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Ightricks Rivacy Olicy

Lightricks' privacy policy outlines how they collect, store, use, and share users' personal data. They collect data directly from users through their use of Lightricks' apps, websites, and services, as well as from third parties. This includes account information, photos/videos uploaded by users, usage data, and direct communications. Lightricks uses this data to provide their services, comply with legal obligations, and support their legitimate business interests such as improving services and advertising. They share some user data with third party service providers but take measures to protect users' personal data.

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0% found this document useful (0 votes)
83 views10 pages

Ightricks Rivacy Olicy

Lightricks' privacy policy outlines how they collect, store, use, and share users' personal data. They collect data directly from users through their use of Lightricks' apps, websites, and services, as well as from third parties. This includes account information, photos/videos uploaded by users, usage data, and direct communications. Lightricks uses this data to provide their services, comply with legal obligations, and support their legitimate business interests such as improving services and advertising. They share some user data with third party service providers but take measures to protect users' personal data.

Uploaded by

Soul Mariner
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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LIGHTRICKS PRIVACY POLICY

Lightricks Ltd., including our subsidiaries and affiliates (collectively, “Lightricks”, “we”, “our” or
“us”), puts great efforts in making sure that the personal data we process is stored securely and
used properly, and that our data practices are accurately communicated to our users and
prospective users (collectively “you” or “your”).

Lightricks offers a number of mobile software applications (each, an "App") and web services
(each, a "Web Service"), allowing you, among other things, to edit and perfect photos, create
images, add filters, create a landing page within your biographic description (“Link in bio”), edit
videos and share your creations through social media and email, as well as within Lightricks apps
(“Lightricks Feed”), and create content and allow collaboration on Brands’ advertising campaigns
enabling the connection between creators and businesses (“Brands”) in order to run campaigns
and develop Brands (“Popular Pays”). Lightricks also operates various websites (each, a
"Website"). This Privacy Policy is our general policy which covers our processing activities within
our multiple Apps, Web Services and Websites

This Privacy Policy (“Policy” or "Privacy Policy") describes how we collect, store, use and disclose
the following types of personal data:

“Prospect Data” or “Prospect(s)” concerning individuals who visit, use or engage with our
website, blogs or other similar forums, online ads and content, surveys, emails or other
communications under our control.

“User Data” concerning individuals (“Users”) who download and register to the Lightricks’ Apps,
Websites and Web Services (together the “Services”).

“Personal data” means any information that can be used, alone or together with other data, to
uniquely identify any living human being.

Specifically, this Privacy Policy describes our practices regarding:


1. Data Collection
2. Data Uses
3. Data Location
4. Data Retention
5. Data Security
6. Data Sharing
7. Cookies and Tracking Technologies
8. Communications
9. Data Subject Rights
10. Roles and Responsibilities
11. Additional Information and Contact Details

Please read this Privacy Policy carefully and make sure that you fully understand and agree
to it. You are not legally required to provide us with any personal data and may do so (or avoid
doing so) at your own free will. If you do not wish to provide us with your personal data or to have
it processed by us or any of our Service Providers (per Section 6 below), please avoid any
interaction with us or any use of our Services.

1. DATA COLLECTION
The data we process regarding our Prospects and Users is typically collected and generated
through automatic means, directly from you, through your interaction with us or with our Services;

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from our Users; or through third-party services, social media, analytics tools, events we organize
or take part in, and other business initiatives.

Such data may include:

