Personal Data Protection Policy

Introduction

EasyMovie, a simplified joint-stock company with a capital of 58,380 euros, registered with the Paris Trade and Companies Register under number 791 945 801, whose head office is located at 92 rue Réaumur, 75002 Paris ("EasyMovie" or "we") provides a video content creation platform that allows customers and users to create and edit videos using an online solution and a mobile application (the "Service").

1. Why do we have a personal data protection policy?

We give great importance to the protection of personal data. This policy is intended to define our commitments to ensure the protection of personal data entrusted to us by customers and users when using the Service. We also comply with the applicable legal provisions defined by Law No. 78-17 of 6 January 1978 and the General Regulations for the Protection of Personal Data.

The registration and use of the Service requires full acceptance of this policy. In the absence of acceptance, the customer and the user will not be allowed to use the Service.

2. Who is responsible for processing personal data?

The data controller for the processing of personal data is the person who determines the means and the purposes of the processing of this data. The data processor is a person who processes personal data on behalf of the data controller. It acts under the authority and on the instructions of the data controller.

The data controller:

• Is the customer, for the personal data collected by the customer and the user when using the Service, and it determines the means and the purposes of the processing of this data. EasyMovie acts as a data processor;

• Is EasyMovie for the personal data collected during the creation of the customer or user account and its use of the Service.

In any case, EasyMovie takes the necessary measures to ensure the protection and the confidentiality of personal data which it holds or that it processes in accordance with the applicable legal provisions, and in particular with the law n° 78-17 of January 6th, 1978 and the general regulations for the protection of personal data

3. What personal data do we collect?

We collect the following personal data from customers and users:

• The data entered or communicated by the customer and the user, namely last and first name, username, image and voice, professional activity, email address, postal address, telephone;

• The automatically recorded data, ie IP addresses and connection logs.

4. What are the purposes of processing this personal data?

The legal basis for the processing of personal data by EasyMovie is as follows: the processing is necessary for the provision of the Service to customers and users in accordance with the contracts between EasyMovie and the customers. It is also carried out with the consent of the customers and users concerned.

In particular, we process the data for the following purposes:

• To enable the creation, compilation, and editing of videos and generally to provide the customer-ordered Service from EasyMovie;

• For billing purposes for the use of the Service;

• For the purposes of monitoring the relationship with customers and users, which includes the provision of advice related to the Service, the provision of customer service but also the sending of newsletters to inform customers and users of changes to the Service or any other information relating to the activity of EasyMovie;

• For purposes of monitoring the use of the Service to suggest improvements to it;

• For commercial prospecting purposes

The data may also be processed for analyzing and improving the Service offered to customers and users, to fight against computer fraud.

5. To whom is personal data transmitted?

No personal data is transmitted to partners for commercial prospection by these partners.

Personal data is transmitted to EasyMovie staff members for the purposes of providing the Service and monitoring the business relationship with customers and users.

Personal data is also transmitted to subsidiaries of EasyMovie as well as third parties, acting as subcontractors, for video editing services as well as for the following processes:

• Secure payment on the website and the mobile application;

• Sending newsletters;

• The sending of commercial prospecting emails;

• The technical maintenance and development of the solution to offer the Service;

• Monitoring the use of the Service

In general, we pay particular attention to the commitments made by our subcontractors regarding the protection of personal data, including the security and confidentiality of the data we entrust to them. We ensure that each subcontractor provides the necessary guarantees for the security and confidentiality of personal data, whether or not it is located in the territory of the European Union.

In particular, we have signed standard contractual clauses with our subsidiary which is located in Tunisia and which provides video editing services. Due to special circumstances, we may disclose the personal data of customers and users to any competent judicial or administrative authority that requests its disclosure in accordance with the applicable legislation.

We may also assign or share all or part of the personal data of customers and users, as part of a merger, acquisition, reorganization, total or partial sale of the assets of the company EasyMovie or in the event of a receivership or liquidation.

6. How are the security and confidentiality of data ensured?

EasyMovie implements appropriate technical and organizational measures to ensure the security, integrity, confidentiality and authenticity of personal data.

In particular, these are technical security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access. Service.

7. How long is personal data kept?

Personal data are only kept for a reasonable and strictly necessary period of time for the fulfillment of the purposes of the processing for which they were collected or which were later authorized by the customers and the users.

Personal data will therefore not be retained for more than 5 years from the end of the business relationship between EasyMovie and the customer concerned, unless specifically requested by the data subjects to remove the data.

8. What are the rights of the people whose data is processed?

Any data subject has the right to request from the data controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability.

Each data subject can send his request to the data controller which is:

• The customer for any data collected and processed by the customer;

• EasyMovie for any data collected and processed by EasyMovie.

To contact EasyMovie, the data subject can send his request in writing to the following address: EasyMovie, 92 rue de Richelieu, 75002 Paris - France or by email at privacy@easy.movie. The data subject must then specify the personal data that he wishes to be corrected, updated or deleted, enclosing a copy of an identity document (identity card or passport) to identify himself. Requests for the deletion of personal data may be assessed by EasyMovie on a case-by-case basis depending on the legal obligations imposed on EasyMovie, particularly as regards the storage or archiving of documents.

Data subjects may also file a complaint with the supervisory authorities, in particular with the French data protection authority (“CNIL”) (https://www.cnil.fr/fr/plaintes).

9. Do the EasyMovie services use cookies?

9.1 EasyMovie Mobile Application

The EasyMovie mobile application to use the Services does not require the use of cookies.

9.2 EasyMovie Platform

- Cookies required in order to perform Services

When using the EasyMovie platform found at the address software.easy.movie, the user is informed that cookies which are necessary for the provision of the Services by EasyMovie are installed on its device.

The cookies are as follows:

• EasyMovie session cookie;

• Amazon Web Services cookie session to balance the load balancer (https://aws.amazon.com/fr/elasticloadbalancing)
   > Cookie name: AWSELB

The user can decide to refuse cookies, at any time, by adjusting browser settings. The user will then be informed that by refusing cookie installation, he cannot use the EasyMovie Services on the platform.

• Audience measurement cookies

Audience measurement cookies to improve user experience on the EasyMovie platform are likely to be used by EasyMovie if the user agrees. These cookies are:

• Persistent audience measurement cookies Google Analytics (https://www.google.com/intl/fr_fr/analytics)
   > Cookie names : _ga, _gat, _gid

• Persistent audience measurement cookies MixPanel (https://mixpanel.com)
   > Cookie names : mp_*_mixpanel

• Persistent audience measurement cookies Google Tag Manager (https://marketingplatform.google.com/about/tag-manager/)
   > Cookie names : gtm_*

• Persistent audience measurement cookies Segment (https://segment.com)
   > Cookie names : ajs_*