Putnam 2025 Privacy Policy

Date: February 7, 2025

Summary

We do not share or sell customer personal information. We are committed to protecting user privacy and maintaining maximum transparency. We only collect the information necessary for the normal operation of our products and services.

Who Are We?

PUTNAM TECHNOLOGY LLC (hereinafter referred to as "we," "our," or "the Company") collects and processes personal data in accordance with this privacy policy and applicable data protection laws. This policy provides customers with necessary information about their rights and our obligations, and explains how, why, and when we process personal data. Our overall principle is to collect only the most necessary information, aimed at better providing all features of our products and services to customers. We strictly adhere to the "minimization" principle when processing personal data.

PUTNAM TECHNOLOGY LLC is a registered company located at 5774 N Bedstrow Blvd, Beverly Hills, FL 34465 US. In processing personal data, PUTNAM TECHNOLOGY LLC acts as the data controller.

If you have any questions about this privacy policy or wish to exercise any of your rights, please contact us at [email protected].

Please read the privacy policy carefully. If you do not agree with our policies and practices described in this privacy policy, please do not use our software and services, access our website, or provide us with your information.

How We Collect Personal Data

We may obtain your personal data in various ways:

When you visit our website https://putnamstustudio.com and its subdomains (hereinafter referred to as the "Website"). For more information on what data is collected, how it is collected, and how it is managed, please refer to the privacy policy on the Putnam 2025 website at https://putnamstustudio.com/privacy.html.

When using our products. You can find a complete list of personal data collected on the dedicated privacy statement page of the product you are using.

What Data We Process

We process different types of data depending on the situation. You can learn more about the data we process in this section.

According to the laws of certain regions and countries, some data we receive and process may be considered personal data ("Personal Data"). When we use the term "Personal Data" or "Personal Information," we refer to any information relating to an identified or identifiable natural person, excluding any anonymous and de-identified data, i.e., data where your true identity is not present or has been removed and cannot be recovered.

The data we process does not exceed what is necessary to provide the full functionality of Putnam 2025 products, website, and services. We do not process any information for tracking purposes and will take all necessary technical, managerial, and physical measures to protect the information we obtain.

When Using Our Website

Sending Information: We may use your email address to publish announcements, notify you of updates and new features of our software or services, provide you with suggestions, or communicate with you when reporting errors.

Cookies: We use cookies to personalize website content, such as setting the default language. The information obtained through cookies is not considered personal data, as it does not allow us to identify your identity. You can disable cookies in your web browser or clear existing cookies at any time, but please note that some of our services may not function properly without cookies. For details, please refer to the privacy policy on the Putnam 2025 website.

Legal Basis for Processing Personal Data

Depending on the type of data, purpose, and processing situation, we use different legal bases to process personal data.

Consent: If you consent to our processing of your personal data for certain purposes, we will process your personal data accordingly. For example, to send you marketing information or assist you with issues using our software. You may withdraw your consent at any time without affecting your use of our software.

Contractual Obligation: We will process your personal data as necessary to fulfill our contractual obligations to you, including providing the functionality of our software and services, or processing your personal data at your request before entering into a contract with you.

Legal Obligation: We will process your personal data as necessary to comply with our legal obligations, such as exercising or defending our legal rights or for tax purposes.

Legitimate Interests: We will pursue our legitimate interests when processing your personal data, unless this interest is overridden by the interests or fundamental rights and freedoms of the data subject.

Where We Process Personal Data

We store personal data in a data center located in Frankfurt, Germany. Your personal data may be processed by our employees, who can only access personal data on a need-to-know basis in the course of their work duties. If you have questions or want to know from which countries your personal data may be accessed, please contact us at [email protected].

For data transfers to other countries, we always take appropriate safeguards to ensure that personal data remains secure and respects your rights:

The country or third party is considered to provide adequate protection.

Effective transfer mechanisms, such as standard contractual clauses, are used, and additional measures are taken where necessary.

The transfer is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.

