3. PRIVACY POLICY

SOUVENIR Collective Inc. respects your privacy and is committed to protecting personal information collected through the Website.

For purposes of applicable data-protection legislation, including the EU General Data Protection Regulation (“GDPR”) where applicable, SOUVENIR Collective Inc. is the controller of personal information processed through the Website.

Information We Collect

Depending on how you interact with SOUVENIR, we may collect:

• your name and contact information;

• email address;

• billing and shipping address;

• telephone number, where provided;

• order and subscription information;

• transaction information;

• newsletter preferences;

• communications you send to us;

• IP address, browser and device information;

• pages visited, referral information and Website usage information; and

• cookie and analytics information where applicable.

Payment information is processed by Stripe where Stripe is used for checkout. SOUVENIR does not ordinarily receive or store your complete payment-card details.

Submissions and Contributor Information

If you submit writing, artwork, photography or other creative work to SOUVENIR, we may collect information including:

• your name and email address;

• mailing address, where provided;

• biographical information or an author/artist bio;

• manuscripts, artwork, photography or other creative work submitted;

• social-media handles;

• cover letters; and

• other information you voluntarily provide with your submission.

We use this information to receive, review and evaluate submissions; communicate with prospective and accepted contributors; administer the editorial and production process; and, where work is accepted and the necessary publication rights have been agreed, publish and promote that work.

Submission information and materials may be made available to SOUVENIR's editorial and production staff and other persons reasonably involved in reviewing, editing, producing or publishing the work.

Submission content will not be made public merely because it has been submitted. Publication of accepted work is subject to the applicable agreement or permission between SOUVENIR and the contributor.

How We Use Personal Information

We may use personal information to:

• receive, review and administer editorial submissions;

• communicate with contributors and manage contributor relationships;

• process and fulfil orders;

• administer subscriptions and membership benefits;

• process payments and refunds where applicable;

• arrange deliveries;

• provide digital access;

• communicate regarding orders and subscriptions;

• respond to enquiries;

• send newsletters and editorial communications where requested;

• operate, maintain and improve the Website and publication;

• understand Website usage and performance;

• prevent fraud and maintain Website security; and

• comply with applicable legal, accounting and tax obligations.

We do not sell personal information.

We do not share contributor contact information with third parties for their own marketing purposes.

Legal Bases for Processing

Where the GDPR applies, SOUVENIR processes personal information under one or more of the following legal bases:

Performance of a contract — where processing is necessary to fulfil an order, subscription, contributor agreement or other agreement with you.

Consent — including certain newsletter communications and optional cookies where consent is required.

Legitimate interests — where reasonably necessary to operate, protect and improve SOUVENIR, manage editorial activities and administer the Website, provided those interests do not override your rights and freedoms.

Legal obligations — where information must be processed or retained to comply with applicable law.

How We Share Information

We may share personal information where reasonably necessary with:

• service providers involved in Website hosting, ecommerce, payments and email delivery;

• SOUVENIR editorial and production staff involved in reviewing or publishing submissions;

• fulfilment, delivery or other providers necessary to complete an order;

• professional advisers where reasonably necessary; and

• public authorities where disclosure is required by applicable law.

We do not disclose submitted creative work publicly unless it has been accepted for publication and the necessary publication rights have been agreed.

Newsletter

Visitors may subscribe to SOUVENIR newsletters and editorial communications through Squarespace.

Subscribers may unsubscribe at any time using the unsubscribe link contained in the email.

Unsubscribing from editorial or promotional communications does not prevent SOUVENIR from sending necessary transactional communications relating to an order or active subscription.

Service Providers

SOUVENIR uses third-party providers necessary to operate the Website and publication, including:

Squarespace for Website hosting, ecommerce, newsletter functionality and Website analytics.

Stripe for payment processing.

These providers process certain information in accordance with their respective terms and privacy practices.

International Data Transfers

SOUVENIR Collective Inc. is established in the United States. Some personal information relating to individuals in France or elsewhere in the European Economic Area may therefore be processed or transferred outside the EEA.

Where required by applicable data-protection law, appropriate safeguards are used for international transfers.

Data Retention

Personal information is retained only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, accounting, tax and contractual obligations.

Submission materials are retained for the period reasonably necessary to review and respond to the submission.

For accepted work, relevant materials and contributor information may be retained as necessary for publication, editorial records and applicable contractual, licensing or copyright purposes.

Order and transaction records may be retained for the period necessary to satisfy accounting, tax and legal recordkeeping requirements.

Newsletter information is generally retained until you unsubscribe or otherwise request deletion, subject to information that SOUVENIR may be required or permitted to retain.

Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• request access to personal information held about you;

• request correction of inaccurate information;

• request deletion of eligible personal information;

• restrict certain processing;

• object to certain processing;

• withdraw consent where processing is based on consent; and

• request portability of eligible personal information.

To exercise your rights, contact magazine@souvenir-paris.com.

We may request information reasonably necessary to verify your identity.

Individuals in France also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL).

Children's Privacy

The Website and SOUVENIR's submission process are not directed to children under 13, and SOUVENIR does not knowingly collect personal information from children under 13 without appropriate authorization.

If we learn that such information has been collected improperly, we will take appropriate steps to delete it.

Data Security

SOUVENIR uses reasonable administrative, organizational and technical safeguards designed to protect personal information.

Transactions rely on the security measures provided by Squarespace and Stripe.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

Third-Party Websites

The Website may contain links to third-party websites and platforms, including Substack, contributor websites, social-media platforms and partner organizations.

These third parties operate under their own privacy practices. SOUVENIR is not responsible for the privacy practices or content of independent third-party websites.