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Cookie Policy
This Cookie Policy governsthe use of cookies on the website www.fotoncard.com (hereinafter:
“Website”) of Foton TechnologiesInc. (hereinafter: “Foton Technologies”, “we”, “us”, “our”).
A cookie is a small text file that the Website saves on your computer or mobile device when you visit
the Website and which contains certain information and sometimes personal data. It enablesthe
Website to remember your actions and preferences(such aslogin, language, fontsize and other
display preferences) over a period of time,so you don’t have to keep re-entering them whenever you
come back to the Website or browse from one page to another.
Social media plugins are small pieces ofsoftware developed and provided by Social Media Service
providers(e.g. Facebook, LinkedIn, Google, YouTube, Pinterest, Instagram and Twitter), which add
social media integration when built into the Website.
Pixels are also small pieces ofsoftware developed and provided by advertisers and Social Media
Service providers, which are integrated into the Website in order to provide you with more relevant
advertisements, tailored to your interests.
NOTE : If you want general information on how we process your personal data other than the
processing through cookies,social media plug-ins and pixels, including in relation to your
communication with us via e-mail, telephone, fax and social media and in relation to your registration
on our Website, please refer to our Privacy Policy.
By continuing to use the Website after having been informed of the use of cookies,social media
plugins and pixels, you acknowledge that you have read this Cookie Policy carefully and that you
agree with it without reservation. You may, however, at all times change your cookie preferences
through the cookie settings.
In General
1. Your personal data are processed by Foton Technologies.
This is the entity responsible for the processing of your personal data as covered in this
Cookie Policy.
2. Any notion starting with a capital shall be defined by explicit reference in this Cookie Policy.
Where possible given the context, singular words shall be interpreted as also including the
plural and vice versa.
To make sure we have the same understanding of what is written here, it is important that
certain notions are interpreted in the same way by you and by us.
3. Where reference is made to certain laws or regulations, such reference shall also include any
change, replacement or annulment of said laws or regulations, including any related
executive decisions.
Laws tend to change from time to time, and we want to make sure that this Cookie Policy
remainsin line with any such changes.
4. Foton Technologies reserves the right to modify, change or amend this Cookie Policy at its
own discretion and from time to time. Such modification, change or amendment shall be
communicated via the Website. If you do not accept the modifications, changes or
amendments, you are to inform us by sending an e-mail to support@fotoncard.com. If we
do not receive such an e-mail from you within three (3) business days after the changes to
the Cookie Policy have been announced in a visible manner on our Website, you will be
deemed to have unambiguously accepted allsuch changes.
As any company, changes in laws, market circumstances, interests etc. may require us to
change our Cookie Policy from time to time to ensure that it remains accurate. If this
happens, you are kindly asked to take note of the changes and to agree with them if you find
them acceptable.
Cookies
1. You can control and/ or delete cookies being placed by configuring your browser as such. For
more details, see aboutcookies.org. You can delete all cookies that are already on your
computer and you can set most browsers to prevent them from being placed. If you do this,
however, you may have to manually adjust some preferences every time you visit a site and
some services and functionalities may not work or stop working properly. To learn how to
opt out of behavioral advertising delivered by Network Advertising Initiative member
companies, please visit the Network Advertising Initative and Digital Advertising Alliance. You
may download the AppChoices app to opt out in mobile apps. If you opt out from interestbased advertising, you may see advertising that is not relevant to you. At present, there is no
industry standard for recognizing Do Not Track browser signals, so we do not respond to
them.
2. When you visit the Website, Foton Technologies places a number of cookies. Most data
pertaining to these cookies, their placement and use allow to identify you, and Foton
Technologies uses them to gain insight in how you and other visitors use the Website by
gathering statistical and usage data, enabling Foton Technologies to provide a better user
experience on the Website.
With this provision, Foton Technologies aims to appropriately inform you of the cookies that
are placed on your device when visiting and using the Website.