If you need a copy of the standard contractual clauses used, please contact us at [email protected]. To determine whether the data protection level in non-EU countries is adequate, please visit the European Commission website.

How We Use Your Personal Data

Your privacy is our top priority. We value personal privacy very highly and will never disclose, share, or sell personal data unless permitted or required by law. The sole purpose of collecting and storing personal data is to provide you with our products and services and to fully realize their potential.

Retention of Personal Data

We retain personal data for the period necessary to provide these products and services to customers or until you withdraw your consent to share this information.

Customer Rights

In certain countries and regions, you may have certain rights regarding your personal data under applicable data protection laws. If you wish to exercise your rights regarding personal data, please contact us at [email protected]. We will consider any requests and take action in accordance with applicable data protection laws. We may ask you to further confirm your identity and will respond to you within the timeframe set by applicable data protection laws. Please note that in certain situations under applicable data protection laws, we may charge a reasonable fee for processing your request or refuse your request.

You have the following rights regarding your personal data:

Right of Access: The right to obtain all your personal data that we store. In certain cases, the right of access may be limited for technical reasons, including situations where the data has been anonymized and cannot be associated with any data subject.

Right to Deletion or Right to be Forgotten: The right to have your personal data completely deleted. You can delete it at your discretion in your Putnam 2025 account or send a request to [email protected].

Right to Rectification: The right to correct any incomplete or inaccurate personal data about you. We will rectify it as soon as possible unless there are legitimate reasons not to correct it, in which case we will notify you.

Right to Restriction: The right to impose restrictions on the processing of your personal data.

Right to Object: The right to object to the processing of your personal data.

Right to Data Portability: The right to receive the personal data provided in a structured, commonly used, and machine-readable format and to transfer that data to another controller. You can export all personal data we hold about you from your [email protected] account to a local file.

Right Not to be Subject to a Decision Based Solely on Automated Processing (including profiling).

Right to Withdraw Consent: If the data processing is based on consent, you have the right to withdraw consent.

Safeguards

We take all possible measures to protect you and your personal data from unauthorized access, alteration, disclosure, or destruction. We implement and maintain the following technical and security measures:

System Access Control: We take reasonable measures to prevent unauthorized use of personal data. These controls may vary depending on the nature of the processing and may include, among other controls, password protection and/or two-factor authentication, documented authorization processes, documented change management processes, and/or multiple levels of access logging.

Data Access Control: We take reasonable measures to ensure that only authorized employees can access and manage personal data. Direct database query access is restricted, and application access permissions are established and enforced to ensure that personnel authorized to use the data processing system can only access the personal data they are authorized to access; during processing, personal data must not be read, copied, modified, or deleted without authorization.

Transmission Control: We take reasonable measures to ensure that we can check and determine which entities personal data is transmitted to through data transmission facilities, preventing unauthorized reading, copying, modification, or deletion of personal data during electronic transmission or transport.

Input Control: We take reasonable measures to check and determine whether and by whom personal data is entered into, modified, or deleted from the data processing system.

Data Backup: We regularly back up the database to ensure database security and encryption to protect personal data from accidental destruction or loss while hosted by us.

Logical Isolation: Personal data is logically isolated within our systems to ensure that personal data collected for different purposes can be processed separately.

Consequences of Not Providing Personal Data

You are not obligated to provide your personal data to us. However, since we need this information to provide you with services or respond to your requests, we will not be able to provide part or all of the services without this information.

Age Restrictions

To the extent permitted by applicable law, we do not allow individuals under the age of 13 to use our services, products, and website. If you become aware of a person under the age of 13 illegally providing us with personal data, please contact us at [email protected]. We will take steps to delete the relevant information.

Changes to This Privacy Policy

We may change this privacy policy from time to time. The evolution of laws, regulations, and industry standards may require us to make these changes, or we may make changes to our business. We will publish changes on this page and encourage you to review our privacy policy periodically for the latest information. If the changes we make will materially affect your privacy rights, we will notify you separately via email. If you do not agree with the changes to this privacy policy, please contact us at [email protected].