1. PURPOSE

    This Photo Finale Data Processing Addendum (“DPA”) supplements and is incorporated by reference into the Photo Finale Terms of Service, together with any terms applicable to any additional Photo Finale services that you choose to use (the “Terms”) by and between You (or “Merchant”), and the Photo Finale Contracting Entity as set forth in the Terms (“Photo Finale”), which outline the specific business purposes and services related to the DPA. In case of any conflict between the Terms and this DPA, the DPA shall prevail with respect to the processing of Your Personal Data.

    You and Photo Finale (each a “Party”, together the “Parties”), agree that this DPA sets forth the Parties’ obligations governing the processing of Your Personal Data in connection with the Terms and Your use of the Services. For the avoidance of doubt, this DPA shall not apply to Photo Finale’s processing of any Personal Data as a Data Controller, including of Personal Data about Customers that it receives as a result of the Customer’s direct relationship or intentional interaction with Photo Finale.

    1. DEFINITIONS

    Capitalized terms used but not defined in this DPA shall have the same meaning given to them in the Terms:

    1. Applicable Data Protection Law(s): Any data protection or privacy laws applicable to Photo Finale’s processing of Your Personal Data under the Terms, their implementing regulations and secondary legislation, each as may be amended, updated or replaced from time to time, including (as applicable, based on the location or residence of Merchant and/or Your Customer(s)):
    2. Canada’s Personal Information Protection and Electronic Documents Act 2000 (“PIPEDA”);
    3. the (a) California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), (b) Virginia Consumer Data Protection Act, (c) Colorado Privacy Act, (d) Connecticut Data Privacy Act, (e) Utah Consumer Privacy Act, (f) Oregon Consumer Privacy Act, (g) Texas Data Privacy and Security Act, (h) Montana Consumer Data Privacy Act and (i) once effective, similar comprehensive privacy laws in other U.S. states (together, “U.S. Data Protection Laws”);
    4. General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and any applicable national implementing laws;
    5. EU e-Privacy Directive (Directive 2002/58/EC), as amended (“e-Privacy Law”);
    6. UK General Data Protection Regulation (“UK GDPR”) and the UK Data Protection Act 2018 (“UK DPA”);
    7. Singapore’s Personal Data Protection Act 2012 (“PDPA”); and
    8. Swiss Federal Data Protection Act (“Swiss FDPA”)
    9. Customer: An individual or entity that visits, engages with, and/or purchases a product, good, or service from Your Store(s).
    10. Personal Data: Information or data defined as ‘personal data,’ ‘personal information,’ or ‘personally identifiable information’ (or analogous term) under Applicable Data Protection Laws from or about Your Customers that is made available to Photo Finale (or third-parties acting on Photo Finale’s behalf) by You (or third-parties acting on Your behalf) as part of using the Services, as well as other personal data You choose to share with Photo Finale about Your Customers as part of using the Services. For clarity, Personal Data shall not include any personal data about Customers that Photo Finale processes as a Data Controller and/or receives as a result of the Customer’s direct relationship or intentional interaction with Photo Finale or with other Photo Finale merchants.
    11. Data Rights Request: A valid and lawful request by an individual to exercise available rights pertaining to Personal Data under an Applicable Data Protection Law.
    12. Data Controller: The Party that determines the purposes and means of the processing of Personal Data, or as otherwise defined under any Applicable Data Protection Law.
    13. Data Processor or Service Provider: The Party or other entity or business that provides services on behalf of and processes Personal Data at the direction and on behalf of the Data Controller, and shall be interpreted in accordance with the Applicable Data Protection Laws.
    14. Personal Data Breach: In relation to Your Personal Data, shall be interpreted in accordance with Applicable Data Protection Law.
    15. “Process,” “processes,” or “processing”: (a) Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; or (b) the definition given to such term(s) under the Applicable Data Protection Law.
    16. “Subprocessor(s)”: Affiliated companies or third-party Data Processors or Service Providers that may process Personal Data at Photo Finale’s direction for the purpose of providing the Services.
    17. “You,” “Your,” or “Merchant”: Means the business that uses the Services and is a Party to the Terms with Photo Finale.