● Account information: e-mail address, name, user name, nickname, date of birth, gender,
social media accounts, shipping address (if needed), subscription status (including a token
indicating payment of the subscription and payment method) and additional optional
information such as profile photo and hashed password or other information used for
authentication and access control, and any other information that may be required when
signing up to any of our Services.
You may also choose to login to our Services using your Apple, Facebook or Gmail account
or connect to your social media account, ads manager account, or other accounts via an
Application Programming Interface ("API") or otherwise. By doing so, you provide us with
information connected to such an account which may also include your name, profile
picture, friends list, your social media provider identifiers, followers, language preferences,
demographic data, location, account ID number/token, and email address. Please note
that Lightricks doesn’t have control over how any third party uses or discloses the personal
data it collects about you.
In the Popular Pays platform you may also participate in campaigns for a Brand or its
agency (the “Gig”). In addition to Account Information, we may collect information
pertaining to a Gig, such as your clothing size when you voluntarily apply for an apparel
campaign etc., and any other identifier you may provide. We may also collect information
in order to facilitate a funds transfer from the Brand to you (e.g. your PayPal account
details).
● Photographs/Videos: As a general rule, all photos and videos on your device will remain
stored on your device. Our Services contain the functionality which allows you to upload
images or videos to the Lightricks Feed which will be stored on Lightricks’ servers
(“Lightricks Cloud”). In such cases, we will collect the images and videos you upload to the
Lightricks Cloud, which may also include Face Data (defined below) and analytical
information.
● Services usage information: connectivity, technical and aggregated usage data, user
agent, IP addresses, device data (such as type, OS, device ID, browser version, locale and
language settings used), access times and dates logs, communication and performance
logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized
on your device.
● Image Data: The Apps allow users to use special functions that are designed for editing
(e.g. manipulating facial and other body features) and processing images and videos,
including identifying the characteristics of images of people and faces. When you first
install an App, you will be asked whether you permit the App access to specific photos or
to your entire camera roll. If you grant access to the camera roll, we scan all your images
in your camera roll, and we may collect and process information on the characteristics of
images and videos that you have in your camera roll, such as the image setting (e.g.,
sunset, indoor, party), the posture, location and characteristics of faces or other face parts
(eyes, lips, etc.) that appear in an image or video, and the number, estimated age and
gender of people in the image or video. Some Services (for example, the “cartoonification”
feature) require the temporary storing and processing on Lightricks Cloud of images and
videos for the duration of the editing process. In certain cases, if you have granted us
access to your camera roll or to a specific image or video, we may also collect and
temporarily store images and videos for analytics purposes. For more details on where
and how we store your personal data, please see the “Data Location" and "Data Sharing"
sections below. Our Services may also recognize the faces of people in your photos (“Face

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Data”) in order to match photos to other photos with the same people or characteristics,
or to suggest the use of certain features or functionalities. This identification process is
conducted on your device. We do not collect or retain any biometric information or
biometric identifiers from your images.
● Direct interactions and communications: messages, comments, feedback (e.g., internal
communications), as well as correspondence with us (e.g., for user enablement, support
and training purposes), including chats, surveys, calls and video recordings, transcriptions,
and analyses thereof, and any other data you choose to provide or upload via the Services
or in the context of the interaction with one of our customer experience representatives;
● Lightricks Feed: On the Lightricks Feed, Lightricks will process personal data such as
profile photos, names, emails, social media accounts, reactions to feed posts and
comments to feed posts.
● External Profile (“Link in bio”): As part of certain of its Services, Lightricks allows users
to host an external linkable profile on its servers, which is called Link in bio.
o A Link in bio profile might include links to other social media accounts of the user,
users’ full name, email, pictures websites, blogs or other communication methods.
In addition, you can add features and integrations to the Link in bio, such as Topjar,
Zoom call links, subscription and purchasing off content or merchandise, which
may contain your personal data or links to external sources which contain your
personal data.
o If you sell anything via Link in bio (e.g. merchandise), Lightricks may hold details of
completed transactions such as date, amount, transaction ID. Lightricks will not
store credit card information.
o If you decide to add subscription or other features which collect personal data
from other users via the Link in bio, it is up to you to make sure that the collected
personal data is being collected according to relevant privacy and data protection
legislation.

2. DATA USES
Lightricks processes the personal data described in Section 1 as necessary for the performance of
our Services; to comply with our legal and contractual obligations; and to support our legitimate
interests in maintaining, improving and advertising our Services. These include understanding
how our Services are used, and how our Services, campaigns and other activities are performing;
gaining insights which help us dedicate our resources and efforts more efficiently; marketing,
advertising and selling our Services; providing customer service and technical support to our users
and customers; and protecting and securing our Services, ourselves and the entities and
individuals we engage with.

Lightricks operates in many countries around the world. Therefore, please note that if you reside
or are using the Services in a territory governed by privacy laws under which "consent" is the only
or most appropriate legal basis for the processing personal data in the manners described in this
Policy (in general, or specifically with respect to the types of personal data you expect or elect to
be or have processed by or via the Services), your acceptance of our Terms of Use and this Privacy
Policy will be deemed as your consent to the processing of your personal data for all purposes
detailed herein. If you wish to revoke such consent, please contact us at [email protected].

We do not sell your personal information, as set forth in the California Consumer Privacy
Act (CCPA).

