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We hereby inform you on Our current policies and practices applicable to the processing of your personal data (“Personal Data”) collected by Inmagine Group through the website https://www.123rf.com/ (the "Website").

Essential Information
123RF (https://www.123rf.com/) is one of the websites being operated by the relevant entity within Inmagine Group which comprises of various legal entities throughout the world.

Inmagine Lab Pte. Ltd. acting as data controller for the processing of your Personal Data will depend on how you interact with the Website where you are located and on the entity that have a relationship with you, as the case may be. The relevant Inmagine Group entities are referred to as "Inmagine Group", "Our", "We" or "Us" in this Privacy Policy.

For any general queries you may contact Us at: info@123rf.com or by postal mail at 30, Cecil Street, #19-08 Prudential Tower, Singapore 049712.

You may get in touch with Our designated Data Protection Officer at dpo@123rf.com.

What does this Privacy Policy cover?
This Privacy Policy generally describes, inter alia, the Personal Data We may collect from you, the processing of such Personal Data and your rights in relation thereto.

Information We may collect from you
The term Personal Data refers to the data you provide to Us through the Website and may vary depending on the type of relationship you have with Us. Personal Data include:

Browsing data
The information systems and software procedures used to operate the Website acquire personal data as part of their standard functioning. The transmission of such data is an inherent feature of Internet communication protocols. This data category includes, among other things, the IP addresses and/or the domain names of the computers and terminal equipment used by any user, the location of the devices, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.) and other parameters related to the users'' operating system and computer environment.

Registration profile
If you decide to create an account on the Website, you may be required to provide Us your Personal Data such as name, username, e-mail address, and billing address with the submission of the registration form. You may also include additional Personal Data such as surname, address, telephone number and date of birth.

If you decide to create an account through your existing profile in a social network (e.g., Facebook), you may be required to share Personal Data such as information of your public profile, (including name, surname and image) and e-mail address.

Financial information and billing details
If you purchase or subscribe any of Our products and/or services, you will also be required to provide Us Personal Data related to payments and billing, including name, surname, address, zip code, telephone number, e-mail address, billing address, as well as credit card details, or Paypal account or bank details. We do not store credit card details or PayPal account or bank details. Upon the completion of the purchase or subscribe of Our products and/or services, We collect transaction details from the payment gateway provider only.

Details under the "Contact Us" section
When you contact Us through the Website, you may be required to provide Us your Personal Data such as name, e-mail address and, at your own discretion, other information you decide to share with Us, that We may collect from you.

If you submit information about you via the career section on the Website or apply for a position, We will collect and process the information which you have submitted for considering your application and all other recruitment purposes.

We use cookies and similar technologies or tools to collect information about your activities on the Website, including to use social media features or services on the Website which may enable you to connect with Our social media page or share any promotional activities with your friends and social networks. Detailed information on the cookies We use and the purpose for which We use them are set out in Our Cookie Policy.

How do We use your information and why?
Your Personal Data will be collected and processed for the following purposes:

Categories of data: Purposes of processing Legal basis:
Browsing data To extract statistical information on service usage (most visited pages, visitors by time/date, geographical areas of origin, etc.) and to check the functioning of the services. It is Inmagine Group''s legitimate interest to analyse and improve the performance of its services and to prevent crimes and frauds (Art. 6(1)(f) of the GDPR). We will analyse your Personal Data in order to improve Our services and your experience with Our Website (where your consent is not required, Art. 6(1)(a) of the GDPR).
Registration/creation of the profile To process the creation of your account and profile on the Website and to provide or allow you the access certain areas, functions (e.g., processing the contents submitted by you and displaying your contents on the Website) and features of the Website. Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1)(b) of the GDPR).
Biographical data, financial information and billing details To provide you with the products and/or services you purchased or subscribed to, as well as processing transactions and payments in connection therewith. Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1)(b) of the GDPR).
For administrative purposes connected with the performance of the commercial relationship with you or the fulfillment of legal requirements (e.g., accounting or tax requirements) or for complying with any requests from the competent authorities. Compliance with a legal obligation to which We are subject (Art. 6(1)(c) of the GDPR) or, in the event there is no such legal obligation, Our legitimate interest to keep adequate records in connection with the execution of the commercial relationship (Art. 6(1)(f) of the GDPR).
To share the Personal Data with the other Inmagine Group companies within the European Economic Area (EEA) for internal administrative and accounting purposes. It is Inmagine Group''s legitimate interest for transmitting Personal Data within the group for undertaking of internal administrative purposes, including the processing of customers'' Personal Data (Art. 6(1)(f) of the GDPR).
Biographical data and contact details To contact you with information about current or new products, commercial opportunities, promotions and services or events sponsored by Us that may deem of interest to you, as well as to verify customer satisfaction and to carry out market researches, analyses and surveys, and also to allow you to participate to prize contests, rewards, trips and/or receive gifts. Your consent (Art. 6(1)(a) of the GDPR).
To respond to your queries and questions and to provide any information you require (e.g., information and suggestion about products) in the section "Contact Us". It is Inmagine Group''s legitimate interest to provide customer service and respond to your queries (Art. 6(1)(f) of the GDPR).

