Effective date: 23rd of October 2017

1. Introduction

1.1 Daiokan SA having a principal place of business at 117 rue saint denis, 1190 Forest, Belgium (hereinafter, referred to as the “Company”, “we”, or “us”) collects from the individual contributor (hereinafter, referred to as “you” or “your”) certain personal data through the website (hereinafter, referred to as the “Website”).

1.2 The Website is an online platform allowing photographers to contribute to the Website and, in exchange, receive royalties.

1.3 This Privacy Policy contains Company’s policies and procedures governing the processing of personal data through the Website. The term “processing” includes collecting, storing, deleting, using, and disclosing your personal data.

1.4 The Website is not intended to be used by persons under the age of 18.

2. Your consent

2.1 Before collecting your personal information, we shall seek for your express consent to this Privacy Policy. By providing such a consent, you are consenting to our processing of your personal data as set forth in this Privacy Policy.

2.2 If a person under the age of 18 provides us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact the Company and request us to destroy or de-identify such personal data. The contact details of the Company are specified in Section 13 of this Privacy Policy.

2.3 The Website uses Google Maps API(s). By using the Website, you agree that Google Privacy Policy available at will apply to your use of Google Maps API(s).

3. Personal data collected by the Company

3.1 The Company complies with data minimization principles. We collect and process only minimal amount of information that is necessary for performing the operations requested by you. The Company does not attempt to collect any personal data from you that is not strictly necessary for performing the requested operations.

3.2 The Website allows you to register a contributor’s account on the Website and upload the photos captured by you. When you register a contributor’s account on the Website and upload your photos onto the Website, the Company collects the following personal data from you:

  • your full name;
  • your email address;
  • your date of birth;
  • your gender;
  • your physical address;
  • your login credential (i.e., a username and a password);
  • your phone number;
  • your portrait photo;
  • your short biography; and
  • any other information that you may decide to provide us.

3.3 If you sign up for our newsletter, the Company will collect your email address.

3.4 When you visit the Website, the Company collects your IP address.

3.5 If you use your social media accounts (i.e., Facebook or Google) to log in or sign up to the Website, your chosen social media provider may supply us with the following personal data: (i) date of birth; (ii) email address; (iii) gender; (iv) a list of contacts; (v) location; (vi) your name; (vii) a profile picture; (viii) a user ID; (ix) username; and (x) access token. We will add the personal data collected pursuant to this Section 3.5 in our database in order to register your contributor’s account.

3.6 When you make payments through the Website, your payments will be processed by one of our third party payment processors (hereinafter, referred to as the “Third Party Payment Processors”), such as PayPal (Europe) S.à r.l. et Cie, S.C.A. having an address at 22-24 Boulevard Royal, L-2449 Luxembourg ( The Third Party Payment Processors may collect payment information from you, which is necessary to make the payments requested by you. Please note that we do not store your credit/debit card information. The Third Party Payment Processors handle all the steps in the payment process on their systems, including data collection and data processing.

3.7 The Company does not collect or process any sensitive data about you (e.g., your health information, opinion about your religious and political beliefs, racial origins and membership of a professional or trade association).

4. The purpose of collection of your personal data

4.1 The Company respects data protection principles and uses the personal data only for the purposes for which such data was provided.

4.2 The personal data collected through the Website is used only for:

  • providing you with the services requested by you (e.g., storing the photos captured by you and making them accessible to Company’s customers);
  • verifying your contact details;
  • administering your contributor’s account;
  • communicating with you with regard to the use of the Website;
  • customizing the Website’s content based on your location;
  • providing you with advertisements of products and services which may be of interest to you;
  • sending you notifications about updates of the Website; and
  • audit and security purposes.

4.3 If we obtain your prior consent, we will send you information about promotions and/or events that may be of interest to you, our newsletter, and other marketing material. For information on how to opt-out from such marketing communication, please check Section 8.3 of this Privacy Policy.

4.4 In case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.

5. Non-personal data collected by us

5.1 The Company may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from the Website.

5.2 The Company collects the non-personal data mentioned in Section 5.1 in order to analyze what kind of users visit the Website, how they find it, how long they stay, from which other websites they come to the Website, what pages they look at, to which other websites they go from the Website.

6. Protection of your personal data

6.1 The Company employs information security tools to protect personal data collected and processed through the Website. Such information security tools include, but are not limited to, organizational measures, anonymization, secured networks, and encryption.

6.2 However, please note that, due to the inherent risks of using the Internet, we cannot be liable for any destruction, loss, leakage, and falsification of personal data caused by circumstances beyond our reasonable control.

6.3 We will put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data.

6.4 You are solely responsible for (i) keeping your login details in a private and secure manner and (ii) deploying a secure connection for using the Website and communicating with us.

7. Third party access to your personal data

7.1 Third party service providers that cooperate with us, such as software developers, hosting, website and storing providers, customer support and marketing partners, may have access to your personal data for the purposes of legitimate service provision. Some of our third party service providers are identified in this Section 7. Please note that such third party service providers perform services on behalf of the Company and they may be located outside Belgium and the EU. The Company will assure any third parties performing services on behalf of the Company can assure an adequate level of protection of personal data that is consistent with this Privacy Policy.

7.2 The personal data provided by you for signing up for our newsletter will be used by SendGrid, which is a trading name of SendGrid Inc. having a principal place of business at 1801 California Street, Suite 500 Denver, CO 80202, the US, to provide you with the requested newsletter. By signing up for our newsletter, you consent to the transfer of your personal data outside the European Union. If you would like to read SendGrid’s privacy policy, please visit

7.3 Hosting services for the Website are provided by Daiokan N.V.having its principal place of business at If you would like to read Daiokan  N.V.’s privacy policy, please visit

7.4 Image printing services are provided by Kite Business Service having a registered office at Lower Floor, 27-28 Eastcastle Street, London W1W 8DH, the UK. If you would like to read Kite Business Service’s privacy policy, please visit

7.5 Please note that your personal data may be visible and accessible to other users of the Website, including Company’s customers. Please be sensible in disclosing any personal or sensitive data about yourself.