Specifically, we use your data for the following purposes:

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Services & Link in bio User Personal Data
Purpose Legal basis for processing
Providing our users with our Services, including the ability to edit Our contractual obligations to
their images, videos and media as well as connecting creators provide you with the Services and
with Brands and agencies, as well as other web services our legitimate interest in providing
you with the Service
To create aggregated data, anonymized or pseudonymized data ▪ Legitimate interest
and/or De-identified Data
To enrich the content and improve the features available within ▪ Legitimate interest
the Services – this includes the use of third-party apps that allows
us to record user journeys and session and create heatmaps.
User content won’t be tracked

To authenticate the identity of our Users, and to allow them to ▪ Legitimate Interest
access our Services
▪ Performance of a Contract
To provide visitors to our Websites and our Users assistance and ▪ Legitimate Interest
support
▪ Performance of a Contract
To evaluate and develop new features, technologies, and Legitimate Interest
improvements to the Service
To perform, facilitate and optimize our marketing campaigns, ad ▪ Legitimate Interest
management and sales operations, and to manage and deliver
▪ Consent
advertisements for our products and services more effectively,
including on other websites and applications
To explore and pursue growth opportunities by facilitating a Legitimate Interest
stronger local presence and tailored experiences
To contact our Website and Apps visitors, Users and Customers ▪ Legitimate Interest
(whether existing or prospective) with general or personalized
▪ Consent
service-related messages, as well as promotional messages that
may be of specific interest to them
To facilitate, sponsor and offer certain events, contests and ▪ Legitimate Interest
promotions
▪ Consent
To support and enhance our data security measures, including ▪ Legitimate Interest
for the purposes of preventing and mitigating the risks of fraud,
▪ Performance of a Contract
error or any illegal or prohibited activity
To create aggregated data, inferred non-personal data or ▪ Legitimate Interest
anonymized or pseudonymized data (de-identified data), which ▪ Performance of a Contract
we or our business partners may use to provide and improve our ▪ Compliance with legal obligations
respective services or for any other purpose
To comply with applicable laws and regulations Compliance with legal obligations

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3. DATA LOCATION
We and our authorized Service Providers maintain, store and process personal data in the various
locations we operate around the globe, including in Israel, the EU and the US, as reasonably
necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Lightricks, its affiliates and Service Providers
are each committed to protect personal data in accordance with this Privacy Policy, customary
industry standards, and such appropriate lawful mechanisms and contractual terms requiring
adequate data protection, regardless of any lesser legal requirements that may apply in the
jurisdiction to which such data may be transferred. For data transfers from the EU we have entered
into Standard Contractual Clauses (“SCC”), you can obtain a copy by contacting us as indicated in
Section 11 below.

4. DATA RETENTION
We retain your personal data for as long as it is reasonably necessary to provide you with our
Services and to maintain and expand our relationship; to comply with our legal and contractual
obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable
to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our
relationship, should any legal issues arise following your discontinuance of use), all in accordance
with applicable laws and regulations. Please note that for many of our Services, Users may not use
an App for a certain amount of time and still expect us to retain their personal data, such as their
account information and photos. Therefore, we will generally retain your personal data for you
until you instruct us to delete it. You may ask us to do so by emailing [email protected] or by
initiating the process in-App, if such option is available.

When images/videos are uploaded to the Lightricks Feed and are incorporated by other Users into
their own creations (“Incorporated Assets”) we won’t be able to amend, delete or fulfil any rights
in relation to such Incorporated Assets.

Please note that except as required by applicable law or our specific agreements with you, we will
not be obligated to retain your personal data for any particular period, and we are free to securely
delete it or restrict access to it for any reason and at any time, with or without notice to you. If you
have any questions about our data retention policy, please contact us by e-mail at
[email protected].

Please also note that we do not retain your payment information, as it is transferred directly to
the relevant Service Provider (as per Section 6 below). We only retain a token of such payment
information (which cannot be used to re-identify you) and the chosen payment method.

5. DATA SECURITY
We implement appropriate technical, organizational, and security measures to reduce the risks of
damage to (or loss of) information, or any unauthorized access or use of information. However,
these measures do not provide absolute information security. Therefore, although efforts are
made to secure your personal data, it is not guaranteed, and you cannot expect that the Services
will be immune to information security risks or attacks. Also, as the security of information
depends in part on the security of the computer, device or network you use to communicate with
us, and the security you use to protect your user IDs and passwords. Please make sure to take
appropriate measures to protect this information.

