenges and Battles. For more information about the App Platform, please refer to our Terms and Conditions available within the Application and published on the Website.

Before accessing and using our Services, please make sure that you have read and understood how we collect, store, use and disclose your personal information as described in this Privacy Policy.

By using our Services you acknowledge and agree that we are providing a platform for you to post content including User Content, to the Services and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Services, consistent with the terms and conditions of this Privacy Policy.

This Privacy Policy applies to all visitors, users, and others who access the Services ("Users").

For information collected under this Privacy Policy, the data controller is: Pixcham International j.s.a., a company established under the laws of Slovak Republic, with registered seat at: Námestie svätého Egídia 42/97, 05801 Poprad, Slovak Republic.

In general

Protection and security of your personal data is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under the EU data protection laws and regulations that apply to the Users. We have appointed data protection officer to help us ensure compliance with the applicable EU data protection laws and regulations. We store your information for as long as needed to provide you with the Services. We can store information for longer, but only so that it cannot be traced back. We operate globally and we share your information with our partners and service providers (see the list of our current partners and service providers here ) as for the purposes described below in “How We Share Your Information” section of this Privacy Policy, which may include a transfer of your personal information outside of the European Economic Area (the “ EEA ”). Please check regularly for changes to this Privacy Policy.

Our Services may, from time to time, contain links to and from third party websites and/or applications, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites and/or applications have their own privacy policies and that we do not accept any responsibility or liability for their privacy policies. Please check the individual privacy policies before you submit any information to those websites and/or applications.

Information We Collect About You

Most of the information that we collect about you comes directly from you when you use our Services or interact with third-party advertisements in our Application. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you use our Application and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-Application purchases (provided that we never receive your payment or credit card information).

The information that we may collect about you through the Services broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, within the Application we will ask for certain information in order for you to submit enquiries to us, such as:

• your name, email address, date of birth, country of citizenship, or other details, necessary to process your inquiries;
• User Content (i.e. selfie photos, tags, and other related content) that you post within the Services;
• any data and information you submit through our Services;
• any information you submit to our support team via email;

The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.

Should you choose to participate in the Challenge and you win such Challenge you may be required to provide us with your bank account number that will be transferred to respective Challenge Organizer and/or third party service e.g. Wise only in order to pay you the monetary prize.

Information that we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

• Data and analytic data about your use of our Services (e.g. In-app progress, Challenges or Battles played, session length, preferred settings, in-app ads you may have viewed, in-app links or just app preferences, how you were referred to our Services);
• Your IP address and device identifiers such as your Advertising ID, Device ID numbers;
• Your device type and the operating system that you use;
• Your communications within the Service (e.g. emotional signals in the App that you exchange with other players);
• Metadata;
• Log file information;
• Broad geographic location (e.g. country or city-level location) based on your IP address;
• Searching the current geographical location through GPS in the Application while using some of its functions and while making selfies;

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). It is about unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Metadata are usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted. The Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo) or other data. This makes your User Content more searchable by other Users and thus more interactive.

Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) the Website or the Application. It can also be provided when the content of the Website or the Application is downloaded to your browser or device. When you use our Services, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / link pages and URLs, number of clicks and how you interact with links within the Services, domain names, target pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

Some of this information may be collected through cookies as explained further under the Cookies section of this Privacy Policy below.

Information we obtain from third-party sources

• Third-Party Social Networks. You may choose to connect to our Services via your social media account. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as your username, gender, your friends using our Application. (See below also section “Third-Party Social Networks”);
• Third-Party Service providers. We may receive personal information about you from third-party sources. We may get your personal information for example when you installed our Application and prior to installing you have clicked an advertisement for the Application;
• Advertising partners. From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of the Application in other publisher’s applications), we will be provided with information from which ad network and advertising campaign the install originated from (See below also “Advertising” section of this Privacy Policy).

A list of our current service providers and partners is here.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Services and developing new products and features within the Application.

No special categories of information (except for User Content)

Except for processing the User Content, we do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person (except for User Content), data concerning health or data concerning a natural person’s sex life or sexual orientation. Kindly be cautious when sharing this information about yourself (or others) within our Services.

How We Use Your Information

In General

We use the information we collect about you/your device to deliver the Services to you and to operate our business. We use it also for improving our Services, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our Services and also in other publisher’s applications and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations.

