Version: 0.91

Last updated: July 19, 2023

This Privacy Policy describes how we collect and process the users’ data through the https://rs.photon-agency.com website operated by Photon Agency LLC. (“Platform”, “Website”). The terms “we”, “us”, “our” refer to PHOTON AGENCY., a legal person registered under the laws of Ukraine.

This Privacy Policy is an integral part of the Terms of Use of the Website. The terms used herein have the same meaning as in the Terms of Use of the Website.

We are committed to safeguarding the privacy of our users. We are not going to misuse your data.

Controller details: 


Contact e-mail address: contact@rs.photon-agency.com

Table of contents

  • Information we collect from you
  • Legal basis for processing
  • Third-party access to information
  • Your rights
  • Security of information
  • Changes to the Privacy Policy

Information we collect from you

Account and profile set-up

If you want to use the Website’s functionality, you will have to create a personal account on the Website (“Account”). 

If you register as a customer, you will have to provide your e-mail address. Your password will be automatically generated and sent to you by e-mail. After the registration on the Platform, you may addend other Account details, such as your name, profile picture, preferred currency, etc.

In case you create a vendor’s Account, we will ask you to provide your e-mail address, first name, last name, shop name, shop URL, and phone number at the time of registering your Account. The password will be sent to your e-mail address.

We will assign a username to your Account. You will be able to sign in to your Account with the help of either your username or e-mail used for Account registration. From your Account dashboard, you will be able to view your orders, manage addresses, edit Account details, etc.

For payments, you will be prompted to a third-party payment processing provider, who will store and process your payment information. We will only receive information about payment confirmation from that provider.

We use your Account information to:

  • create and maintain your user Account, including in connection with other data points listed below;
  • contact you regarding the work of the Platform or your Account;
  • analyse the efficiency of our Website in our legitimate interests;
  • upon receiving the consent from you, to send you marketing or promotional materials.

We will store your Account data, including the categories from the Website functionality section, for as long as you have the Account with us and for 90 days after you delete your Account. If you become inactive, we will delete or anonymize your information 2 years after your last user session.


Website, sales, and marketing activities

The following data collection activities are carried out on our Website:

  • collection of visitor logs (device, browser information, IP address) to ensure fraud prevention and manage user sessions, stored for 6 months of your last visit;
  • visitor traffic analysis done using third-party analytics providers;
  • cookies – for more information please visit our Cookie Notice;
  • provision of a newsletter, which you may obtain by providing your e-mail address. 

We store marketing data for 12 months of the last communication with you. For the activities that are based on consent, you can withdraw your consent at any time by contacting us directly. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out of the e-mail subscription by clicking the appropriate button in our e-mails to you.

Reviews

We may use your personal data, such as name and e-mail, to post your reviews of AI Products presented on the Website. By creating an Account on the Website and providing us with a review of that kind, you agree to such use of your personal data. 

We will display the review for so long as it is necessary for promotional and marketing purposes. However, you are free to contact us at any time (at contact@rs.photon-agency.com) to withdraw your consent from using your review. We will delete your review as soon as practicable after we receive your request.

Legal basis for processing (for users from the EU/EEA)

Performance of contract

We process your Account data and log information to provide you with our services. Without this information, we will be unable to provide you with the Website functionality as the condition tracking and interpretation strongly depends on the user indicators.

Your consent

We use your consent as a legal basis for the processing for the following purposes:

  • sending e-mails with our newsletters, announcements, and other offers (marketing e-mails);
  • collecting certain types of cookies on the Website.

You can withdraw your consent at any time by contacting us directly. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out from the e-mail subscription by clicking the appropriate button in our e-mails to you.

Legitimate interests

For improving our Website, helping you with your support requests, and conducting our marketing analysis, we process statistics of your activity and your requests for support. We can also send you occasional e-mails with our updates or new AI Products, and other e-mails for the information purpose.

