Paul Steen, AZE

Hospeltstrasse 69

50825 Cologne



Privacy Policy Statement

I, Paul Steen, respect your privacy. This Policy describes the ways I as a self-employed artist with a personal web page may collect information from and about you, and what I do with the information, so that you may decide whether or not to provide information to me. By accessing our website, or purchasing our products or services you agree to this Privacy Statement in addition to any other agreements I might have with you. I do not govern the practices of entities that I do not own or control, or entities that do not own or control me as a self-employed artist or people that I as a self-employed artist do not employ or manage. This Privacy Policy Statement incorporates the Privacy Shield Statement, as is listed below.

Collection of your Personal Information The information I collect may include your personal information, such as your name, contact information, IP addresses, product and service selections and other things that identify you. I collect personal information from you at the certain points, including but not limited to the following: ? when I correspond with you as a customer or prospective customer; ? when you visit my website; ? when you contact me for help; ? when the site sends me error reports or application analytics data.

My Use of your Personal Information I as a self-employed artist may use information that I collect about you to: ? deliver the products and services that you have requested; ? provide you with customer support; ? perform research and analysis about your use of, or interest in, my products, services, or content, or products, services or content offered by others; ? communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from me, or other third parties; ? develop and display content and advertising tailored to your interests on my site and other websites; ? enforce my terms and conditions; ? manage my business; ? transfer personal information to third parties for any legally permissible purpose in my sole discretion.

Disclosure of your Personal Information to Third Parties I may share your personal information with third parties in the following ways: ? I may provide your information to my agents, vendors or service providers who perform functions on my behalf or who help me provide and support our Services. For example, if it is necessary to provide you something you have requested. Examples of our Vendors and Service Providers include payment processors, hosting services and content delivery services, such as Salesforce, Stripe, Zendesk, Google, Drip, Mailchimp and Intercom ; ? third party contractors may have access to our databases. Usually these contractors sign a standard confidentiality agreement; ? I may share your data with any parent company, subsidiaries, joint ventures, other entities under a common control or third party acquirers. I expect these other entities will honor this Privacy Statement; ? I may allow a potential acquirer or merger partner to review my databases, although I would restrict their use and disclosure of this data during the diligence phase; ? as required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to our Company; or when I believe, in my sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our agreements or Company policies; and ? sometimes, I share your information with our third party Service Providers, ? I may, from time to time, offer surveys, contests, sweepstakes, or other promotions on my Websites or through social media (collectively ?My Promotions?). Participation in my Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. I use the information you provide to administer My Promotions. I may also, unless prohibited by the Promotion?s rules or law, use the information provided to communicate with you, or other people you select, about our Services. I may share this information with my affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion. ? other third parties with your consent or direction to do so. Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.

Public Information ? Social media platforms and widgets. My Websites may include social media features, these features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. I also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to me via a social media platform is done at your own risk without any expectation of privacy. I cannot control the actions of other users of these platforms or the actions of the platforms themselves.

Our Security Measures to Protect your Personal Information This page uses industry-standard technologies when transferring and receiving data exchanged between me as a self-employed artist and other companies to help ensure security. This site has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access. However, ?perfect security? does not exist on the Internet. Also, if this website contains links to other sites, I am not responsible for the security practices or the content of such sites.

My Use of Cookies, Web Beacons, Web Analytics Services, and Links ? Cookies are text files I may place in your computer?s browser to store your preferences. Cookies, by themselves, do not tell me your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at my site. However, once you choose to furnish the site with personal information, this information may be linked to the data stored in the cookie. I use cookies to allow you to understand site usage and to improve the content and offerings on our sites. I also may use cookies to offer you products, programs, or services. You have many choices with regards to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies, please consult the privacy features in your browser. ?

Web Beacons. I, as a self-employed artist, and third parties, may also use small pieces of code called ?web beacons? or ?clear gifs? to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. These ?web beacons? may be used to deliver cookies that conform to our Company?s cookie requirements. ?

Web Analytics Services. I may use Google Analytics, a service for the marketing analysis of the site provided by Google, Inc. Google Analytics uses cookies to allow us to see how you use our site so I can improve your experience. Google?s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html ?

and the Google Privacy Policy available at ?

http://www.google.com/policies/privacy/ .

You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at ?

https://tools.google.com/dlpage/gaoptout ? .

? I may create links to other websites. I will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual?s right to privacy. However, many other sites that are not associated with or authorized by me may have links leading to my site. I as a self-employed artist cannot control these links and I am not responsible for any content appearing on these sites. Since this website does not control the privacy policies of third parties, you are subject to the privacy practices of that third party. I encourage you to ask questions before you disclose any personal information to others. ? My websites may use third parties to present or serve the advertisements that you may see at its web pages and to conduct research about the advertisements and web usage. This Privacy Statement does not cover any use of information that such third parties may have collected from you or the methods used by the third parties to collect that information.

Our Retention of your Personal Information I will retain any personal information only for as long as is necessary to fulfill the business purpose it was collected. I will also retain and use your personal information for as long as necessary to comply with my legal and fiscal obligations, resolve disputes, and enforce our agreements.

Your Right to Opt-Out or Unsubscribe from Communication If you do not want to receive communication from me in the future, please let me know by sending me an e-mail at info@paulsteen.se. If you supply me with your postal address online you will only receive the information for which you provided us your address.

International Transfers of your Personal Information Information collected from you may be stored and processed in the United States or any other country in which I as a self-employed artist or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country. European Union or Swiss individuals may refer to the Privacy Shield statement with regard to the transfer of their personal data. ?