We use your information for the following purposes:

Delivering and improving the Services. We use your information for developing, delivering and improving the Services, other products, services, and content, tailoring our Services, providing Application updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Services, and administering the Application.

Displaying advertisements. We use your information for showing advertisements for our Services in other publisher’s applications and for displaying third-party advertisements in our Application. Please see more in Advertising Section of this Privacy Policy.

Marketing. If you give us your consent, we will use your information for direct marketing of our Services and dispatch of business announcements by all available means, including electronic means of communication.

Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.

Analysis and research. We use your information for understanding and analyzing trends in connection with the usage of the Services, gathering demographic information about our user base, data about where the Application was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with the Services, or to test our Application features and content.

Security. We use your information for enhancing the safety and security of the Services.

Customer Support. We use your information for providing customer support to you and to respond to your inquiries.

Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.

How We Share Your Information

We may share your personal information with some third parties in order to provide the successful operation of the Services and for the purposes of developing and delivering the Services, displaying advertisements, conducting analysis and research and for measuring our partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

• Our analytics providers. We use third-party analytics for the purposes of delivering the Services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to you. We can aggregate the data for the comparison function.
• Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers;
• Our tracking and fraud prevention providers. For our Application we use tracking and fraud prevention providers, for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve the Services and for fraud prevention purposes. Such providers may use APIs, and SDKs in our Application to enable them to collect and analyze user and device-related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-Application events.
• Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering and operating the Application.
• Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.

We may contract with additional partners or change existing partners in the future to perform any services in connection with the Services. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.

The list of our current service providers and partners is available here.

Should you choose to participate in the Challenge, and you win such Challenge, we will disclose your information (including personally identifiable information) to the respective Challenge Organizer. You will always be aware on the identity of the Challenge Organizer before entering the Challenge. By entering the Challenge, you agree that we may transfer your personal data to Challenge Organizer in order to award you the prize.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

For any additional questions about third-party information collection, please refer to legal@pixcham.com

Advertising

In General

We use advertising to fund our Services and to make our Application available. We offer some features of our Application for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve the Services and at the same time keep our Application accessible for a wide user base.

Please be aware that:

a) When you use the Services, we rely on our legitimate interest in showing you advertisements. The legal basis to show ads to the Users is the legitimate interest in accordance with the European data protection requirements, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers’ networks in accordance with the applicable legal requirements. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.

b) Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at relevant button at loading of the Application. We allow our advertising partners to show personalized ads to you only if you have pressed “accept” in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you accept to show you personalized ads at loading of the Application. The legal basis to show personalized ads to the Users is the consent in accordance with the requirements under the applicable EU data protection laws and regulations. In addition, a data processing agreements were concluded with external ad technology providers’ networks in accordance with the applicable legal requirements. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve the Services and provide the Users with more relevant ads. You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Application settings and clicking the “Terms & Privacy” button therein, in section Personalized Ads Consent Withdrawal of the Privacy Policy you will be able to manage your preferences by choosing to which advertising you would like to get. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

In-Application advertising (i.e. when you view ads in the Application)

To enable us to show in-Application ads, we may send your Advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Application. You can control and limit our use of your Advertising ID in your device settings. We do not control which specific ads are shown in our Application (it is controlled by ad networks), but we do blacklist certain categories of ads.

Advertising IDs are used by the ad networks for a number of purposes including:

• limit the number of times you see the same ad;
• ensure that they are humans with real devices and not "automated" robots;
• serve you with advertisements likely to be relevant to you based on your Advertising ID engagement with other brands and ads, also recorded using your Advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in the Application. The ad network or ad exchange acts as intermediary between the other application companies and us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertising ID;
• keep track what Challenges or features of the Application you have used to market you similar kind of Challenges or features. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).

View of our ads on third-party services

We also advertise the Services in other applications by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs). The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

• measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ applications);
• informing Users, that have not been using the Application for a while, about new content in the Application. We give a list of these Users in the form of Advertising IDs to an ad network. Ad network then shows these Users ads about the new content in the Application;
• marketing the Services to a group of potential Users.

Who can show personalized ads to you?

Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.

How can you turn off personalized ads?

Besides specific instruments available to the Users via the Application you can use your device settings.

iOS

Open the “Settings” application of iOS and select the “Privacy Policy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.