    III. NATURE OF THE PROCESSING AND ROLES OF THE PARTIES

    Photo Finale receives and processes Your Personal Data in order to provide You with the Services and as otherwise set forth below. Depending on which of the Services You request or use, Photo Finale will process the categories of Personal Data set forth at Appendix A, in the manner and on the bases contained therein.

    Photo Finale shall only process Your Personal Data as a Data Processor or Service Provider as necessary to provide and improve its Services or as otherwise permitted by Applicable Data Protection Laws. As part of its provision and ongoing improvement of its Services, Photo Finale may aggregate, anonymize or de-identify Your Personal Data.

    To the extent Photo Finale receives from You Personal Data that has been de-identified, Photo Finale will maintain and use the data only in a de-identified fashion.

    1. OBLIGATIONS OF PARTIES

    The following section describes the Parties’ respective obligations with respect to the processing of Personal Data covered by this DPA.

    1. General Compliance
    2. The Parties will comply with their respective obligations under Applicable Data Protection Laws.
    3. Photo Finale shall have no obligation to interpret or advise You on Your obligations under Applicable Data Protection Laws, including with respect to Personal Data covered by this DPA. You are solely responsible for determining Your legal and regulatory obligations, including evaluating whether the technical and organizational measures of the Services are consistent with Your independent legal and regulatory obligations.
    4. Photo Finale’s Obligations
    5. Data Security
      Photo Finale will implement and maintain appropriate technical and organizational measures designed to protect Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration, or disclosure, as set forth in Appendix B.
    6. Personal Data Breach Notification and Investigation
      a) As required by Applicable Data Protection Laws, Photo Finale will provide notice to You upon Photo Finale confirming any Personal Data Breach.
    7. b) Such notice shall include the information required under Applicable Data Protection Laws to the extent such information is reasonably available to Photo Finale. Photo Finale’s response to, or notice of, a Personal Data Breach is not an acknowledgment by Photo Finale of any fault or liability.
    8. c) Photo Finale agrees to investigate any Personal Data Breach, and use commercially reasonable efforts to identify, prevent, mitigate, and remedy the effects.
    9. Data Rights Requests
      a) To the extent required under Applicable Data Protection Laws, Photo Finale will facilitate Your ability to process and respond to Data Rights Requests from Your Customers related to Your use of the Services.
    10. b) To obtain assistance in responding to any such Data Rights Request, forward the Request to Photo Finale via the Photo Finale Support, unless Photo Finale notifies You of a different mechanism.
    11. Your Obligations with Respect to Personal Data
    12. Privacy Notices and Transparency:You represent and warrant that You are in compliance with all obligations under Applicable Data Protection Laws to provide notice and transparency concerning Your processing of Personal Data under the Terms and in connection with Your use of the Services. To the extent required under Applicable Data Protection Laws, You shall communicate to the relevant individuals all disclosures necessary for Photo Finale to lawfully and fairly process Personal Data in connection with this DPA, including by providing a link to Photo Finale’s Privacy Policy or to Your own Privacy Policy.
    13. Customer Rights and Permissions:You represent and warrant that You have all necessary rights, permissions, and consents to make available Personal Data to Photo Finale in accordance with the Terms, Your use of the Services You receive and Applicable Data Protection Laws.
    14. Data Rights Requests:You represent and warrant that You provide the ability for Your Customers to exercise Data Rights Requests, as required under Applicable Data Protection Laws, with respect to all Personal Data processed by Photo Finale for which You are the Data Controller.
    15. Regulatory Inquiries:Unless prohibited by applicable law, You will notify us promptly in accordance with the Notice provision in the Terms of any governmental, regulatory or other third party inquiry or complaint concerning Your use of the Services.
    16. U.S. DATA PROTECTION LAWS

    This section applies only to the extent that: (i) U.S. Data Protection Laws apply to You in connection with Your use of the Services; and (ii) the following provisions are required by U.S. Data Protection Laws and You are a “business” or “controller” under these laws.