I have appropriate security measures in place in my physical facilities to protect against the loss, misuse or alteration of information that I have collected from you at our site.

COPPA (Children Online Privacy Protection Act) When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online. I do not specifically market to children under the age of 13 years old.

Changes to my Privacy Statement I may amend this Privacy Statement at any time by post ing a new version. It is your responsibility to review this Privacy Statement periodically as your continued use of this website represents your agreement with the then-current Privacy Statement.

Contacting Us If you have any questions about this Privacy Statement, the practices or concerns of this site, or feel that the site is not following its said policy, please contact our Privacy Officer at: info@paulsteen.se ? .

Privacy Shield Statement I have done my best to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit ? https://www.privacyshield.gov/ ? ?

. This Privacy Statement outlines my general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

A) Definitions ?Personal Data? means information that (1)is transferred from the EU/EEA or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. ?Sensitive Personal Information? means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual?s health. B) Principles I may receive Personal Data from my own personnel as well as from affiliates and other parties located in the EU/EEA. Such information may contain names, addresses, email addresses and payment information and may be about customers, clients of customers, business partners, consultants, employees, and candidates for employment and includes information recorded on various media as well as electronic data. Other than its own human resources data, I generally do not collect Personal Data directly from individuals.

Personal Data Collection Principles: 1. I shall inform an individual of the purpose for which I collect and use their Personal Data and the types of third parties to which I as a self-employed artist disclose or may disclose that Personal Data. I shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to our Company, or as soon as practicable thereafter, and in any event before I use or disclose the Personal Data for a purpose other than for which it was originally collected. I may be required to disclose Personal Data in response to lawful request by public authorities, including to meet national security or law enforcement requirements.

2. Individuals have the opportunity to choose (opt out) whether their Personal Data is (1) to be disclosed to a non-Agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual by contacting me via email at info@paulsteen.se ? Agents, employees, or contractors of me as a self-employed artist or my affiliates may have access to an individual?s Personal Data on a need to know basis for the purpose of performing services on behalf of me, or providing or enabling elements of the services. All such agents, employees, or contractors who have access to such information are contractually required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing or as otherwise required by law. '

3. Accountability for Onward Transfer. ? Prior to disclosing Personal Data to a third party, I shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. I will: ? Limit the data we share with our partners and vendors to only that data I have permission to share. ? Proactively confirm that my partners and vendors understand purpose limitations. ? Ensure partners and vendors will make at least the same level of privacy protection as required by the Privacy Shield principles to comply with the purpose limitation and appropriate protection of that data. ? Transfer such data only for limited and specified purposes as detailed in the privacy policy. ? Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles. ? Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with my obligations under the Principles. ? Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing. ? I require any third party agent to notify me in the event that it makes a determination that it can not longer meet its obligation to provide the same level of protection as is required by the Privacy Shield principals. ? Provide a summary or representative copy, of the relevant privacy policy provision of its contract with that agent, to the department upon request. ? Unless I prove that I am not responsible for the event giving rise to the damage. I recognizes my responsibility and potential liability for onward transfers.

4. Data Security. ? I shall take reasonable steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. I have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, I cannot guarantee the security of Personal Data on or transmitted via the Internet.

5. Data Integrity ? ? and Purpose Limitation. ? I shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, I shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

6. Access and Recourse. ? I acknowledge the individual?s right to access their Personal Data. We shall allow an individual access to their Personal Data and allow the individual the opportunity to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals may contact our me via email to request access.

7. Enforcement and Liability. ? The Federal Trade Commission has jurisdiction over my compliance with the Privacy Shield. In compliance with the EU-US Privacy Shield Principles, I commit to resolve complaints about privacy and our collection or use of Personal Data. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact me at: Paul Steen, AZE Hospeltstrasse 69 50825 Cologne Germany E-mail: ? info@paulsteen.se

a. Human Resources Data ? . I would generally not collect human resources data. If there was reason to collect such information and there was a complaint it would be addressed within a timely period. If your complaint is not satisfactorily addressed by me, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (?DPA Panel?), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (?FDPIC?). To do so, you should contact the state or national data protection or labor authority in the jurisdiction whe re you work. I agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC. The services of EU DPAs are provided at no cost to you.

b. Independent Recourse - Non-Human Resources Data ? . ? I have further committed to refer unresolved Privacy Shield complaints to ? EU data protection authorities (?DPA Panel?) and The Swiss Federal Data Protection and Information Commissioner (?FDPIC?) ? , an alternative dispute resolution provider located in the (the EU, or Switzerland, as applicable). If you do not receive timely acknowledgment of your complaint from me, or if we have not resolved your complaint, please contact or visit : EU DPA Contact: https://ec.europa.eu/info/departments/justice-and-consumers_en#contact Phone number+32 2 299 11 11 (Commission switchboard) Postal address: Directorate-General for Justice and Consumers European Commission 1049 Bruxelles/Brussel Belgium FDPIC Contact: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html Data Protection and Information Commissioner of Switzerland Tell. +41 58 462 43 95; Fax +41 58 462 99 96 Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. C) Amendments This Privacy Statement may be amended from time to time consistent with the requirements of the Shield Frameworks. I will post any revised policy on this website. D) Information Subject to Other Policies

I am committed to following the Principles for all Personal Data within the scope of the Privacy Shield Frameworks. Updated: May 29, 2018