PRIVACY POLICY

This Privacy Policy (together with the documents expressly referred to in it) gives you information about how Drawy (“Drawy”, “we”, “us”, “our” or other similar expressions) collects, uses, and discloses information obtained through using our websites (the “Website”) and the obtaining, subscribing to or otherwise enjoying the services Drawy offers (the “Services”).

We really value your privacy rights and wish to be as clear and complete as possible about our data processing activities. We strongly recommend any customer or user who has a question about this Privacy Policy to inform us of this.

Please read this Privacy Policy carefully and make sure that you understand it, before ordering or using any Services from the Website. This Privacy Policy contains important clauses which may have an impact on you such as the processing of your personal data, the transfer of your data to third parties and the transfer of your data to third countries that do not offer a level of protection as provided in your home country.

Please note that when registering, you will be asked to explicitly agree to this Privacy Policy. Additionally, by making use of the Website without registration, you explicitly agree to be bound by this Privacy Policy where and to the extent relevant.

If you do not agree with any provision set out in this Privacy Policy, please discontinue the use of the Services and access to the Website.

1.1 The use Drawy makes of the information collected through the Services varies depending on whether you are:

1.1.1 a Drawy customer (“Customer”),i.e. any person having directly concluded an agreement with Drawy for the provisions of the Services, and this for the benefit of the Customer and its Users;

1.1.2 a Drawy user (“User”),meaning an end-user of the Services under the subscription by the Customer; or

1.1.3 a mere visitor of our Website, without registering our subscribing to the Services (“Visitor”),which may include Customers as well as prospective customers. The information of this Privacy Policy is split up between those categories of persons, whereas the provisions which are applicable to all categories are contained in a separate section. Please consult all provisions which are applicable to you.

1.2 Personal data as used throughout this Privacy Policy, refers to all information which directly or indirectly relates to a natural person, such as a name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual, or as otherwise defined by applicable privacy and data security laws. Personal information together with other information is collectively referred to in this Privacy Policy as “Information”.

1.3 Your use of our Services and Website, and any dispute over privacy, is subject to this Privacy Policy, our Cookie Policy and our Drawy Terms and Conditions.

2.1 We collect Customer Information directly from our Customers. We will collect:

• Name and family name
• Company information (address, VAT number, bank account number)
• Email address
• Password
• Credit card information

When a Customer sends us an email asking a question, or signs up to our email newsletters, we will collect the Information that the Customer submits to us. We will also collect other Information that Customers choose to provide to us.

2.2 When a Customer uses the Customer Portal (as defined in the Drawy Terms and Conditions),we collect:

• Name and family name
• Company information (address, VAT number, bank account number)
• Email address
• Password
• Credit card information

3.1 We use Customer Information for the following purposes:

3.1.1 Providing our Service.

3.1.2 Communicating with you or others.

3.1.3 Marketing and advertising.

4.1 We may disclose Customer Information as follows:

4.1.1 Drawy affiliates. We may disclose Customer Information to any current or future affiliates, parent companies, or subsidiaries.

4.1.2 Our service providers. We may disclose Customer Information to Stripe for only payments.

4.1.3 Customers. We may disclose Customer Information to other Customers. For example, when buying a design in the marketplace.

5.1 Customers may verify, correct, or update the Information they have provided us with by updating the Information in their account, or by emailing us at info@drawy.eu. Customers may also request the deactivation of their account by emailing us at info@drawy.eu.

5.2 We may send periodic promotional or informational emails to Customers who have opted in to receive these. Customers may at any moment opt out of such communications by following the optout instructions contained in the email. Please note that it may take up to 3 business days for us to process opt-out requests. If Customers opt out of receiving emails about recommendations or other information we think may interest them, we may still send them emails about their account or any Services they have requested or received from us.

6.1 We collect User the following Information directly from Users:

• Name and family name
• Company information (address, VAT number, bank account number)
• Email address
• Password
• Credit card information

6.2 We also collect User Information automatically through a User’s use of or interaction with our Services and this by means of tracking technologies which allow to individualize a User. This Information may include, without limitation, information about a User’s operating system, the webpages or our Website accessed by Users, the link that led a User to a Customers’ website, the dates and times a User accesses webpages and content of the Website, event information (e.g., system crashes),and general location information (e.g., city and state). We also collect User IP addresses.