We may also store certain information, such as information about your payments, to comply with legal obligations in our jurisdiction. As this activity is governed by the non-EU laws, the applicable legal basis is our legitimate interests.

You can opt-out of e-mail subscription by clicking the appropriate button in our e-mails to you.

Third-party access to information

Analytics, cloud storage, and CRM

To analyze our efficiency and conduct marketing research, we use (or will use in the near future) the services of analytics providers and client relationships and content management software.

As for the storage, your information is being stored using the services of cloud providers, who ensures the secure storage of the data in accordance with the industry standards.

When using the analytics services, we collect details of the use of the Website, including, but not limited to, traffic data, location data, length visit, and other communication data.

Non-personally identifiable information is collected and processed, among other services, by Google Analytics in an anonymized and aggregated way to improve our Website’s usability and for marketing purposes. Google Analytics is a web analytics service that tracks and reports user traffic on apps and websites. Google Analytics uses the data collected to track and monitor the use of the Website. This data may also be shared with other Google services. For more information on the privacy practices of Google, you can check its Policies at www.google.com/analytics/policies/.

Payment providers

To process payments that you make for purchasing AI Products on the Platform, we use third-party payments processors. Please note that we do not receive your payment details from them, but only payment confirmations and details of the transactions you perform. This means that we do not collect nor process your payment information. Payment processors are independent controllers over your payment information which includes your payment card data.

To learn more about how those third-party payment processors process your payment details, please visit their websites or contact them directly.

Integrated plug-ins

The Website allows the connection of third-party software providers via an API. Please note that whenever you interact with those third-party providers, you provide your information directly to them.

Other disclosures

In addition to the disclosures for the purposes identified before, we may disclose information about you:

  • to our affiliated companies;
  • to our contractors, service providers, and other third parties that we contract with to support our business, and who are bound by contractual obligations to keep personal data confidential and to use it only for the business purposes for which we disclose it to them;
  • if we are required to do so by law, in connection with any legal proceedings or to establish, exercise or defend our legal rights; and
  • in case we sell, license or otherwise assign our company, corporate rights, the Platform or its separate parts or features to third parties.

We will disclose your personal data for the purposes stated afore only to those third parties which provide the same or equal protection of user data as stipulated in this Privacy Policy.

Except as provided in this Privacy Policy, we will not sell, share or rent your information to the third parties.

Your rights

To control our data protection activities, you may exercise certain rights regarding your information. In particular, you have the right to:

  • Access your information. You have the right to know if we process your information; obtain disclosure regarding certain aspects of the processing; and obtain a copy of the information undergoing processing;
  • Object against the processing of your information. If we process your information in our legitimate interests, e.g., for direct marketing e-mails or for our marketing research purposes, you can object against it. We will consider your request and, if there are no compelling interests to refuse it, stop the processing for such purposes;
  • Verify your information and seek its rectification. If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected;
  • Restrict the processing of your information. When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will not process the information for any purpose other than storing it until the circumstances of restriction cease to exist;
  • Withdraw your consent to the processing of your personal information if such processing is based on consent (this will not affect our right to process your personal data up until such time as you provide us with notice that you no longer consent);
  • Ask us to delete/destroy/otherwise remove your information. If we are not obliged to keep the data for legal compliance, we will remove your information upon your request; and
  • Ask us to transfer your information to another organization if we process the information based on your consent or on the necessity to perform the contract.


If you believe that our use of personal information violates your rights, you can lodge a complaint with the competent data protection authority.

Security of information

We will take all necessary measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. As we have employees across several countries outside of the European Union, we may transfer the collected data to those countries for further processing. In such cases, we will make sure that relevant safeguards are in place.

Immediate access to the data is only allowed to our authorized employees involved in maintaining the Website. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.

In the event that we become aware of any accidental or unauthorized access to your information, we will notify you of such data breach by sending an e-mail in accordance with applicable laws.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time by posting a new version on our Website. We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavor to provide you with an announcement about any significant changes.