3. Foton Technologies knows about the following most important cookies being used on the
Website:
1. Functional cookies
Foton Technologies uses several functional cookies on its Website. These cookies
are needed for the Website to work properly and to give you a good user
experience. An example isthe cookie used to remember your language setting.
1. JSESSIONID: Foton Technologies places this Cookie to maintain an
anonymized usersession by our website server.
2. Secret: Foton Technologies places this Cookie to validate connection and
block CSRF attacks
2. Analytical and statistical cookies
Some cookies gather information meant to give Foton Technologies insight
(typically through statistics) in how the Website is used by users, what features are
popular, which are not and so on. This information can be used to make the
Website betterso asto give you a better user experience.
1. Google Analytics: The cookies placed by Google are the “_ga”- (2-year
lifespan), as well as the “_gid”/“_gat”-cookie (1-day lifespan). It enables
Foton Technologies to learn information about our users’ use of the
Website, such as the time of visit, the pages viewed, whether the user has
visited the Website before, and the website visited prior to visiting the
Website. For further information please see:
https://developers.google.com/analytics/devguides/collection/analyticsjs/
cookie-usage?csw=1
2. HotJar: the cookies placed by HotJar
(https://www.hotjar.com/legal/policies/cookie-information). It enables
Foton Technologies to learn the information about our users use of the
website
Purposes For Which Foton Technologies Uses Your Personal Data
1. Foton Technologies processes your personal data to perform statistical analyses so that we
may improve our Website, products and services or develop new products and services.
2. Foton Technologies processes your personal data to provide you in a personalized and
efficient way with the products and services, via the Website.
3. Foton Technologies processes your personal data for marketing purposes, i.e. to provide you
with targeted communications, promotions, offerings and other advertisements of Foton
Technologiesregarding our products and services.
4. Foton Technologies may process your personal data for informing any third party in the
context of a possible merger with, acquisition from/by or demerger by that third party, even
if that third party islocated outside the EU.
5. Foton Technologies may process your personal data for the preservation of the legitimate
interests of Foton Technologies, its partners or a third party if and when your registration
with, or use of, the Website can be considered (a) a violation of any applicable terms of use
or the intellectual property rights or any other right of a third party, (b) a threat to the
security or integrity of the Website, (c) a danger to the Website or any of Foton
Technologies’ or its subcontractors’ underlying systems due to viruses, Trojan horses,
spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene,
discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or
illegal.
Here we reserve the right to process your personal data if you use our Website in any way
that may harm Foton Technologies orsomeone else or isillegal.
Legal Basis For Processing Your Personal Data
 For processing your personal data under the conditions outlined in this Cookie Policy, but
with the exception of functional cookies, Foton Technologies as the responsible party asks
for your consent. The law requires us to state precisely which legal basis we use to process
your personal data, considering the purposes we have listed in the previous article. The main
legal basis for the processing covered in this Cookie Policy is your consent. Foton
Technologies obtains your consent through the cookie banner. By clicking on this banner
affirmatively and continuing to use any of the Website you acknowledge that you have read
this Cookie Policy carefully and that you agree with it without reservation.
Recipients
1. We do notshare your personal data with third partiesin a way that those parties can identify
you directly unless you consent to it or unless we have anonymized your personal data. You
understand however that when you use Facebook for instance to communicate, Facebook
also processes your personal data.
Foton Technologies may share personal data with third party business partners when this is
necessary to provide our services to you. Other than this, we do not send your personal data
in a directly identifiable manner to any third party without your explicit permission to do so.
You understand, however, that our use of analytical and statistical as well as social media
cookies may imply that the third party providers of those cookies may obtain certain
information about you, including about yoursurfing behavior. You can find more information
in the respective policies of those providers.
2. Our Website may be developed, maintained or hosted by third parties. Similarly, we rely on
the services of third partiessuch as cloud providersto process your personal data internally.