    1. Photo Finale will not: (i) retain, use, or disclose such Personal Data outside its direct business relationship with You or for any other purpose other than for the limited and specified purposes identified in this DPA and/or the Terms, including retaining, using or disclosing such Personal Data for a commercial purpose other than for the limited and specified purposes identified in this DPA, and/or the Terms, (ii) “sell” or “share” such Personal Data within the meaning of the CCPA; or (iii) combine such Personal Data with Personal Data that it receives from other sources, in each case except as permitted under U.S. Data Protection Laws.
    2. Photo Finale will (i) provide the same level of privacy protection required of businesses or Data Controllers by such laws, and inform You if it determines that it can no longer meet these obligations, in which case You may take reasonable and appropriate steps to stop or remediate any unauthorized processing of such Personal Data, (ii) ensure personnel who it authorizes to process Personal Data either enter into written confidentiality agreements or are subject to statutory obligations of confidentiality, (iii) upon reasonable written request, and as part of enabling You to take reasonable and appropriate steps to ensure Photo Finale uses such Personal Data in a manner consistent with U.S. Data Protection Laws; and (iv) upon termination of its Services to You, Photo Finale will initiate its purge process to delete or de-identify the Personal Data.
    3. You represent and warrant that You will not share with Photo Finale any Personal Data of an individual who has exercised an opt-out right that You have committed to honoring or any sensitive Personal Data of an individual who has not consented to the processing of such sensitive data.
    4. MISCELLANEOUS
    5. Global Data Transfers
      You acknowledge that Personal Data may be transferred and processed in any country in which Photo Finale, its affiliated companies or third party service providers are located (including in Singapore and Canada). Any transfer of Personal Data to these recipients will be made in compliance with Applicable Data Protection Laws. For more information on international data transfers, where Photo Finale is subject to privacy requirements in the EEA, the UK, or Switzerland, see section II(B)(8) of Appendix C.
    6. Response to Legal Requests
    1. You acknowledge that, in the course of providing the Services to You, Photo Finale may share Your Personal Data (i) to comply with legal requirements or to respond to court orders or other similar government or regulatory demands; or (ii) to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (such as the Terms) or our policies (such as our Acceptable Use Policy).
    2. Photo Finale will make reasonable efforts before producing such Personal Data to ensure that such disclosure is permitted under Applicable Data Protection Laws and will be treated as confidential information under the applicable legal framework.
    1. Disclosure in Corporate Transactions
      You acknowledge that, in the course of providing the Services to You, Photo Finale may be required to share Personal Data with potential counterparties to any corporate or restructuring transaction.
    2. Photo Finale’s Use of Subprocessors/Service Providers
    1. You acknowledge that, in the course of providing the Services to You, Photo Finale may use Subprocessors to process Personal Data. If Applicable Data Protection Laws grant you such rights, You may object to Photo Finale’s use of a Subprocessor, and if Photo Finale is unable or unwilling to accommodate such requests, You may, in accordance with such laws, terminate Your use of the impacted Services within 30 days of such notification in accordance with the Terms.
    2. Photo Finale’s use of Subprocessors to process Personal Data that You provide will be in compliance with Applicable Data Protection Laws. Where Photo Finale engages a Subprocessor, Photo Finale will enter into a written agreement with the Subprocessor that imposes contractual obligations that are substantially the same as the ones set out in this DPA.
    1. DPA Amendment
      You acknowledge and agree that Photo Finale may amend this DPA from time to time by posting the relevant amended and restated DPA on Photo Finale’s website and such amendments to the DPA are effective as of the date of posting. Your continued use of the Services after the amended DPA is posted to Photo Finale’s website constitutes Your agreement to, and acceptance of, the amended DPA. If You do not agree to any changes to the DPA, do not continue to use the Service.

    VII Appendices

    1. Appendix A – Categories of Personal Data
    2. Appendix B – Data Security
    3. Appendix C – GDPR, UK GDPR, and Switzerland Data Processing Appendix

    APPENDIX A: CATEGORIES OF PERSONAL DATA

    As part of Your use of the Services, and depending on which Services You use, we may receive and process the following categories of Personal Data to provide the Services:

    • Customer name, email, contact, billing and shipping information.
    • Purchase and other transaction information from Your Store(s).
    • Update(s) about the status of transaction(s) with You or Your Store(s)
    • Customer activity in Your Store(s), including products viewed and/or included in shopping carts.
    • Customer preference signals, including Global Privacy Control (“GPC”), opt-out and opt-in signals.
    • Customer device information for device(s) used when visiting Your Store(s), including IP address, browser, and network activity.
    • Other information about the Customers’ interactions with You.
    • Any other Personal Data You choose to make available with Photo Finale.

