Privacy Policy

Last updated: February 14, 2025

This Privacy policy explains who we are, how we collect and process your personal data and how you can exercise your data protection rights.

Pixcham International j.s.a., with its registered office at Námestie svätého Egídia 42/97, 05801 Poprad, Slovak Republic, registered in the Commercial Register of the District Court of Prešov, Section: Sja, Entry No.: 28/P (hereinafter referred to as "Pixcham", "we", "our" or "us"), has created and operates the Pixcham app, which is available for download in the Apple App Store and the Google Play Store. This Privacy Policy applies to the personal data we collect and process when operating our Pixcham mobile application (the "App") and website http://www.pixcham.com (the "Website") (the App and Website are collectively referred to as the "Services" ). By using our Services, you agree to this Privacy Policy and consent to the processing of your personal data in accordance with this Privacy Policy (the "Privacy Policy").

Pixcham operates the App, which provides you with a fast, beautiful and fun way to share selfie photos, tags and other related content ("User Content") through our Content Sharing Platform on the App, and allows you to participate in Challenges organized by Challenge Organizers or us through the App, and Battles. For more information about the App Platform, please refer to our Terms of Service available on the App and published on the Website.

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

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

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

Capitalized terms in this Privacy Policy have the same meanings as assigned to them in the Application Terms of Service ("Terms"), unless otherwise specified in this Privacy Policy.

When we are the controller and when we are the processor of personal data

Pixcham acts as both a controller and a processor of personal data in accordance with the GDPR when operating the Application.

Pixcham acts as a data controller when it determines the purposes and means of processing your personal data. As a data controller, Pixcham processes your personal data when you create an account on the App (e.g. email addresses) for the purposes of managing accounts, providing access to the Services, providing customer support, conducting marketing activities, ad analytics, engaging in Battles, verifying the identity of Winners, or organising Challenges on its own behalf.

Pixcham acts as a data processor when it processes the personal data of Users (in particular, selfies, email and username) who participate in Challenges. In such cases, the Challenge Organiser acts as the data controller and Pixcham acts as its data processor, processing the Users' personal data on behalf of the Challenge Organiser in accordance with the data processing addendum set out in Annex 1 of this Privacy Policy or under a separate data processing agreement concluded with the Challenge Organiser.

In general

The protection and security of your personal data is important to us and we always take special care to process your data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR"). We have appointed a Data Protection Officer to help us ensure compliance with the provisions of the GDPR and applicable data protection laws. We retain your information for as long as necessary to provide the Services. We may retain information for longer if required by applicable law. We operate globally and share your information with our partners and service providers (a list of our current partners and service providers can be found here) for the purposes described below in the "How We Share Your Information" section of this Privacy Policy, which may include transferring your personal information outside of the European Economic Area ("EEA"). Please check this Privacy Policy periodically for changes.

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

Pixcham does not use automated decision-making when processing personal data.

Information We Collect About You

Most of the information we collect about you comes directly from you when you use our Services or interact with ads on our App. In general, the information we collect about you relates to the type of device you use, information that helps us identify your device, how you use our App, and may also include information you provide when you voluntarily contact us.

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

Information that you provide voluntarily

Some parts of our Services may ask you to voluntarily provide personal information. For example, within the App, when you create an account, we will ask you for certain information so that you can participate in Challenges or Battles, such as:

your username, display name on the App, email address, date of birth, country of nationality, password or other information necessary to process your enquiries;
User Content (i.e. selfie photos, tags, and other related content) that you post within the Services;
any data and information you submit through our Services;
any information you submit to our support team via email;

If you participate in a Challenge organised by a Challenge Organiser other than Pixcham, you are providing your personal data to that Challenge Organiser. Pixcham will process your personal data (in particular selfie photos, username, email) provided during the Challenge on behalf of the Challenge Organiser as a data processor.

If you choose to participate in a Challenge and you win such Challenge, you may be asked to provide us or the Challenge Organiser with additional information for the delivery of the Prize, such as your name, surname, telephone number, address or bank account number.

