Privacy Statement

Last updated 1 October 2025

We have updated this Privacy Statement in preparation for the launch of Photo Assignments. These updates do not introduce any new categories of personal data and do not involve sharing your data with new third parties. The changes are intended to clarify how your personal data is processed in connection with Photo Assignments.

Material Change:

• Contracting Party and data controller: Camera Setup has transitioned from a sole proprietorship to a private limited company. Camera Setup Services B.V. is now the contracting party and data controller.

Other adjustments were clarifications or compliance alignments and do not materially change participants’ rights or obligations.

You can request a copy of this Privacy Statement at any time by emailing info@camerasetup.co.

1. General

Camera Setup Services B.V. (“Camera Setup”, “we”, “us” or “our”) is a private limited liability company registered in Amsterdam, the Netherlands, and registered with the Dutch Chamber of Commerce under number 98437674.

For the processing of personal data as referred to in this privacy statement, Camera Setup is considered as a Data Controller within the meaning of applicable privacy and data protection laws, including the General Data Protection Regulation (“GDPR”), the UK GDPR, the California Consumer Privacy Act (“CCPA”), and comparable legislation in other jurisdictions.

2. About this Privacy Statement

In this Privacy Statement, Camera Setup informs you (the “participant” or “subscriber”) about the purposes and legal bases on which personal data are processed, how you can exercise your privacy rights, and other information that may be of importance to you.

Camera Setup reserves the right to amend or update this Privacy Statement at any time at its sole discretion. Any material changes to this Privacy Statement will be communicated to participants by email and posted prominently on this webpage. Continued Participation following such notification constitutes acceptance of the updated Privacy Statement.

3. Contact Camera Setup

If you have any questions about this privacy statement, the personal data processed by Camera Setup or how to exercise your rights, you may email us at privacy@camerasetup.co.

4. Third Party Service Providers

Camera Setup makes use of the Substack platform (www.substack.com) to send Photo Assignments and uses Padlet (www.padlet.com) to host the community gallery. Uploading photos to the Padlet community gallery is part of the Photo Assignments service and governed by our Terms of Service; however, submitting photos to the community gallery is entirely voluntary and not required to use the service. Without prejudice to the provisions of this Privacy Statement, the separate privacy policies of Substack and Padlet apply to the processing of your personal data carried out by Substack and Padlet.

Substack’s privacy policy can be consulted at https://substack.com/privacy.

Padlet’s privacy policy can be consulted at https://legal.padlet.com/privacy.

5. Personal Data Processed by Camera Setup

5.1. Photo Assignments via Substack

Below is an overview of the personal data that Camera Setup may process. In specific cases, it may be possible that we process additional or different data:

• For subscribing to and receiving the newsletter and updates: the subscriber’s first and/or last name and email address as provided by you during the sign-up/opt-in process;

• For managing paid subscriptions: subscription status and related account information. Payment details are processed by Substack and its payment provider Stripe;

• For analytics and insights: information on whether you open an email, click on links, read a post, and other engagement statistics provided by Substack;

• For communication and interaction: content of replies to emails, comments on posts, or survey/poll responses;

• For technical and security purposes: IP address, device and browser type, and similar technical data collected via Substack’s platform.

Camera Setup processes personal data for the following purposes:

• To send electronic messages, particularly in the form of photo assignments;

• For internal administration;

• To inform the subscriber about changes related to Photo Assignments and/or content, services, and products of Camera Setup;

• To improve the content, services, and products offered by Camera Setup;

• To collect payment information when the subscriber uses a paid service of Camera Setup in order to process that payment;

• To grant the subscriber access to an online (subscription) environment;

• To respond to the subscriber via the online channels used by Camera Setup;

• As part of research or content publication, when the subscriber actively participates in such research.

5.2. Community Gallery via Padlet

Below is an overview of the personal data that Camera Setup may process. In specific cases, it may be possible that we process additional or different data:

• For creating and managing a Padlet workspace: username, email address, and any profile information you choose to provide within Padlet;

• For participating in the Padlet workspace: any content you upload or share (such as text, images, or files), as well as metadata associated with that content (such as timestamps);

• For interacting with shared content within Padlet: comments, reactions, or other interactions you make within the community gallery.

Camera Setup processes personal data in Padlet for the following purposes:

• To create and maintain the Community Gallery, enabling participants to upload photos, share content, and interact with each other;

• To moderate contributions, ensuring shared content complies with our Terms of Service;

• To share selected submitted photos via Substack and other social media channels (with credit to the contributor, where applicable);

• To manage participation in the gallery, including responding to questions or issues raised by contributors.

Please note: Your accounts on Substack and Padlet are created and managed by those platforms, and may also be used for purposes outside of Camera Setup’s Photo Assignments services. Camera Setup only processes the account information necessary to manage and facilitate the Photo Assignments and does not have control over, or access to, your Substack or Padlet accounts beyond this scope.

6. The legal basis Camera Setup relies on

The processing of personal data must be based on a reason, also known as a legal basis, as stipulated in privacy legislation. The primary basis for processing is the performance of the agreement between you and Camera Setup, as your participation in Photo Assignments requires the collection and processing of certain personal data.