    APPENDIX B: DATA SECURITY

    Photo Finale will maintain an information security program designed to (a) enable You to secure Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration, or disclosure; (b) identify reasonably foreseeable risks to the security and availability of the Services You receive; and (c) minimize security risks to the Services.

    1. Photo Finale’s information security program will include the following safeguards:
    2. Logical Security
    1. Access Controls Photo Finale will make its systems accessible only to authorized personnel, and only as necessary to maintain and provide the Services. Photo Finale will maintain access controls and policies designed to manage authorizations for access to its systems, including through the use of firewalls and/or other technology and authentication controls.
    2. Restricted User Access Photo Finale will (i) provision and restrict access to its systems in accordance with least privilege principles based on personnel job functions, and (ii) require two-factor authentication (2FA) for access to its systems.
    3. Vulnerability Assessments Photo Finale will maintain a vulnerability assessment and penetration testing program, responsible for investigating and tracking identified issues with the Services to resolution where necessary.
    4. Application Security Photo Finale maintains an application security program responsible for protecting Services from application security threats.
    5. Change Management Photo Finale will maintain controls designed to log, authorize, test, approve and document changes to existing Services resources, and will document change details within its change management or deployment tools. Photo Finale will test changes according to its change management standards prior to migration to production.
    6. Data Integrity As appropriate, Photo Finale will maintain controls designed to provide data integrity during transmission, storage and processing within the Services.
    7. Availability Photo Finale will (i) implement redundancy where appropriate for the Services to minimize the effect of a malfunction on the Services, (ii) design the Services to anticipate and tolerate failures, and (iii) implement appropriate processes designed to move Personal Data traffic away from the affected areas when necessary to recover from failures.
    8. Business Continuity and Disaster Recovery Photo Finale will maintain a risk management program designed to support the continuity of its critical business functions, including processes and procedures for identification of, response to, and recovery from, events that could prevent or materially impair Photo Finale’s provision of the Services You receive.
    9. Incident Management Photo Finale provides documentation for You to report security or availability incidents, ask security or availability questions, and submit information about potential security or availability issues. Photo Finale will maintain corrective action plans and incident response plans designed to detect, mitigate, investigate, and respond to potential security threats to the Services.
    1. Physical SecurityWhere necessary to protect Services, Photo Finale will (i) implement reasonable measures designed to prevent unauthorized physical access, damage, or interference to the Services, (ii) use appropriate control devices designed to restrict physical access to the Services to only authorized personnel who have a legitimate business need for such access, and (iii) perform periodic reviews to validate adherence with these standards.
    2. Photo Finale EmployeesPhoto Finale employees who are authorized to access Personal Data are bound by obligations of confidentiality as part of their terms of employment. Photo Finale will implement and maintain employee security training programs regarding Photo Finale information security requirements. The security awareness training programs will be reviewed and updated periodically.
    3. Modifications to this Appendix

    Photo Finale reviews its security measures from time to time, and may update this Appendix in its sole discretion. Any such updates will replace prior versions of this Appendix as of the date that Photo Finale publishes the updated version.

    APPENDIX C: GDPR, UK GDPR, AND SWITZERLAND DATA PROCESSING APPENDIX

    Where the processing of Personal Data under the DPA is subject to data protection requirements in the European Economic Area (the “EEA”), the United Kingdom (the “UK”), or Switzerland (collectively, “European Data Protection Laws”), Appendix C supplements this DPA.

    1. Nature of the Processing and Role of the Parties
    2. Personal Data
    1. Under this Appendix You shall act as a Data Controller and Photo Finale shall act as a Data Processor with respect to the processing of Your Personal Data as described in Annex 1, as necessary to fulfill the business purposes outlined in the Terms and provide You with the Services You choose to use.
    2. For the avoidance of doubt, Photo Finale shall act as an independent Data Controller with respect to Personal Data about Customers that Photo Finale receives as a result of the Customer’s direct relationship or intentional interactions with Photo Finale, as described in Photo Finale’s Privacy Policy.
    1. Obligations of the Parties
    2. Your Obligations

    You shall comply with:

    • European Data Protection Laws binding on You in the performance of this Appendix; and
    • Your obligations set out in the DPA, including Your obligations set forth in this Appendix.

