I. NAME OF THE PERSON RESPONSIBLE

The person responsible within the meaning of the GDPR and other national data protection laws of the member states as well as other data protection regulations is:
Pep Services
Naperville, Illinois
USA
Email: info@photoeditpath.com
Company registration number DK34704643
(hereinafter, “Pep”, “we,” “us,” and “our”)
Pep Services is a subsidiary of Pep TopCo A/S, USA (Company registration number: 42309192). Companies legally owned and controlled by Pep TopCo A/S are hereinafter designated as “subsidiary” or “subsidiaries”.

II. GENERAL INFORMATION

Pep respect your privacy and the importance we place on establishing trust with our customers and users (hereinafter “you” and “your”). To earn and maintain that trust, we commit to communicating transparently, providing security, and protecting the privacy of data on the site located at www.Pep.com, or any other sites, platforms, applications owned or operated by Pep that does not post a different privacy policy (hereinafter, “Site”).

This Privacy Policy also describes your choices and rights with respect to your Personal Data.

We keep your personal information personal and private. We will only share or otherwise disclose your personal information as necessary to provide our services, as described in this policy, or in cases where we first provide you with notice and the opportunity to consent.

An exception applies to cases in which prior consent can not be obtained and the collection, processing, storing, sharing and use of the data is permitted by law.

By using our site, you agree to the collection, process, storing, sharing and use of your personal data in accordance with this privacy policy.

Please read on to learn how we collect and use information obtained from the site. If You have any questions about our privacy policy feel free to contact Us at info@photoeditpath.com
.

III. WHAT DATA WE MAY COLLECT?

Personal data

Personal data or personally identifiable information (hereinafter, “personal data”) means any information about an individual from which that individual can be identified or contacted. Personal data may include, but is not limited to, your name, postal address, email address, contact information and employer.

Log data & Cookies

We collect information that your browser sends whenever you visit our site or use our services (“log data”). Log data may include but not limited to information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In order to provide you with thorough and personalized service, we may use “cookies” to keep and occasionally track information about you. We use cookies and other information-gathering technologies for a variety of purposes, such as providing us with information about how you interact with our site. You may view a complete list of cookies and change your cookie preferences by clicking on the “Cookies” link in the footer of www. Pep.com.

IV. WHAT DO WE USE THE COLLECTED PERSONAL DATA FOR?

Any of the personal data Pep collect from you may be used for one or more of the following purposes:

• Personalize your customer or user experience.
• We continually strive to improve our site and service based on the inputs we receive from you. By collecting usage data about how you interact with our site and service, we are able to develop and improve.
• Administer and protect business, rights, property or safety of Pep, our customers, users and other third parties.
• The use of personal data could be troubleshooting, maintenance, data analysis, testing, support, updates, reporting and hosting of data ect.
• Establish a channel of communication with you, where we may contact you with details about our services, newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from Pep by contacting us (refer to above email address).
• Measure or understand the effectiveness of the advertising we serve to you.
• Apply data analytics to improve our site, services, marketing, customer relationships and experiences.
• We use machine learning to develop and improve our services and offerings to you. Our work with machine learning is a continuous improvement based on a large volume of data. The data used are mainly retrieved from digital assets. Some of this data may be personal data.

Please note that Pep may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

V. TRANSFER OF DATA TO SERVICE PROVIDERS

We work and may receive and share personal data with service providers. These service providers may also process personal data on our behalf. We may enrich your personal data with the additional personal data received from these service providers.

Below are the types of service providers that Pep share personal data with:

• Subsidiaries owned by Pep TopCo A/S. In the event that we acquire or diversify business or assets, we may disclose your data to the prospective seller or buyer of such business or assets.
• Business partners, suppliers and subcontractors for the performance of any contracts Pep enter into. These third parties provide such services as IT support, system administration, email, other communications, hosting services, backup services, credit card processing, research, development, marketing, post production of digital assets, and customer support ect.
• Professional advisers including but not limited to lawyers, bankers, auditors, insurers, and other advisors providing other professional services.
• Regulators and other authorities who require disclosure in certain circumstances.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you. We may use data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target group.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site, services so that we may provide information about our products or services to you.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• Share with others as you may consent to.

We ensure contractual documentation in relation to any third parties to make sure that they process data according to our legal obligations and in accordance with this privacy policy.