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6. DATA SHARING
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law
enforcement officials access to your personal data, in response to a subpoena, search warrant or
court order (or similar requirement), or in compliance with applicable laws and regulations, with
or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a)
we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to
investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other
wrongdoing; or (c) such disclosure is required to protect our legitimate business interests,
including the security or integrity of our Services.

Service Providers: we engage selected third-party entities to perform services complementary to


our own. Such Service Providers include hosting and server co-location services, communications
and content delivery networks (CDNs), internet service providers, operating systems and platform,
data analytics services, marketing and advertising services, data and cyber security services, fraud
detection services, billing and payment processing services, shipping and handling services, web
analytics, e-mail and SMS distribution and monitoring services, session or activity recording
services, remote access services, performance measurement, data optimization services, social
and advertising networks, content providers, support and customer relation management
systems; and our business, legal, financial and compliance advisors (collectively, “Service
Providers“). These Service Providers may have access to your personal data, depending on each
of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may
only use it for such purposes.

Third-Party Websites and Services (“Vendors”): our Services may include links to third-party
websites, and integrations with third-party services. Such websites and third-party services, and
any information you process, submit, transmit, store or otherwise use with such websites and
third-party services, are beyond the scope of Lightricks’ terms of use and Privacy Policy and will
therefore be governed by such third-party’s terms and privacy practices and policies, and not by
this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such
websites and third-party services. Moreover, if the Services integrate with a third-party service, the
API that performs the integration will enable the relevant third party to serve you certain content
as well as access some of your Account Content. For example, if you wish to upload or otherwise
share your Account Content to an integrated third-party service such as Instagram or TikTok, or to
make use of certain functionality in those services, the API will enable the applicable third party to
access your Account Content (such as your photo library). Additionally, when you pay for fee-based
Services or items, your payment will be processed by third party payment processors, such as
Google’s or Apple’s in-app purchase mechanism, or if you charge for merchandise through Link in
bio this will be done via Stripe. While we do make significant efforts to only work with reputable
companies which we have evaluated they take privacy seriously, we do not control, and are not
responsible for, the privacy practices of such third parties, or for their content, products and
services, and we encourage you to read the terms and conditions and privacy policies of each third
party that you choose to use or interact with. These Vendors may also collect your personal data
through their respective tracking tools incorporated or embedded within our Services. We use
their services for the purposes set forth above.

Protecting Rights and Safety: we may share personal data with others if we believe in good faith
that this will help protect the rights, property or personal safety of Lightricks, our Prospects, Users,
or any members of the general public.

Lightricks Subsidiaries and Affiliated Companies; Change of Control: we may share personal
data internally within our group, for the purposes described in this Privacy Policy. In addition,
should Lightricks Ltd. or any of its subsidiaries or affiliates undergo any change in control or

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ownership, including by means of merger, acquisition or purchase of substantially all or part of its
assets, or will be considered or found eligible for a governmental grant and/or a potential
investment, personal data may be shared with the parties involved in such an event. If we believe
that such event might materially affect your personal data then stored with us, we will notify you
of this event and the choices you may have via e-mail or prominent notice on our Services.

In-App sharing: due to the nature of the Apps and the Lightricks Feed feature, certain personal
data available in the Apps is visible to other Lightricks Users in that App, for example your
username, likes and comments on other Users’ content. We will never share your photos or videos
with other Users unless you actively choose to do so.

SDKs: We use third party software development kits (SDKs) and other similar technologies on our
Services to ensure their stable operation and to provide the Services as described above. Please
see below a list of SDK providers we use (which may be updated from time to time), and more
information about our use and sharing of your personal data with our SDK providers. Some of
these third-party SDK providers may collect personal data from you for their use and processing
and may obtain your consent prior to doing so.

Additional Sharing: we may share your personal data in additional ways, pursuant to your
request or explicit approval, or if we are legally obligated to do so, or if we have successfully
rendered such data non-personal, non-identifiable and/or anonymous. We may transfer, share or
otherwise use non-personal and non-identifiable data at our sole discretion and without the need
for further approval.

7. COOKIES AND TRACKING TECHNOLOGIES


We may use cookies, tracking pixels (also known as clear GIFs and web beacons) and other
technologies for performance which are used to anonymously track the online usage patterns of
users of the Services and in order to provide you with a better experience. In addition, we may
also use tracking pixels in HTML-based emails sent to our users to track which emails are opened
and which links are clicked by recipients. This information allows for more accurate reporting and
improvement of the Services. We may share non-identifiable/aggregated extracts of such
information with our partners for our legitimate business purposes.