If you participate in the Challenge and provide the Challenge Organiser or Pixcham with your personal data, in particular your username and selfie photo, you acknowledge that this data will be published on the App for other Users who have participated in the Challenge and also on the relevant Challenge sub-page, which is publicly accessible to all visitors. The Challenge Organiser or Pixcham may also share your personal data via social networks for self-promotion purposes. The Challenge Organiser or Pixcham may also share your personal data via social networks for self-promotion purposes. The information you provide will remain published on the App and on the Challenge sub-page until you choose to delete your Profile on the App.

Information that we collect

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

data and analytics about your use of our Services (e.g., history of Challenges you have participated in or history of Battles, session length, preferred settings, ads on the App that you may have viewed, links on the App or just App preferences, how you have been referred to our Services);
Logs to the Application;
Your IP address and device identifiers such as your Advertising ID, Device ID numbers;
The type of operating system you are using and its version;
Your communications within the Service (e.g. emotional signals in the App that you exchange with other players);

Device identifier/device information means the device type, device operating system and device version available to the developer from the device to check the compatibility of the device with a particular Application.

Some of this information may be collected through the use of cookies, as further explained in the Cookies section of this Privacy Policy.

Information we obtain from third-party sources

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

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

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

No special categories of information (except for User Content)

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

How We Use Your Information

In General

We use the information we collect about you/your device to provide the Services and to operate the App. We also use it to improve our Services, enhance security, and for analytics and research purposes to provide you with the best possible Services. In addition, we use your information to promote our Services, as well as in other publishers' apps and to display third-party advertisements. We also use your data to monitor and prevent fraud for advertising purposes and to comply with our legal obligations.

We use your information for the following purposes:

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

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

Marketing. If you give us your consent or if we rely on our legitimate interest, we will use your data for direct marketing of our Services and to send you commercial communications by all available means, including electronic means of communication.

Monitoring and evaluation of advertising. We use your data to monitor the performance of our advertising campaigns.

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

Security. We use your information to enhance the safety and security of the Services.

Customer support. We use your data to provide customer support and to answer your questions.

Verification of the identity and age of the winners. In order to verify the identity and age of the Winner, we may perform verification through a third party service.

Our legal obligations. We use your data when we are required to do so by law, for example to record data breaches or to deal with requests to exercise the rights of data subjects.

Proving, asserting and defending legal claims.

How We Share Your Information

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

We may share such information to:

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

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

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

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

We reserve the right to disclose your data (including personal data) pursuant to law, legal process, litigation and/or requests by public and governmental authorities in or outside your country of residence. We may also disclose information about you if we determine that disclosure is necessary or appropriate for national security, law enforcement or other matters of public importance. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce these Terms or to protect our operations, Users, or the User experience. In addition, in the event of a reorganization, merger or sale, we may transfer any information (including Personal Information) we collect to the appropriate third party.

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

Advertising

In General

We use advertising to fund our Services and make our App available. We offer some features of our App free of charge, and to do so we need to share information that we collect from you, particularly when you interact with ads. To protect your privacy, we retain personal information only temporarily. The information we collect helps us to improve the Services while keeping our App accessible to a broad user base.

Please be aware that:

a) if you use our Services, you may receive marketing communications (e.g. newsletters) based on our legitimate interest or the legitimate interest of the Challenge Organisers. You have the right to object to receiving such marketing communications at any time.

b) We analyze your interaction with the ads displayed (e.g., the number of times an ad is seen or clicked on) during the duration of the Challenge solely on the basis of your consent. We share this analytical data with the Challenge Organisers. We use the following data for this purpose: country, operating system, account identifier.

Third-party Social Networks

Connecting to Third-Party Social Networks

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

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

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

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

How you share your information on Third-Party Social Networks

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

Cookies

Cookies are small files that are stored on your mobile device or internet browser when you browse our Website. They enable us to improve the functionality of the Website, understand user behaviour and deliver more targeted online advertisements and campaigns. We use the following basic types of cookies on our Website:

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

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

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

Cookies

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

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

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

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

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

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

Children's Privacy

In order to protect children's privacy and ensure their safety, children under the age of 16 are not permitted to create an account on the App. Participation in the Challenge may also be restricted to Users under the age of 18 or subject to the consent of a parent or legal guardian of a User under the age of 18. As the operator of the Application, we take reasonable steps to ensure that the person providing consent is the parent or legal guardian of a child under the age of 18. If we become aware that we have collected personal information from children under the age of 16, we will take immediate steps to remove all such information from our servers and terminate any accounts that the child has created through the Application.