VI. INTERNATIONAL TRANSFERS

Pep is a global service provider and our customers are located all over the world, which is also reflected in our global operation. Your personal data may be transferred, stored, and processed in any country, where we have operations, our staff are located or where we engage service providers. This will involve a transfer of your personal data to countries outside of your country of residence.

Pep transfer, store and process personal data outside the European Union or the European Economic Area (Hereinafter, “EU”). For third parties located in countries whose level of personal data protection does not correspond to that of the EU and EU has not issued an adequacy decision for these countries, we have taken appropriate precautions to ensure an adequate level of personal data protection for any personal data transfers. These include, among others, the standard contractual clauses or binding internal personal data protection policy.

VII. SECURITY OF PERSONAL DATA

We take reasonable, industry standard steps to safeguard prevent your personal data from being accidentally lost, accessed in an unauthorised way, altered, unauthorized used. When your personal data is collected by us, we use systems with limited access, located at facilities with technical, physical, and administrative security measures, to protect against unauthorized access.

Any password and username allocated to you by Pep must be kept secret and must not be disclosed to anyone, unless we have given you our prior written permission.

VIII. PERSONAL DATA RETENTION

We retain personal data for as long as reasonably necessary and consistent with the purposes for which it was collected or for the purposes of satisfying any legal, litigation, tax, accounting, any contractual obligations or reporting requirements. When the personal data retention period expires for a given type of personal data, we will delete or destroy it. If we for reasons are unable to do so, we will implement appropriate security measures to prevent any further use of such data.

IX. LINKS TO OTHER SITES

Please note our site may contain links to other websites that are not operated by Pep. When you link to another website, you should review their privacy policy, as it may be different from Pep privacy policy. Such sites may send their own cookies to users, collect data or solicit personal data. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services. This privacy policy applies solely to personal data collected by the Pep site.

X. DIGITAL ASSETS SENT TO US FOR AVAILING OUR SERVICES

Pep is engaged in the business of providing post-production services for digital assets, and related technology tools and solutions. Digital assets are defined as images, video, and other virtual digital files.

When processed, the digital assets will be available at a public internet location, the URL of which will not be published. As this location is public (and therefore potentially available to any internet-connected device), We urge you to use discretion in sending us images that may be sensitive to you or to third parties. Under no circumstances shall we be liable for unauthorized transmission of images that do not belong to you.

XI. WHAT ARE YOUR RIGHTS?

If you wish to exercise any of your rights stipulated in this privacy policy, please contact us on the email address stated above. We will respond to such queries within 30 days. If the request is complex the return time may take longer. In this case, we will notify you and keep you updated. You have the following rights regarding the personal data we process:

• Right to access: We will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data.
• Right to rectification: If the personal data we process is inaccurate or incomplete, you are entitled to request to have it rectified.
• Right to deletion: You may, under certain circumstances, ask us to delete or remove your personal data. Such circumstances may arise where we no longer need it or if you withdraw your consent (where applicable).
• Right to restrict processing: You can, under certain circumstances, ask us to ‘block’ the processing of personal data.
• Right to data portability: You have the right, under certain circumstances, to obtain your personal data collected by us (in a structured, commonly used and machine readable format) and to reuse it elsewhere.
• Right to object to certain data processing activities
• Right to withdraw your consent: If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
• Right to complain: If you have a concern about any aspect of our practices regarding the processing of personal data, you can report it to the relevant supervisory authority. In Denmark, you can send your complaint to the Danish Data Protection Agency

Where requests are manifestly unfounded or excessive, in particular because of the repetitive character, we may either charge a reasonable fee considering the administrative costs of providing the information, communication, taking the action requested or refuse to act on the request.

Any request must be provided with sufficient information that allow Pep to reasonably verify that you are the person about whom we collected personal data and describe your request with sufficient detail such that we may understand, evaluate, and respond to it.

XII. CHANGES

Pep reserve the right to update or change our privacy policy at any time. Your continued use of the site after we post any modifications to the privacy policy will constitute your acknowledgment, consent to, abide by, and bound by the modified privacy policy. You should therefore check this privacy policy periodically. In the event that we make material changes that restrict users rights or obligations under this privacy policy, we will publish a clear notice in this section of this privacy policy that informs users when they are updated.

Last updated: June 3, 2024