In addition, Camera Setup may process personal data:

• where necessary to comply with a legal obligation applicable to Camera Setup;

• where processing is necessary for purposes related to Camera Setup’s legitimate interests, such as ensuring the security and integrity of our services, maintaining proper administration, or improving the quality of our offerings;

• on the basis of your consent, but only where such consent is explicitly requested and provided, for example in relation to optional activities outside the scope of the agreement.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

7. Third-party recipients of personal data

Camera Setup may share the personal data obtained from subscribers with affiliated companies, (future) parent and sister companies, and external service providers where necessary to deliver our services. The main third-party providers we rely on are:

Substack
We use Substack to publish and distribute Photo Assignments, manage subscriptions, and send email updates. This means that your personal data (such as name, email address, subscription status, and engagement analytics) may be processed by Substack in order to deliver our services. If you purchase a paid subscription, Substack partners with Stripe to process payments. In that case, your payment details (including billing address and credit card information) are processed directly by Substack and Stripe. Their terms and privacy policies apply, and Camera Setup is not liable for this processing.

Substack acts as an independent data controller and/or processor for your subscription data, and we have chosen Substack with the understanding that they apply appropriate technical and organisational measures to safeguard your personal information.

Padlet
We use Padlet to facilitate the community gallery. This means that any personal information included in photos you upload, as well as any profile or contact details you provide for access, may be processed by Padlet in order to provide the Photo Assignment services.

Padlet also acts as an independent data controller and/or processor for this information, and we have chosen Padlet with the understanding that they apply appropriate technical and organisational measures to safeguard your personal information.

We may need to share your personal information in the following situations:

• Change of Business Structure. We reserve the right to change the legal structure of our business at any time, including transitioning from a sole proprietorship to a limited liability company or another legal entity.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

8. International transfer of Personal Data

In order to provide our services, Camera Setup may transfer personal data to recipients located outside the European Economic Area (EEA), the United Kingdom (UK), or Switzerland. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data, as required under applicable data protection laws. These safeguards may include the use of standard contractual clauses approved by the European Commission or other lawful transfer mechanisms.

We take steps to ensure that any party processing personal data on our behalf provides an adequate level of protection, regardless of where they are located. In certain cases, personal data may also be disclosed to competent authorities if required by applicable law.

9. Retention periods of personal data

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Statement, unless a longer retention period is required or permitted by law.

You may take steps to manage or remove certain personal data at any time, such as deleting submitted photos or other content on the community gallery, or by closing your account with a third-party service provider (e.g., Substack or Padlet). Please note that some data may remain available on those third-party platforms in accordance with their own terms of service, including possible backup or archival retention.

10. Security of personal data

Camera Setup takes the protection of your personal data seriously and implements appropriate technical and organisational measures to prevent misuse, loss, unauthorised access, unwanted disclosure, and unauthorised modification. These measures are intended to provide a level of security appropriate to the risks associated with the processing.

However, no electronic transmission over the Internet or method of information storage can be guaranteed to be completely secure. This means that we cannot promise or guarantee that unauthorised third parties (such as hackers or cybercriminals) will never be able to bypass security measures and gain access to your information.

If you believe your data is not properly secured or if there are indications of misuse, please contact us at privacy@camerasetup.co.

11. Personal data from minors

For participating in Photo Assignments, you have to be at least 18 years old, as stated in our Terms of Service.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records.

If you become aware of any data we may have collected from children under age 18, please contact us at privacy@camerasetup.co.

12. Your rights

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

1. to request access and obtain a copy of your personal information

2. to request rectification or erasure

3. to restrict the processing of your personal information

4. if applicable, to data portability; and

5. not to be subject to automated individual decision-making.

6. to object to the processing of your personal information.

For a request for access, modification, or deletion of personal data, to object to (further) processing, to withdraw consent, or for a request regarding data portability, you can contact us at privacy@camerasetup.co.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

13. Controls for do-not-track features

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

14. Rights of United States residents

Categories of Personal Information We Collect

We collected the following categories of personal information in the past twelve (12) months:

A. Identifiers

B. Personal information as defined in the California Customer Records statute

F. Internet or other similar network activity

H. Audio, electronic, sensory, or similar information

We did not collected any of the following categories of personal information in the past twelve (12) months:

C. Protected classification characteristics under state or federal law

D. Commercial information

E. Biometric information

G. Geolocation data

I. Professional or employment-related information

J. Education Information

K. Inferences drawn from collected personal information

L. Sensitive personal Information

We may collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in “5. Personal Data Processed by Camera Setup”.

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, “5. Personal Data Processed by Camera Setup”.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “7. Third-party recipients of personal data”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

The third-parties to whom we disclosed personal information for a business or commercial purpose can be found under “7. Third-party recipients of personal data”

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (”profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)

• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

To exercise these rights, you can contact us by emailing us at privacy@camerasetup.co.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@camerasetup.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy@camerasetup.co.

15. Applicability

This Privacy Statement provides information about the processing of personal data by or for Camera Setup and pertains solely to the use of subscribers’ (personal) data. This Privacy Statement does not apply to third-party websites. Camera Setup advises subscribers to consult the privacy policies of these third parties on their respective websites.