7.6 The Company will respond to lawful requests from public authorities to disclose information about the users of the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

7.7 With the exception of the cases mentioned in Section 7 of this Privacy Policy, the Company does not disclose your personal data to third parties.

7.8 The Company does not sell your personal information to third parties, and does not intend to do so in the future.

8. Accessing, correcting, and deleting your personal data

8.1 The Company takes reasonable steps to ensure that the personal data collected and processed by the Company is accurate, complete, and up-to-date. Thus, we ask you to keep your personal data as current as possible and update your personal data on the Website through your contributor’s account if necessary.

8.2 If you would like to access, modify, or delete your personal data that is processed through the Website, please send a request to the following email address: [email protected] or edit your personal data and privacy preferences through your contributor’s account. The Company will answer your request as soon as possible but no later than within two weeks.

8.3 Op-out from marketing communication. If you would like to opt-out from our newsletter or any other marketing communication, you can do so by (i) clicking on the “unsubscribe” link contained in any of the newsletters and other marketing materials submitted to you by us or (ii) contacting us at [email protected] We will answer your request as soon as possible but no later than within two weeks.

9. Retention period

9.1 Your personal data will be kept for as long as is necessary to provide you with the requested service. For instance, if your personal data is collected to deliver the newsletter, your personal data will be kept until you unsubscribe from the newsletter service.

9.2 When your personal data is no longer necessary to deliver the requested service or you delete your contributor’s account, the Company will remove your personal data from its database as soon as possible.

10. Third party links and social media widgets

10.1 The Website may contain links to other websites. The Company is not responsible for the privacy practices of those websites. Please read carefully the applicable privacy policies before using any of the websites operated by third parties.

10.2 The Website may contain features enabled by third-party social media providers (e.g., the “share” functionality). Such features may collect your IP address and other personal data in accordance with the privacy policies of the third party social media providers. Please read carefully the applicable privacy policy before using any of such features.

11. Cookies

11.1 About cookies. The Website uses cookies. A cookie is a small computer file. It typically consists of letters and numbers. When you visit a website, the website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer system. The main purpose of cookies is to allow a website to recognize user’s device. There are two types of cookies, namely, (i) persistent cookies, which remain valid until their expiration date, unless deleted by the user before that date and (ii) session cookies, which will be stored on a web browser and will remain valid until the moment when the browser is closed. Cookies do not typically contain personal data. However, personal data stored by us may be linked to the information stored in and obtained from cookies. Web servers can use cookies to: (1) identify and track users while they navigate through different pages on a website; and (2) identify users returning to a website.

11.2 What cookies do we use? The Company uses both session and persistent cookies. The Company uses session cookies, such as “loginmemory”,… in order to verify your details until you are navigating from page to page on the Website. The session cookies enable you to avoid re-entering your details each time you enter a new page on the Website. The Company also uses persistent cookies, such as “loginmemory”, in order to recognize you as a unique user when you return to the Website. As a result, you do not have to enter your login details multiple times as you move from other websites to the Website. The company will not use cookies for purposes, which are not mentioned in this Privacy Policy.

11.3 Google Analytics. The Company uses Google Analytics to analyze your use of the Website. Google Analytics generates statistical and other information about the Website by means of cookies. The information generated by Google Analytics in relation to the Website is used to create reports about the use of the Website. We use the following Google Analytics advertising features: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google Analytics Demographics and Interest Reporting; and (iv) Integrated services that require Google Analytics to collect data via advertising cookies and identifiers. If you would like to opt out from Google Analytics advertising features, you can do so through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI’s consumer opt-out). You can also install a Google Analytics opt-out browser add-on available at

11.4 By using the Website, you agree to our use of cookies as described in this Privacy Policy. If you do not agree to our use of cookies, you need to either (i) discontinue your use of the Website or (ii) set your browser to refuse cookies. Please be aware that some parts of the Website may not function properly without cookies. If you would like to set your browser to refuse cookies, check your browser’s help information.


12.1 The Website provides you with a possibility to submit comments (hereinafter, referred to as the “Comments”). You agree not to submit any Comments on the Website that violate the applicable privacy and other laws.

12.2 We shall not be liable for any direct or indirect damages caused by your publication of unlawful content.

12.3 Please beware that any Comments submitted by you to us may become public. Please keep this in mind before submitting any Comments to us.

13. Contact details & complaints

13.1 If you have any questions or concerns about this Privacy Policy, please contact the Company by email at [email protected] or please write to the following address:

  • Company: Daiokan SA
  • Address: 117 rue saint Denis, 1190 Forest, Belgium
  • Phone number: +32474907047

13.2 You have the right to submit a complaint about the way in which your privacy has been handled by using the contact details indicated in Section 13.1 of this Privacy Policy. After you submit such a complaint, we will send you an email within 5 business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but no later than two weeks. If you are based in the EU and you are not satisfied with the outcome of the complaint, you have the right to launch a complaint with your local data protection authority.

14. Amendment of the Privacy Policy

14.1 We reserve the right to amend this Privacy Policy from time to time by posting an amended version on the Website and seeking for your explicit consent to the changes of the Privacy Policy. Your continued use of the Website after providing such consent will constitute your acknowledgment of the amendments and you will abide and be bound by the amended Privacy Policy.

15. Last amendment

15.1 This Privacy Policy has been last amended on 23rd of October 2017.