Your Rights

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

With regard to consent, we must expressly inform you that you have the right to withdraw your consent at any time by sending an email to legal@pixcham.com. Withdrawal of consent does not affect the lawfulness of data processing based on consent prior to its withdrawal.

Your other rights include:

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

Legal Basis

In any case, when we process your data, we do so lawfully in accordance with one of the legal bases set out in the GDPR.

The legal bases that we rely upon are the following:

Contractual Necessity. This applies to information that we process in order to provide you with the service you have requested - and to which we have agreed to provide - i.e. to provide and improve the Services, to provide customer support, to provide special features on the App,
Legitimate interests. This includes information that we process for purposes that can reasonably be expected in connection with your use of the Services, to pursue our legitimate interests in order to provide you with the best possible experience when using the App and/or the Services, to ensure the security of your information, and to provide you with certain features of the App free of charge or at a low cost. We pay particular attention to your data protection rights, ensuring that your data protection rights do not override our legitimate interests. We rely on our legitimate interests when processing data for the purposes of analytics, fraud tracking and prevention, push notifications, cross-promotion and contextual advertising. Pixcham also relies on legitimate interests in the event of legal or extrajudicial disputes or in proceedings with public authorities in which it asserts or defends its legal claims or when sending marketing communications to its existing or former Users in order to offer Users relevant and interesting information. Pixcham also processes, on the basis of legitimate interest, the personal data of contact persons or other persons authorised to act for or on behalf of the Challenge Organisers as well as in verifying the identity of the Winners.
Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
Legal obligation. This applies to information that we process to comply with a legal obligation, for example, to keep records for tax purposes, when dealing with a request to exercise the rights of data subjects, when recording personal data breaches or when dealing with complaints.

Security

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

International Transfer of Personal Information

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

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

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

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

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

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

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

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

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

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

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

Service provider:
Temporal Technologies Inc.
Privacy policy of service provider:
https://temporal.io/global-privacy-policy
Transfer mechanism:
EU SCC.

Service provider:
MongoDB, Inc.
Privacy policy of service provider:
https://www.mongodb.com/legal/privacy/privacy-policy
Transfer mechanism:
Adequacy Decision under Article 45 GDPR, EU Standard Contractual Clauses, EU and US Data Privacy Framework.

Retention of personal data

We retain your data for as long as necessary to provide the Services. If you request cancellation of your Account, your personal data will no longer be available on the App. However, we will retain the data for 30 days from the date of cancellation of your Account, after which it will be permanently deleted. In the event that a Challenge Organiser cancels its business account on the App, your personal data relating to its Challenges will be retained until such time as its business account is cancelled. For identity verification, we will retain the data provided for 2 years from the date your identity is verified. We will retain data related to ad analytics for a maximum of 7 days from the end of the Challenge(s).We will delete the information as soon as we no longer need it for the purposes described in this Privacy Policy.

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

Changes to Our Privacy Policy

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

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

Contact us

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

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

Annex 1 - Appendix on the processing of personal data (hereinafter referred to as the "Appendix")

1. Subject matter of the Addendum and its basic terms and conditions

1.1 Pursuant to this Addendum, the Challenge Organizer authorizes Pixcham to process personal data to the extent and under the terms and conditions set forth in this Addendum. Pixcham undertakes, on the basis of the Call Organiser's authorisation, to process personal data in the manner, to the extent, for the duration, for the purpose and in accordance with the further terms and conditions set out below, so that all activities where Pixcham processes personal data on behalf of the Call Organiser are carried out in accordance with the GDPR, European Union law or other generally binding legislation of the Slovak Republic in the field of personal data protection (hereinafter referred to as the "Legislation").