    You represent and warrant that You have a valid legal basis for processing the Personal Data (including making any such data available to Photo Finale) and have obtained any necessary consents, rights and authorizations and given any necessary notices to individuals regarding Your disclosure of Personal Data to Photo Finale to enable Photo Finale’s processing of Personal Data to provide the Services, as required by European Data Protection Laws.

    1. Photo Finale’s Obligations
    2. Instructions of the Controller and Infringement of European Data Protection Laws
    3. a)The Parties agree that the Terms together with this DPA constitute Your documented instructions regarding Photo Finale’s processing of Your Personal Data (“Documented instructions”).
    4. b)Photo Finale will process Personal Data as a Processor only: (i) in accordance with Your Documented instructions, or (ii) to comply with Photo Finale’s obligations under applicable laws, subject to any notice requirements under European Union or European Union member state law to which Photo Finale is subject.
    5. c)Photo Finale will notify You if it receives an instruction that it reasonably determines infringes European Data Protection Laws (but Photo Finale has no obligation to actively monitor Your compliance with European Data Protection Laws).
    6. Confidentiality obligation

    Photo Finale will ensure persons who it authorizes to process Personal Data either enter into written confidentiality agreements or are subject to statutory obligations of confidentiality.

    1. Security measures
    2. a)Photo Finale shall implement and maintain appropriate technical and organizational measures designed to protect Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, unauthorized access, alteration, or disclosure, as set forth in Annex 2.
    3. b)Taking into account the nature of the Personal Data and related processing, Photo Finale shall provide such reasonable assistance as You may reasonably request to help You fulfill Your security obligations under European Data Protection Laws.
    4. c)Photo Finale shall provide You with notice, without undue delay, upon becoming aware of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Your Personal Data transmitted, stored or otherwise processed.
    5. d)Photo Finale agrees to investigate any such security breach and use commercially reasonable efforts to mitigate the effects.
    6. Subprocessors
    7. a)You generally authorize Photo Finale to engage Subprocessors to process Personal Data. You further agree that Photo Finale may engage its affiliates as Subprocessors.
    8. b)Photo Finale’s use of Subprocessors to process Your Personal Data will be in compliance with European Data Protection Laws.
    9. c)Photo Finale maintains an updated list of all Subprocessors as set forth in Annex 3. Photo Finale will update the list of Subprocessors as appropriate and provide You with a mechanism to obtain notice of the addition or replacement of a Subprocessor. You may object to Photo Finale’s use of a new Subprocessor.
    10. d)To the extent You object to Photo Finale’s use of a Subprocessor, and Photo Finale is unable or unwilling to accommodate such requests, You may terminate Your use of the impacted Services within 30 days of such notification in accordance with the Terms.
    11. e)Where Photo Finale engages a new Subprocessor, Photo Finale will enter into a written agreement with the Subprocessor and Photo Finale will impose, on the Subprocessor, contractual obligations that are substantially the same as the ones set out in this DPA. Photo Finale shall be fully liable for the acts and omissions of its Subprocessors to the same extent Photo Finale would be liable if performing the services of each Subprocessor directly under the terms of this DPA. Photo Finale’s liability will nevertheless be subject to the conditions and limitation of liability set forth in the Terms.
    12. Assistance to the Controller
      Taking into account the nature of Your Personal Data and related processing, Photo Finale shall provide such reasonable assistance as You may reasonably request to assist You in complying with Your obligations:
    • to respond to Data Rights Requests under European Data Protection Laws;
    • to notify relevant authorities and/or data subjects of a Personal Data Breach;
    • to conduct data protection impact assessments and prior consultations;
    • to ensure the security of the processing in accordance with section 3.
    1. Assessing compliance
    2. a)Photo Finale may fulfill Your right of audit under European Data Protection Laws in relation to the processing of personal data by providing You – upon Your written request and subject to confidentiality – with:

    (i) Photo Finale’s most recent audit report results, either from Photo Finale’s self-audits or prepared by an independent third party auditor;
    (ii) additional information in Photo Finale’s control if a data protection or governmental authority requests it.