Android

Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalization” to prevent the creation of profiles and the display of personalized advertising. You can delete the Advertising ID in the same menu at any time (“Reset Advertising ID”), then a new ID will be created which will not be merged with the previously collected data.

Third-party Social Networks

Connecting to Third-Party Social Networks

The Application also uses third-party services such as Google Play App Service, Apple App Center, Facebook, Twitter or Instagram (“Third Party Social Networks”). The Application enables you to log in to your Third-Party Social Network account to connect to the Application by using the “Log in” feature in the Application. You may also share the content you create within the Application on Third-Party Social Networks. Please note that Third Party Social Networks are governed by their own privacy policies, terms and agreements with end users, and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate these sites. For additional questions, contact us at legal@pixcham.com.

Information we may receive when you connect to Third-Party Social Networks

The information you allow us to access varies by Third Party Social Networks and is affected by the privacy settings you establish on those Third-Party Social Networks. You can control and find out more about these settings from the Third-Party Social Network in question. When you use the “Log in” feature, we may access and store some or all of the following information, as allowed by you, from Third-Party Social Networks and your preferences: (i) your basic information from your public profile, such as your nickname, profile picture; (ii) login ID and/or user identifier string; (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the “Log in with” process. We may share your name and your Application data (such as moves, Challenges progress and scores) with respect to the Application, with your friends who have also used the “Log in with” or “Connect to” feature in connection with the Application or with your contacts in applicable Third-Party Social Media Network account.

The Application may further ask you to allow us to post on such Third-Party Social Networks on your behalf (e.g. status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the Application on your device so that the Application will be able to communicate with Third Party Social Network directly.

How you share your information on Third-Party Social Networks

If you use the Third-Party Social Networks to participate in Application-related activities, such as Challenges, Battles, leaderboards and multiplayer features, you share your information with other Users and the Third-Party Social Networks (for example, your selfies, scores, rankings, and achievements etc.).

Cookies

Cookies are small files stored on your mobile device or internet browser when browsing our website. They enable us to enhance website functionality, understand User behaviour, and deliver more targeted online advertising and campaigns. We employ the following basic types of cookies on our website:

• Necessary cookies are indispensable for making a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Performance cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.
• Marketing cookies are employed to track visitors across website. The intention is to display ads that are relevant and engaging for the individual User and thereby more valuable for publishers and third party advertisers.

To comply with the applicable laws, we kindly request your prior consent for the use of performance and marketing cookies. You have the freedom to withdraw this consent at any time by interacting with the "cookies banner." Please note that we automatically store necessary cookies without requiring your consent, as it is done on the legal basis of performing the contract or legitimate interests.

Additionally, we differentiate between "1st party" cookies, which are directly stored by us or our servers, and "3rd party" cookies, which are stored by external service providers or third parties.

Cookie name: CONTEST
Type of cookie: Necessary
Expiration: 2 years
Description: Used to detect if the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for GDPR-compliance of the web site.

Cookie name: vuex
Type of cookie: Necessary
Expiration: Session
Description: Registers the User's log-in status. This enables the website owner to control accessibility to certain parts of the website based on whether the User is logged in or not.

Cookie name: _ga
Type of cookie: Performance
Expiration: 1 year 1 month
Description: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

Cookie name: _ga_#
Type of cookie: Performance
Expiration: 1 year 1 month
Description: Used by Google Analytics to collect data on the number of times a user has visited the website, as well as the dates for the first and most recent visit.

Cookie name: YSC
Type of cookie: Marketing
Expiration: Session
Description: This cookie is set by YouTube to track views of embedded videos.

Cookie name: VISITOR_INFO1_LIVE
Type of cookie: Marketing
Expiration: 6 months
Description: This cookie is set by Youtube to keep track of user preferences for Youtube videos embedded in sites; it can also determine whether the website visitor is using the new or old version of the Youtube interface.

Children's Privacy

This section of Privacy Policy outlines how we obtain and process personal information of children under the age of 16 years (“Child” or “Children”). To protect Children's privacy and ensure their safety, obtaining parental consent is mandatory for the creation of Child’s account within the Application. As the operator of this Application, we take reasonable steps to ensure that the person providing consent is the Child’s parent or legal guardian. As a result we collect and process personal information from Children only with the verifiable consent of the holder(s) of parental responsibility. If we become aware that we have collected personal information from Child without obtaining parental consent, we will promptly take steps to remove any such information about the Child from our servers and terminate any account the Child has created within the Application.