Foton Technologies relies on third party processors to provide you the Website as well as to
process your personal data on our behalf. These third party processors are only allowed to
process your personal data on behalf of Foton Technologies upon explicit written instruction
of us. Foton Technologies warrants that all third party processors are selected with due care
and are obliged to observe the safety and integrity of your personal data.
Quality Assurances
1. We will not process more personal data about you than we need for the purposes we have
communicated to you.
Foton Technologies does its utmost best to process only those personal data which are
necessary to achieve the purposeslisted under the purpose for processing.
2. Here we explain how long we will keep your personal data in a way that allows us to identify
you.
Your personal data are only processed for as long as needed to achieve the purposes which
are described above or up until such time where you withdraw your consent for processing
them. Note that withdrawal of consent may imply that you can no longer use the whole or
part of the Website. Foton Technologies will de-identify your personal data when they are no
longer necessary for the purposes outlined in the purpose for processing, unlessthere is:
o an overriding interest of Foton Technologies or any other third party in keeping your
personal data identifiable;
o a legal or regulatory obligation or a judicial or administrative order that prevents
Foton Technologiesfrom de-identifying them.
3. We are committed to keeping your personal data safe.
Foton Technologies will take the appropriate technical and organizational measures to keep
your personal data safe from unauthorized access or theft as well as accidental loss,
tampering or destruction. Access by personnel of Foton Technologies or its third party
processors will only be on a need-to-know basis and subject to strict confidentiality
obligations. You understand, however, that safety and security are best efforts obligations
only, which can never be guaranteed.
Your Rights
1. You have the right to request access to all personal data processed by Foton Technologies
pertaining to you. We reserve the right to charge an administrative fee for multiple
subsequent requestsfor accessthat are clearly submitted for causing nuisance or harm to us.
2. You have the right to ask that any personal data pertaining to you that are inaccurate, are
corrected free of charge. If a request for correction is submitted, such request shall be
accompanied of proof of the flawed nature of the data for which correction is asked.
3. You have the right to withdraw your earlier given consent for processing your personal data.
4. You have the right to request that personal data pertaining to you will be deleted if they are
no longer required in light of the purposes which are outlined above or if you withdraw your
consent for processing them. However, you need to keep in mind that a request for deletion
will be evaluated by Foton Technologies against:
o overriding interests of us or any other third party;
o legal or regulatory obligations or administrative or judicial orders which may
contradictsuch deletion.
o Instead of deletion you can also ask that we limit the processing of your personal
data if and when (a) you contest the accuracy of that data, (b) the processing is
illegitimate or (c) the data are no longer needed for the purposes which are outlined
above, but you need them to defend yourself in judicial proceedings.
5. You have the right to oppose the processing of personal data if you are able to prove that
there are serious and justified reasons connected with his particular circumstances that
warrantsuch opposition.
6. You have the right to receive from us in a structured, commonly used and machine-readable
format all personal data you have provided to us.
7. If you wish to submit a request to exercise one or more of the rights listed above, you can
send an e-mailsupport@fotoncard.com for all data subject rights matters. An e-mail
requesting to exercise a right shall not be construed as consent with the processing of your
personal data beyond what isrequired for handling your request. Such requestshould clearly
state and specify which right you wish to exercise and the reasons for it if such is required. It
should also be dated and signed, and accompanied by a digitally scanned copy of your valid
identity card proving your identity.Foton Technologies will promptly inform you of having
received this request. If the request proves valid, we shall notify it as soon as reasonably
possible and at the latest thirty (30) days after having received the request.If you have any
complaint regarding the processing of your personal data by Foton Technologies, you may
always contact us via the e-mail address mentioned in the first paragraph of this clause. If
you remain unsatisfied with our response, you are free to file a complaint with the
competent data protection authority. For a list of national data protection authorities,
visit https://edpb.europa.eu/about-edpb/board/members_en.

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