6.3 For more information about how we use cookies and other technologies, please refer to our Cookie Policy

7.1 We use User Information for the following purposes:

7.1.1 Providing our Services. To provide our Services to Users and our Customers, including but not limited to our Service consisting of proving date and time of access to Website content by Users.

8.1 We may disclose User Information as follows:

8.1.1 Drawy affiliates. We may disclose User Information to any current or future affiliates, parent companies, or subsidiaries.

8.1.2 To our service providers. We may disclose User Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection) on our behalf.

8.1.3 Unaffiliated third parties. We may disclose User Information to other unaffiliated third parties.

8.1.4 Customers. We may disclose User Information to Customers for purposes of Service delivery as described in our agreement.

9.1 We collect Visitor Information directly from you or from third parties who collect Visitor Information. We may combine all of the Information we collect from various sources.

9.2 Information we collect directly from you. We may collect Visitor Information directly from you. For example, when you send us an email asking a question, or submit a form on our Website to receive marketing materials or email newsletters, we will collect the Information that you submit to us.

9.3 Information we collect from third parties. We may collect Visitor Information about you from third parties that collect information automatically through your use of the Site, such as web analytics companies. Such information may include, without limitation, information about your operating system, settings and system configurations, device model, device ID and other unique device identifiers, mobile related information, the webpages you access within our Website, the website that led you to our Website, the website to which you go after leaving our Website, the dates and times you access our Website, event information (e.g., system crashes) and web log data. These third parties may also collect your IP address however we do not collect these IP addresses.

9.4 For more information about how we use cookies and other technologies, please refer to our Cookie Policy

10.1 We use your Visitor Information for the following purposes:

10.1.1 Providing our Service. To provide and manage our Website and Services.

10.1.2 Communicating with you or others. To communicate with you, including via email, about our Services; to respond to your inquiries or complaints.

10.1.3 Marketing and advertising.

10.1.4 Analyzing use of our Services.

11.1 We may disclose Visitor Information as follows:

11.1.1 Drawy affiliates. We may disclose Visitor Information to any current or future affiliates, parent companies, or subsidiaries.

11.1.2 Drawy service providers. We may disclose Visitor Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.

12.1 The Information we collect from Customers, Users and Visitors are used for the purposes as respectively set forth in the sections above, as well as for the following purposes:

12.1.1 Analyzing use of our Services. To better understand how Customers, Users, Visitors access and use our Website and Services, both on an aggregated and individualized basis, to respond to Customers’, Users’, and Visitors’ desires and preferences, and for other research, analytical, and statistical purposes.

12.1.2 Legal compliance. To comply with applicable legal obligations, including requests from law enforcement or other governmental entities.

12.1.3 Protecting our rights and interests. To protect our rights and interests and the rights and interests of our Customers, Users, Visitors, and the general public, as well as to enforce this Privacy Policy and our Terms and Conditions.

13.1 When we disclose your Information with third parties, we require such recipients to agree to only use the Information we share with them in accordance with this Privacy Policy and for no other purpose than those determined by us in line with this Privacy Policy.

13.2 In addition to the disclosures detailed above, we may also disclose Information for the following purposes:

13.2.1 Business transfers. We reserve the right to disclose and/or transfer Information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer.

13.2.2 Legal compliance. We may disclose Information in order to comply with the law, regulation, a judicial proceeding, subpoena, court order, or other legal process.

13.2.3 Protecting rights and interests. We may disclose Information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved.

13.2.4 Aggregate and de-identified Information. We may disclose aggregate or de-identified information about users for marketing, advertising, research, or other purposes.

14.1 For more information about how we use cookies and other tracking mechanisms on our Website and when providing our Services, please refer to our Cookie Policy.

15.1 Our Website and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information security nor privacy practices of such third-party websites.

16.1 We value the security of your Information, including but not limited to the Personal data collected via the Website or Services. We have taken steps to help protect the Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction and any other form of unauthorized processing. Please be aware, however, that no data security measures can guarantee 100% security. We also refer to our security provisions as set out in the Terms and Conditions.

17.1 We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Personal data as the country in which you reside

17.2 By providing Information, including Personal data, under this Privacy Policy, you expressly consent to the use of such Information in accordance with this Privacy Policy and to the transfer of your Information to another country (including e.g., the United States).

18.1 If you have questions about the privacy aspects of our Website or Services, please contact us at: info@drawy.eu

19.1 We may change this Privacy Policy from time to time, so please be sure to periodically check the latest version of the Privacy Policy. We will post any changes to this Privacy Policy on our Website.