1.2 The purpose of the processing of personal data determined by the Challenge Organiser is the provision of services related to the implementation of the Challenge in the Application.

1.3 Pixcham is only authorised to process Personal Data on the documented instruction of the Challenge Organiser, unless otherwise stated in clause 1.5 of the Appendix. For the purposes of this Addendum, the documented instruction of the Challenge Organiser shall be deemed to be the creation of the Challenge on the App itself. This is without prejudice to the Challenge Organiser's ability to specify other conditions for the processing of personal data in its instruction.

1.4 Pixcham is entitled to process personal data even without a documented instruction from the Challenge Organiser, insofar as this is required by the Legislation.

1.5 Pixcham is entitled to process personal data within the meaning of this Addendum only until cancellation of the User's account on the App or until cancellation of the Challenge Organiser's account on the App, unless Pixcham is required by Law to process such data for a longer period of time.

1.6 Pursuant to this Addendum, Pixcham will process on behalf of the Challenge Organiser, in particular, routine personal data (e.g. username, email, selfie photos) provided by the User when joining the Challenge. If the User wins a Prize, Pixcham may also process other personal data necessary for the delivery of the Prize; for example, residence, telephone number or account number.

1.7 The data subjects whose personal data will be processed by Pixcham pursuant to this Addendum are Users.

1.8 Pixcham is entitled, on the instructions of the Challenge Organiser and in accordance with the Legislation, to personal data, in particular:

☒ obtain,

☒ record,

☐ organise,

☐ structure,

☒ preserve,

☐ revise or change,

☐ search,

☐ use,

☐ provide by transmission,

☐ rearrange,

☒ delete or dispose of.

2. Other conditions for the processing of personal data

2.1 Pixcham is entitled to process personal data to the extent and under the conditions set out in this Appendix and in the Legislation. Pixcham undertakes that when processing the personal data of data subjects, it will act in such a way as to avoid jeopardising the rights and legitimate interests of such persons.

2.2 Pixcham is obliged to maintain the confidentiality of personal data.

2.3 Pixcham shall ensure that its employees and any other persons designated by it who process the personal data of data subjects ("Authorised Persons") process such data only on the basis of, and in accordance with, the instructions of the Challenge Organiser and that they are bound by an obligation of confidentiality in respect of such data. Pixcham is obliged to ensure that this obligation of confidentiality continues after the processing of the data subjects' personal data by the Authorised Persons has ceased.

2.4 Pixcham is obliged to inform all Authorised Persons of the security measures taken, of the rights and obligations provided for by the Legislation and of the liability for breach thereof. Pixcham is obliged to carry out the instruction before issuing the first instruction to an Authorised Person to carry out any processing operation with Personal Data. Each Authorised Person shall acknowledge the instruction by signing it.

2.5 Pixcham shall keep a written record of the instruction throughout the duration of the employment or other relationship with the Eligible Person.

2.6 The duty of confidentiality of Pixcham and the Eligible Persons under clauses 2.2 and 2.3 shall not apply in relation to the relevant Supervisory Authority and in relation to the Challenge Organiser when inspecting the performance of any obligation under this Addendum or the Legislation.

2.7 Pixcham is obliged to ensure the secure processing of Personal Data, in particular to protect it against damage, theft, loss, unauthorised access, alteration or dissemination. To this end, Pixcham undertakes to adopt and regularly update appropriate technical, organisational and personnel measures determined in the light of the state of the art, the state of the art, the costs of implementing these measures, the nature, scope, context and purposes of the processing of personal data and the risks to the rights and freedoms of data subjects. To this end, Pixcham shall ensure in particular that:

(a) personal data are used, disclosed, made available or otherwise processed only in accordance with the purpose for which they are processed and are not otherwise unreasonably processed;

(b) only designated persons who are trained and authorised to process personal data have carried out the necessary operations with personal data within the purpose of the processing;

(c) use appropriate technical equipment and software in a manner which excludes unauthorised or accidental access to personal data;

(d) personal data are accessible only to designated persons who are trained and authorised to process personal data;

(e) personal data in electronic form is stored on secure servers or on secure storage media to which only Authorised Persons will have access;

(f) the personal data in electronic form is backed up regularly;

(g) the long distance transmission of personal data was only over a network not accessible to the public or through secure transmission over public networks;

(h) personal data on physical media or in paper form are stored in appropriately secured premises and rooms (that is, in a locked area); and

(i) all Authorised Persons who come into contact with the Personal Data have maintained the confidentiality of the Personal Data.