Your Rights

You have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests to legal@pixcham.com.

With regards to consent we must explicitly inform you that you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Your rights include:

• Right to withdraw your consent - you may withdraw your consent to show personalized ads to you, by loading “Terms & Privacy” from your Application settings and following instructions in section Personalized Ads Consent Withdrawal of the Privacy Policy;
• Right to access your data - you have the right to obtain:
  • confirmation of whether, and where, we are processing your personal information;
  • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • information about the categories of recipients with whom we may share your personal information; and
  • a copy of the personal information we hold about you.
• Right to correct your data – you have the right to have any inaccurate or incomplete personal data we hold about you corrected without undue delay;
• Right to erasure of your data - in certain circumstances, you have the right to request that we erase your personal data without undue delay if the further processing of such personal data is not justified;
• Right to restriction of processing - in certain circumstances, you have the right to request that we restrict the purposes for which we process your personal data if further processing of your personal data in this way is not justified, for example if you have challenged the accuracy of the personal data;
• Right to take your data with you – you have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person;
• Right to object how your data is handled – you have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
• Right to send complaints to the supervisory authority – you have the right to lodge a complaint to your national data protection authority.

Legal Basis

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under the applicable EU data protection laws and regulations.

The legal bases that we rely upon are the following:

• Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve the Services, to provide customer support, to deliver special features in the Application, to deliver content of the in-Application purchases you may make.
• Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of the Services to pursue our legitimate interests in order to ensure you have the best experience when using the Application and/or the Services, to make sure your information is secure and to provide to you some features of the Application free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
• Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
• Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes.

Security

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. We use commercially reasonable efforts to assure that your information remains secure when maintained by us.

International Transfer of Personal Information

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with the applicable EU data protection laws and regulations. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Data Privacy Framework.

To ensure transparency, we have compiled the list of our service providers below:

Service provider:
Stripe Payments Europe Limited
Privacy policy of service provider:
https://stripe.com/en-sk/privacy
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR, EU-US Data Privacy Framework.

Service provider:
Wise Europe SA
Privacy policy of service provider:
https://wise.com/gb/legal/global-privacy-policy-en
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR.

Service provider:
Veriff OÜ
Privacy policy of service provider:
https://www.veriff.com/privacy-notice
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR.

Service provider:
Sinch Email
Privacy policy of service provider:
https://www.mailjet.com/legal/privacy-policy/
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR, EU SCC with Data Processing Agreement.

Service provider:
Amazon Web Services EMEA SARL
Privacy policy of service provider:
https://aws.amazon.com/privacy/
Transfer mechanism:
EU SCC with Data Processing Addendum.

Service provider:
Hetzner Online GmbH
Privacy policy of service provider:
https://www.hetzner.com/legal/privacy-policy
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR.

Service provider:
Google
Privacy policy of service provider:
https://policies.google.com/privacy?hl=en
Transfer mechanism:
Adequacy decision in accordance with Art. 45 GDPR, EU SCC, EU-US Data Privacy Framework.

Service provider:
Apple Distribution International Limited
Privacy policy of service provider:
https://www.apple.com/legal/privacy/en-ww/
Transfer mechanism:
EU SCC.

Retention

We store your information for as long as needed to provide you with the Services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with the Services has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in “Your Rights” section of this Privacy Policy.

Changes to Our Privacy Policy

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at www.pixcham.com/privacy-policy.

For previous versions of this Privacy Policy, please contact us via legal@pixcham.com.

Contact us

If you have questions or concerns about this Privacy Policy, please contact us through one of the following ways:

• for privacy questions and exercising your rights via legal@pixcham.com
• our data protection officer: legal@pixcham.com
• if you have a concern or compliance regarding our treatment of your personal data you can contact the relevant data protection authority. You can find contact details of data protection authority at https://edpb.europa.eu/csc/about-csc/members-coordinated-supervision-committee_en. For more information on which authority to contact, please email us at legal@pixcham.com.
• for general information, please feel free to contact us via our contact service page: www.pixcham.com/contact-us/