Cookies: cookies are small text files that are stored through the browser on your computer or
mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are
removed when you close your browser session - these are the “session cookies”. Some last for
longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the
use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do
Not Track” signal in the HTTP header from a browser or mobile application, you can manage your
cookies preferences, including whether or not to accept them and how to remove them, through
your browser settings. Please bear in mind that disabling cookies may complicate or even prevent
you from using the Services. For more information regarding cookies, you may find the following
websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

Google Analytics: we use Google Analytics to collect information about the use of our Services.
Google Analytics collects information such as how often you visit the Services, which pages you
visited when doing so, and which other sites they used prior to coming to our Services. We do not
merge the information collected through the use of Google Analytics with personally identifiable
data. Google’s ability to use and share information collected by Google Analytics about your visits
to and use of the Services is restricted by the Google Analytics Terms of Service and the Google
Privacy Policy. You can learn more about how Google collects and processes data specifically in
connection with Google Analytics here. Further information about your option to opt-out of these
analytics services is available here.

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Facebook Pixel Tags: We use pixel tags from Facebook. These tags provide information about,
e.g., a user’s patterns of activity on our Services, IP address, time of visit, and so on. This
information can be used by Lightricks and/or Facebook to help target Lightricks’ advertising. You
can read more about Facebook’s Pixel Tag policies here.

To learn more about our cookies practices, please visit our Cookie Policy.

8. COMMUNICATIONS
We engage in service and promotional communications, through e-mail, phone, SMS and
notifications.

Service Communications: we may contact you with important information regarding our
Services. For example, we may send you notifications (through any of the means available to us)
of changes or updates to our Services (such as billing issues, login attempts or password reset
instructions, alerts and notifications concerning anomalies detected by our Services, abandoned
cart emails, surveys, etc.). You can control your communications and notifications in accordance
with the instructions included in the communications sent to you. Please note that you will not be
able to opt-out of receiving certain service communications which are integral to your use.

Notifications and Promotional Communications: we may also notify you about new features,
additional offerings, events, webinars, special opportunities or any other information we think you
will find valuable. We may provide such notices through any of the contact means available to us
(e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns
on any other sites or platforms. Furthermore, if you contact us with an inquiry, we may respond
with promotional emails relating to your inquiry. For example, if you contact us with an inquiry
about a feature you would like to see on one of our Services, we will use your Contact Information
to later inform you once our Services have been updated to include features similar to those you
inquired about or other features you may be interested in. In order to control your notifications
settings- please follow the instructions included in the promotional communications sent to you.
If you do not wish to receive such communication, you may also notify us by sending an e-mail to:
[email protected] or opt-out of these email updates by following the unsubscribe link located at
the bottom of the email.

9. DATA SUBJECT RIGHTS


Individuals have rights concerning their personal data. If you wish to exercise your privacy rights
under any applicable law, including the EU General Data Protection Regulation (GDPR), or the
CCPA, such as the right to request access, rectification, or erasure of your personal data held with
Lightricks, your right to restrict or object to such personal data’s processing, or to port such
personal data – please contact us by e-mail at: [email protected]. Please be advised that deleting
your personal data stored with Lightricks will adversely affect your use of our Services.

Should you ever decide to delete your Account, you may do so by emailing [email protected] or
by clicking on the delete account option in the App settings. If you terminate your Account, any
association between your Account and personal data we store will no longer be accessible through
your Account. However, given the nature of sharing on certain Services, any public activity on your
Account prior to deletion will remain stored on our servers and will remain accessible to the public.

Please note that such rights are not absolute. There are instances where applicable law or
regulatory requirements allow or require us to refuse to provide some or all of the personal data
that we hold about you. In the event that we cannot accommodate your request, we will inform
you of the reasons why, subject to any legal or regulatory restrictions.

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When images/videos are uploaded to the Lightricks Feed and are incorporated by other Users into
their own creations (“Incorporated Assets”) we won’t be able to amend, delete or fulfil any rights
in relation to such Incorporated Assets. If you wish to exercise your rights in relation to such
Incorporated Assets, please reach out directly to the relevant creator.

Please also note that we may require additional information, including certain personal data, in
order to authenticate and process your request. Such additional information may be then retained
by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in
accordance with Section 4 above. We may redact from the data which we will make available to
you, any personal data related to others.