2.8 Pixcham is responsible for the security of the personal data it processes under this Addendum.

2.9 Pixcham undertakes to provide the Challenge Organiser with the necessary cooperation and assistance through appropriate technical and organisational measures in fulfilling the Challenge Organiser's obligation to respond to requests for the exercise of the rights of data subjects set out in Chapter III of the GDPR or in other Legislation governing the rights of data subjects in relation to their personal data.

2.10. Pixcham undertakes to provide the Challenge Organiser with cooperation and assistance in fulfilling the obligation to provide data subjects with the necessary information (Articles 13, 14 GDPR), to process personal data securely (Article 32 GDPR), the obligation to notify a personal data breach to the competent supervisory authority (the Office for Personal Data Protection of the Slovak Republic) (Article 33 GDPR), the obligation to notify a personal data breach to the data subject (Article 34 GDPR), the obligation to carry out an impact assessment of the planned processing operations on the protection of personal data (Article 35 GDPR) and, depending on the results of the impact assessment carried out, the obligation to consult with the competent supervisory authority (the Office for Personal Data Protection of the Slovak Republic) prior to the commencement of the processing of personal data (Article 36 GDPR), all to the extent and taking into account the nature of the processing and the information available to Pixcham.

2.11 Pixcham undertakes to provide the Challenge Organiser, upon request, with all information and certificates proving compliance with the obligations set out in this Agreement and the Legislation, without undue delay after receipt of the Challenge Organiser's request.

2.12 Pixcham agrees to allow the Challenge Organiser to inspect and audit compliance with the obligations set out in this Addendum and the Legislation ("Audit"), whether by the Challenge Organiser in person or by a third party appointed by the Challenge Organiser. The Audit shall be carried out on a date to be agreed in advance between the Parties.

2.13 Pixcham undertakes to notify the Challenge Organiser without undue delay in a demonstrable manner of any case where, in its opinion, instructions given by the Challenge Organiser are in breach of the Legislation.

2.14 Pixcham undertakes to notify the Challenge Organiser without undue delay in a demonstrable manner of any breach of the protection of the personal data of Data Subjects processed of which it becomes aware.

2.15 Pixcham shall perform all obligations under this Addendum and the Legislation at its own expense, without any claim for reimbursement of such costs and without any claim for remuneration.

2.16 Pixcham shall, without undue delay after the end of the provision of the Services, cease processing personal data and return any data, information, records and documents containing personal data to the Challenge Organiser and destroy any copies of such personal data in its possession. If the Challenge Organiser instructs Pixcham to carry out the destruction of the Personal Data directly without the need to return it to the Challenge Organiser, Pixcham shall do so, including before the end of the provision of the Services. Pixcham shall not be obliged to destroy the personal data processed on behalf of the Challenge Organiser or copies thereof, unless the Legislation requires their retention, of which Pixcham shall provide Pixcham with demonstrable prior notice.

3. Involvement of another intermediary

3.1 The Challenge Organiser hereby authorises Pixcham to engage the processors listed on this link https://www.pixcham.com/partners to process the personal data of the data subjects. In addition to these persons, Pixcham may also involve IT service providers or marketing service providers with whom it cooperates to ensure the operation of the Application in the processing of personal data within the meaning of this Addendum.

3.2 Pixcham shall be obliged to inform the Challenge Organiser in advance of the intended addition of an additional processor or the replacement of an existing processor with another processor in a demonstrable manner.

4. Pixcham statement

4.1 Pixcham declares that it meets the requirements of professional, technical, organisational and personnel competence and capability to guarantee the security of the personal data of Data Subjects processed and to provide sufficient guarantees that the personal data of Data Subjects will at all times be processed in accordance with the Legislation.