    1. b)Provided that and only to the extent that European Data Protection Laws grant You this right, You may exercise Your Audit right: (i) to the extent that an independent internationally recognized auditor attests that Photo Finale’s provision of an audit report does not provide sufficient information for You to verify Photo Finale’s compliance with this DPA and with European Data Protection Laws or (ii) as necessary for You to respond to a government authority audit. Each audit must conform to the following parameters: (i) be conducted by an independent third party that will enter into a confidentiality agreement with Photo Finale; (ii) be limited in scope to matters reasonably required, and as mutually agreed upon, for You to assess Photo Finale’s compliance with this DPA and the parties’ compliance with European Data Protection Laws; (iii) occur at a mutually agreed date and time and only during Photo Finale’s regular business hours; (iv) occur no more than once annually (unless required under European Data Protection Laws); (v) cover only facilities controlled by Photo Finale; (vi) restrict findings to Personal Data only; and (vii) treat any results as confidential information to the fullest extent permitted by European Data Protection Laws. For clarification, Photo Finale will comply with any of Your rights under this section 6 in accordance with its confidentiality obligations with third parties.
    2. End of processing
    3. a)During Your use of the Services, You may leverage account tools to access, return to yourself, or delete Personal Data.
    4. b)Following termination, Photo Finale will, at Your choice, delete or return Your Personal Data. Notwithstanding the foregoing, Photo Finale may retain Personal Data: (i) as required by law, including European Data Protection Laws; and (ii) in accordance with its standard backup or record retention policies, provided that, in either case, Photo Finale will maintain the confidentiality of, and otherwise comply with the applicable provisions of this DPA with respect to, retained Personal Data, and not further Process retained Personal Data except for such purpose(s) and duration permitted under such applicable laws.
    5. International Transfers
    6. a)Subject to compliance with European Data Protection Laws, Photo may transfer Personal Data processed under this Appendix outside of the EEA, the UK, and Switzerland as necessary to provide its Services (“International Transfers”).
    7. b)Such transfers consist primarily in transferring Personal Data to Photo Finale Inc., based in the USA.
    8. c)Any International Transfers to countries which do not ensure an adequate level of data protection within the meaning of the European Data Protection Laws, will be subject to appropriate safeguards including the following transfer mechanisms:
    • the relevant modules under the 2021 Standard Contractual Clauses approved by the European Commission in its decision 2021/914/EC dated June 4, 2021;
    • the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers issued by the UK Information Commissioner’s Office under S119A(1) of the UK Data Protection Act 2018;
    • the 2021 Standard Contractual Clauses as amended to satisfy the requirements of the Swiss Federal Act on Data Protection (as amended from time to time) of June 19, 1992 as revised as of September 25, 2001; and
    • any standard contractual clauses, international data transfer addendum or other clauses, addenda or transfer mechanisms that might replace the current clauses and addendum.
    1. d)Photo Finale may, in its sole discretion, replace any transfer mechanism to ensure that data transfers comply with applicable laws. If a transfer is based on standard contractual clauses and such clauses are updated by the relevant authorities, such updated clauses or similar agreements will be incorporated into this DPA as if fully stated herein.

    ANNEX 1 – PERSONAL DATA

    DESCRIPTION OF THE PROCESSING OF PERSONAL DATA

    1. Subject Matter of the Processing

    Provision of Photo Finale Services to Merchant.

    1. Categories Of Data Subjects

    Customers of Merchant.

    III. Categories Of Personal Data Processed

    See Appendix A above.

    1. Frequency of the transfer

    Continuous.

    1. Nature Of The Processing

    Collection, recording, hosting, access, use, transfer and deletion of Personal Data as described in the Terms.

    1. Purposes For Which The Personal Data Is Processed On Behalf Of The Controller

    For the performance and improvement of the Services as described in the Terms.

    VII. Duration Of The Processing

    Duration of the Services under the Terms or applicable agreement, plus the period after such expiration until the anonymization, return, or deletion of data.

     

    ANNEX 2 – SECURITY MEASURES

    Information on security measures is provided in Appendix B of the DPA.

    ANNEX 3 – LIST OF SUBPROCESSORS

    The Subprocessors used by Photo Finale for the performance of the Services under the Terms can be requested by contacting Photo Finale Support.

    The Subprocessors will process the categories of Personal Data described above in connection with the Services for the duration of their agreement with Photo Finale.