10. ROLES AND RESPONSIBILITIES


Certain data protection laws and regulations, such as the GDPR or the CCPA typically distinguish
between two main roles for parties processing personal data: the “data controller” (or under the
CCPA, “business”), who determines the purposes and means of processing; and the “data
processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data
controller (or business). Below we explain how these roles apply to our Services, to the extent that
such laws and regulations apply.
Lightricks is the “Data Controller” of its Visitors’ and Apps Users’ data. With respect to such
data, we assume the responsibilities of data controller (solely to the extent applicable under law),
as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will
assume the role of “data processor”.
Lightricks is a “co-controller” of certain portions of its Users Data, alongside such Service
Providers that process Personal Data for both Lightricks’ analytics and marketing purposes - and
the Service Providers’ own purposes. In such cases, such Service Providers (e.g. Facebook and
Google) will in such circumstances be deemed as “co-controllers” of such data, which would
typically relate to Users who also use the Service Provider’s own platforms. If you wish to limit such
independent activities by these Service Providers, consider disabling third-party cookies as
detailed in Section 7 above.
Lightricks is the “Data Processor” of Creator Data (as defined below) uploaded to Popular
Pays’ platform. “Creator Data” means content created by Users and includes, but not limited to,
personal data contained within creative materials, audio, written text in captions and blogs,
photographs, video, or other deliverables provided on the Popular Pays platform by the User to a
Brand. The Brand is the Data Controller of Creator Data.

11. ADDITIONAL INFORMATION AND CONTACT DETAILS

Updates and Amendments: we may update and amend this Privacy Policy from time to time by
posting an updated version on our Services. The amended version will be effective as of the date
it is published. We will provide prior notice if we believe any substantial changes are involved via
any of the communication means available to us or via Services. After such notice period, all
amendments shall be deemed accepted by you if you continue to use the Services.

External Links: while our Services may contain links to other websites or services, we are not
responsible for their privacy practices. We encourage you to pay attention when you leave our
Services for the website or application of such third-parties, and to read the privacy policies of
each and every website and service you visit. This Privacy Policy applies only to our Services.

Children: The Services (both Web Services and Apps) are not intended for minors under the age
of thirteen (13). IF YOU ARE UNDER THE AGE OF THIRTEEN (13) YOU MAY NOT USE THE SERVICES.
If you are between thirteen (13) and eighteen (18) years old, you must review this Policy with your
parent or guardian. If you have concerns about your child’s privacy, or if you believe that your child

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may have provided us with their personal data, please contact us at [email protected]. We will
take steps to delete the information as soon as possible should we learn that we have collected
the personal data of a child under 13 without first receiving verifiable parental consent.

California Privacy Rights: California Civil Code Section 1798.83 permits our Users and Customers
who are California residents to request certain information regarding our disclosure of personal
data to third parties for their direct marketing purposes. To make such a request, please send an
email to [email protected]. Please note that we are only required to respond to one request per
customer each year.

Deletion of Content from California Residents: If you are a California resident under the age of
18 and a registered User, California Business and Professions Code Section 22581 permits you to
remove content or personal data you have publicly posted. If you wish to remove such content or
personal data and you specify which content or personal data you wish to be removed, we will do
so in accordance with applicable law. Please be aware that after removal you will not be able to
restore removed content. In addition, such removal does not ensure complete or comprehensive
removal of the content or personal data you have posted and that there may be circumstances in
which the law does not require us to enable removal of content.

EU Representative: Lightricks has designated representatives in Germany for data protection


matters. Inquiries regarding our EU privacy practices may be sent to [email protected] or
Lightricks GmbH, c/o Mazars Tax GmbH, Theodor Stern Kai 1, 60596 Frankfurt am Main, Germany.

UK Representative: Lightricks has designated representatives in the United Kingdom for data
protection matters. Inquiries regarding our UK privacy practices may be sent to
[email protected] or Lightricks (UK), 37 Broadhurst Gardens, London, England, NW6 3QT United
Kingdom.

DPO: Lightricks has appointed PrivacyTeam as its Data Protection Officer, for monitoring and
advising on Lightricks’ ongoing privacy compliance and serving as a point of contact on privacy
matters for data subjects and supervisory authorities. If you have any comments or questions
regarding this Privacy Policy, if you have any concerns regarding your privacy, or if you wish to
make a complaint about how your personal data is being processed by Lightricks, you can contact
our DPO at [email protected].

Questions, concerns or complaints: if you have any comments or questions regarding our
Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you
wish to make a complaint about how your personal data is being processed by Lightricks, you can
contact us at [email protected].

Effective Date: July 10, 2022

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