The submission of your Personal Data is not mandatory. Any refusal to provide the consent will not have any effect other than Our inability to provide you the products and/or services. In such situation, We shall not be liable for any losses, liabilities and damages whatsoever and howsoever arising thereof.
At any time, you have the right to withdraw your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before the withdrawal.

Information We may share and data recipients
Your Personal Data are processed by Our personnel and, if necessary or functional to fulfilling the purposes indicated above, your Personal Data may be processed by third parties that may be appointed by Us as data processors.

The categories of recipients to whom your Personal Data may be disclosed are the following:
  1. third parties such as (i) IT providers; (ii) financial institutions or payment gateway providers in connection with the processing of financial and payment information; (iii) marketing agencies to carry out marketing campaigns, surveys and promotions; (iv) legal, accounting, tax, labour consultants and other professionals; (v) other Inmagine Group companies within the European Economic Area (EEA), and

  2. public entities and authorities, exclusively for the purpose of fulfilling legal and regulatory obligation.

Under certain circumstances, your Personal Data may be transferred outside the European Economic Area (EEA) to other Inmagine Group companies or to third parties data processors. In such cases, We ensure that We have adopted appropriate safeguards, including binding corporate rules or standard data protection clauses adopted by the European Commission, in order to guarantee the data subjects with an adequate level of protection. You may obtain a copy of these appropriate or suitable safeguards when contacting Us at the contact details above.

Retention of your Personal Data
Data are retained as long as necessary for the performance of the services provided on the Website and to comply with legal obligations (including, auditing or taxation purposes), to meet regulatory requirements, resolve disputes, maintain security, and/or to prevent frauds and abuse.

In relation to the Personal Data of your profile, We will retain the same as long as your account with Us is still active. If you choose to close the account or if your account is closed, We will delete your Personal Data and information within thirty (30) days. This is without prejudice to Our right to retain the information (such as username and transaction details) to comply with legal obligations, prevent frauds and protect its legal interest.

We treat the security for all information submitted or provided by you to Us seriously and is of importance to Us. We will take reasonable steps to protect or secure this data, including your Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing, and etc). You are also advised not to disclose and secure your own username and password.

Your Rights
You have the right to obtain from Us confirmation whether your Personal Data are being processed by Us, and, in said circumstances, you have the right to request access to and rectification or erasure of the same or restriction of processing, and to object to the processing at any time, as well as under certain circumstances the right to data portability. With respect to the data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of said data.

With respect to the right to object where the processing is based on Our legitimate interest, you can object to the processing at any time and We will cease processing your Personal Data unless we have a compelling legitimate reason to continue such processing or where the processing is needed for legal reasons. In addition, you can object to the processing of your Personal Data in the circumstance such as where We are processing the Personal Data for direct marketing purposes.

If you have subscribed to or opted-in to receive Our marketing communications you can opt-out at any time, free of charge, requesting that your Personal Data not be used for marketing purposes.

You may exercise any of the above rights by contacting Us at info@123rf.com or by postal mail at 30, Cecil Street, #19-08 Prudential Tower, Singapore 049712.

You have the right to lodge a complaint with a supervisory authority.

Links to Third Party Website(s)
The Website or any products/services being rendered to you may contain links to other websites that are not operated by Us and whose privacy practices may differ from Us. If you click on a third-party link, you may be directed to the third-party website. Any submission of your Personal Data to any of those third-party websites will be governed by the relevant third-parties'' privacy policies. We have no control and shall not assume any responsibilities howsoever arising thereof and We strongly advise you to carefully read the privacy policies prior to the disclosing of any information.

We may, from time to time, partner with a third party to display Our''s or a third party''s advertisement(s) on the Website or engage a third party to manage Our advertising on the Website. For more detailed information, please refer to Our Cookie Policy.

Mobile Applications or Mobile Website
We may provide Our products or services to you via our mobile applications or mobile website that is designed to be used on mobile computing devices (the "Applications"). You may be required to log in to Our mobile applications or mobile website with your username and password in order to allow you to associate with the user account you have created on the Website. The processing of the Personal Data information therein will also be governed in accordance with this Privacy Policy and Our Cookie Policy.

Contact Us
If you: (i) have any questions, queries, inquiries or comments on this Privacy Policy; (ii) have any concerns about how We process your Personal Data; (iii) would like to opt out of direct marketing activities; (iv) would like Us to update information or preferences you have provided to Us; or (v) have any other issues relating to this Privacy Policy, you may also get in touch with Our designated Data Protection Officer at dpo@123rf.com.

Changes to this Privacy Policy
We will keep this Privacy Policy under regular review, and We may update this Privacy Policy from time to time. The updated version shall apply and supersede all previous versions. Hence, it is advisable that you check this Privacy Policy on a regular basis.

This document is prepared in English and may be subsequently translated into other languages. In the event of inconsistency between the English version and the translated version, the English version shall prevail.

Last updated: 13 October 2021