1.1. Welcome to Photagon, a Platform as a Service (PaaS) owned and operated by Photagon LTD (hereinafter ‘Photagon’ or ‘We’), a company specialized in On-line photo contests and processing that offers both free and paid services, accessible through the internet as Platform as a Service (hereinafter the ‘Photagon Platform’ or «Service»).

1.2. This is our Privacy Policy. It’s very important for us to keep you informed on how we handle and keep your data safe. This policy will give you information on:

• What types of personal data we collect;
• How we collect your personal data;
• Why we collect your personal data;
• How long do we keep your data;
• Your privacy rights;

2. What Types of Personal Information We Collect

The data we collect depends on the features and services you sign up for

2.1. Upon registration:

• Username: To know who you are and connect you with your peers and audience)
• Password. So that you enter safely in your account.
• Email (not published). To verify your account, to send you important emails about transactions, to contact you for commercial opportunities.
• Date of birth (must be over 18 or provide parental consent (?). Only adults are permitted in photagon due to the paid services of the platform.
• Country, because every user activity supports a national NGO with the photagon activity. Country is mandatory info)

2.2. While you use our services:

• Your PCoins history: It is necessary in order to keep track of your transaction history. Your Rankings: To provide you a track on how you are doing.
• Your comments: To provide a full communication history. You may delete your comments at all times by simply clicking the delete button.
• Login history and usage data: Το track the frequency of your participations and take them into consideration while forming the reward point system. To also provide helpful notifications, photagon offers, and personalized tools according to your activity.
• Blocked users: To track the users you block and the reasons for the blocking. This action can be reversed for any blocked user from your account settings
• Research history: to see preferences and provide a personalized experience
• Your photos (uploaded, purchased or added to favorites): To save your gallery library
• Your contest participations and your votes: To have your contest history information for rankings, statistics, analytics.
• Your transactions: To hold all records of your transactions, provide you the history of the transactions.
• Your reports (of photos): To handle your reports, investigate potential issues of copyright or inappropriate behavior in photagon. To inform you about the process of your reports.
• Your messages in our help center: To keep track of potential issues of photagon functions, to provide assistance if you have a problem, to respond to your message, to keep a log of our communication for security reasons.

3. Why we collect your data (Basic bases of processing)

• Following your preferences, to provide you with our services.
• To know you better and provide optimized and customized services for maximum convenience and security;
• Archiving purposes that may facilitate you in future queries;
• For safety and security;
• For communication purposes as allowed by the law. You may opt out at all times;
• To verify and validate your information for maximum data accuracy;
• To distribute the PCoins according to the votes you collect in contests.
• In regard to transaction activity, comments, reported photos, blocked users, log in history, contest history, we process this data in order to secure the `Photagon Platform and optimize our services as follows:
  • To monitor, identify and manage potential inappropriate activities,
  • To configure rankings following the popularity status.
  • To provide rewards or bonus PCoins following usage data like the activity or earnings, regularity of contest participations, recommendations of friends.
  • Especially for the affiliate program: In the event an affiliate promotes photagon then they receive % from the users’ activities for a specific period of time. For this reason the affiliate will know if their users subscribed and entered contests.

4. Our rules for collecting your data

1. We only use the data to provide the Services with respect to your personal data and the applicable regulation.
2. We meet the GDPR requirements and in the country where we provide you with a service via our website or our applications;
3. We fully explain why we need the data and how we’ll use it (unless we have legitimate reason not to);
4. We check and update privacy information on a regular basis (we might also cross-check the data against other database to make sure it’s correct);
5. We do not share data with anyone unless we have a legal or legitimate reason, or we have permission from you or if you are a child under 16 from your parents;
6. We will never sell your data.

4. We may share your data with

• Private credit, bank institutions to manage payments and cash outs.
• Google analytics

5. How long do we keep your data

• Registration data: During the term of registration plus two years in order to retrieve any data upon request or when a relevant legal basis apply.
• Usage data: During the term of registration plus two years

The criteria used to determine our retention periods include:

• As long as you use our Services and hold a Photagon account.
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

In the event you request to delete your data to delete any information concerning you before the set retention periods (when applicable), we may not be able to do so for technical, legal, regulatory or contractual constraints. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any remaining amount of money owed, and to resolve disputes.

We will destroy your personal information as soon as possible and in a non-restorable, non re-identifiable manner.

6. Your Rights over your data

6.1. You have the right to:

1. Access all personal data you provide to us, in printed or in electronic form free of charge;
2. Obtain rectification of any inaccurate or outdated data, or to complete any incomplete data;
3. Receive or ask us to provide you or transmit your data in common format;
4. Delete your personal data, provided we have no legal obligation to do otherwise;
5. Ask for the restriction of any data processing activities;
6. Object to certain types of processing including direct marketing, customer profiling;
7. Submit a complaint your local Data Protection Authority.;

6.2. All rights can be exercised by submitting a written request to via email free of charge (e-mail: info@photagon.com).

6.3. Our designated officer will respond to your request within thirty (30) calendar days.

6.4. We can only identify you via your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our users or customers.

7. Complaints about our behavior

7.1. You have the right to complain if you don’t feel Photagon is living up to our responsibilities when it comes to your data.

7.2. We have an appointed Officer, who takes your complaint very serious. You can contact our appointed Officer on this email info@photagon.com. We will send you a confirmation within 5 days and do our very best to deal with the issue within 30 days. If the issue is difficult or requires a lot of work it may take longer, but we will keep you updated.

7.3. You always have the right to complain to the authorities as well, but because we take privacy matters very seriously, we would really appreciate it, if you would talk to us.  

You can complain about:

1. How your personal data has been processed;
2. How your request for access to data has been handled;
3. How your complaint has been handled;
4. Appeal against any decision made following a complaint.

8. Overseas Transfers of Your Personal Data

Your personal data will be stored on _________,. As the case may be your personal data will be shared with ____________. Your personal data will not be transferred to countries outside the EU.