Categories of data: Purposes of processing Legal basis:

Categories of data:	Purposes of processing	Legal basis:
Browsing data	To extract statistical information on service usage (most visited pages, visitors by time/date, geographical areas of origin, etc.) and to check the functioning of the services.	It is Pixlr Pte. Ltd.’s legitimate interest to analyse and improve the performance of its services and to prevent crimes and frauds (Art. 6(1)(f) of the GDPR). We will analyse your Personal Data in order to improve Our services and your experience with Our Website (where your consent is not required, Art. 6(1)(a) of the GDPR).
Registration/creation of the profile	To process the creation of your account and profile on the Website and to provide or allow you to access certain areas, functions and features of Our Website.	Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1)(b) of the GDPR).
Biographical data, facial geometry, financial information and billing details	To provide you with the products and/or services you purchased or subscribed to, as well as processing transactions and payments in connection therewith.	Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1) of the GDPR).
	For administrative purposes connected with the performance of the commercial relationship with you or the fulfillment of legal requirements or for complying with any requests from the competent authorities.	Compliance with a legal obligation to which We are subject (Art. 6(1)(c) of the GDPR) or, in the event there is no such legal obligation, Our legitimate interest to keep adequate records in connection with the execution of the commercial relationship (Art. 6(1)(f) of the GDPR).
	To share the Personal Data with the other Pixlr Pte. Ltd. companies within the European Economic Area (EEA) for internal administrative purposes.	It is Pixlr Pte. Ltd.’s legitimate interest for transmitting Personal Data within the group of undertakings for internal administrative purposes, including the processing of customers’ Personal Data (Art. 6(1)(f) of the GDPR).
Account and contact details	To contact you with information about current or new products, commercial opportunities, promotions and services or events sponsored by us that may be deemed to be of interest to you, as well as to verify customer satisfaction and to carry out market research, analysis and surveys, and also to allow you to participate into prize contests, rewards, trips and/or receive gifts.	Your consent (Art. 6(1)(a) of the GDPR).
	To respond to your queries and questions and to provide any information you require (e.g., information and suggestion about products) in the “Contact Us” section.	It is Pixlr Pte. Ltd.’s legitimate interest to provide customer service and respond to your queries (Art. 6(1)(f) of the GDPR).
	To contact you with information about other products owned by Us that may deem interest to you.	Your consent (Art. 6(1)(a) of the GDPR).

The submission of your Personal Data is not mandatory. Any refusal to provide the consent will not have any effect other than Our inability to provide you the products and/or services. In such situation, We shall not be liable for any losses, liabilities and damages whatsoever and howsoever arising thereof. At any time, you have the right to withdraw your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before the withdrawal.

Information We may share and data recipients

Your Personal Data are processed by Our personnel and, if necessary or functional to fulfilling the purposes indicated above, your Personal Data may be processed by third parties that may be appointed by Us as data processors.

The categories of recipients to whom your Personal Data may be disclosed to as follows:

• third parties such as (i) IT providers; (ii) financial institutions or payment gateway providers in connection with the processing of financial and payment information; (iii) marketing agencies to carry out marketing campaigns, surveys and promotions; (iv) legal, accounting, tax, labour consultants and other professionals; (v) other Pixlr Pte. Ltd. companies within the European Economic Area (EEA); and
• public entities and authorities, exclusively for the purpose of fulfilling legal and regulatory obligations.

Under certain circumstances, your Personal Data may be transferred outside the European Economic Area (EEA) to other Pixlr Pte. Ltd. companies or to third party’s data processors. In such cases, We ensure that We have adopted appropriate safeguards, including binding corporate rules or standard data protection clauses adopted by the European Commission, in order to guarantee the data subjects with an adequate level of protection. You may obtain a copy of these appropriate or suitable safeguards when contacting Us at the contact details above.

Retention of your Personal Data

Data are retained as long as necessary for the performance of the services provided by the Website and to comply with legal obligations, to meet regulatory requirements, resolve disputes, maintain security, and/or to prevent frauds and abuse.

In relation to Personal Data of your profile, We will retain the same as long as your account with Us is still active. If you choose to close the account or if your account is closed, We will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted We will delete your Personal Data and information within thirty (30) days. This is without prejudice to Our right to retain the information (such as username and transaction details) to comply with legal obligations, prevent frauds and protect Our legal interest.

Security

We treat the security for all information submitted or provided by you to Us seriously and is of importance to Us. We will take reasonable steps to protect or secure this data, including your Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing and etc). You are also advised not to disclose and secure your own username and password.

Your Rights

You have the right to obtain from Us confirmation whether your Personal Data are being processed by Us, and, in said circumstances, you have the right to request access to and rectification or erasure of the same or restriction of processing, and to object to the processing at any time, as well as under certain circumstances the right to data portability. With respect to the data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of said data.

With respect to the right to object where the processing is based on Our legitimate interest, you can object to the processing at any time and We will cease processing your Personal Data unless we have a compelling legitimate reason to continue such processing or where the processing is needed for legal reasons. In addition, you can object to the processing of your Personal Data in the circumstance such as where We are processing the Personal Data for direct marketing purposes.

If you have subscribed to or opted-in to receive Our marketing communications you can opt-out at any time, free of charge, requesting that your Personal Data not be used for marketing purposes.

You may exercise any of the above rights by contacting Us at info@vectr.com or by postal mail at 30, Cecil Street, #19-08 Prudential Tower, Singapore 049712. As an EU citizen, you may also contact Our representative in the EU, RIVACY GmbH, at Mexikoring 33, 22297 Hamburg, Germany. As a UK citizen, you may also contact Our representative in the UK, RIVACY Ltd., at Unit G1/G2, The Imperial Laundry, 87 Warriner Gardens, London SW11 4DX.

You have the right to lodge a complaint with a supervisory authority.

Links to Third Party Website(s)

Our Website or any products/services being rendered to you may contain links to other websites that are not operated by Us and whose privacy practices may differ from Us. If you click on a third-party link, you may be directed to the third-party website. Any submission of your Personal Data to any of those third-party websites will be governed by the relevant third-parties’ privacy policies. We have no control and shall not assume any responsibilities howsoever arising thereof and We strongly advise you to carefully read the privacy policies prior to the disclosure of any information.

Advertising
We may, from time to time, partner with a third party to display Our or a third party’s advertisement(s) on Our Website or engage a third party to manage Our advertising on Our Website. For more detailed information, please refer to Our Cookie Policy (https://vectr.com/cookie.html).

Mobile Applications or Mobile Website

We may provide Our products or services to you via our mobile applications or mobile website that is designed to be used on mobile computing devices (the "Applications"). You may be required to log in to Our mobile applications or mobile website with your username and password in order to allow you to associate with the user account you have created on Our Website. The processing of Personal Data information therein will also be governed in accordance with this Privacy Policy and Our Cookie Policy.

Contact Us

If you: (i) have any questions, queries, inquiries or comments on Our Privacy Policy; (ii) have any concerns about how We process your Personal Data; (iii) would like to opt out of direct marketing activities; (iv) would like Us to update information or preferences you have provided to Us; or (v) have any other issues relating to this Privacy Policy, you may also get in touch with Our designated Data Protection Officer at dpo@pixlr.com.

Changes to this Privacy Policy

We will keep this Privacy Policy under regular review, and We may update this Privacy Policy from time to time. The updated version shall apply and supersede all previous versions. Hence, it is advisable that you check this Privacy Policy on a regular basis.

Last updated: 23 October 2024.