LEGAL NOTICE – PELLI

Last updated: October 6, 2025

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Language and Interpretation

This Legal Notice has been written in French and translated into English for convenience. In the event of any inconsistency or discrepancy between the French and English versions, the French version shall prevail.

French law applies to this Legal Notice. In case of dispute, French courts shall have exclusive jurisdiction.

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1. IDENTIFICATION OF THE SITE PUBLISHER

In accordance with the provisions of Article 6 of Law No. 2004-575 of June 21, 2004 on confidence in the digital economy, users of the website https://pelli.io and the web application https://app.pelli.io (hereinafter collectively referred to as "the Site") are informed of the identity of the various parties involved in its creation and monitoring.

1.1 Publisher and Publication Director

Company name: Pelli Legal form: Simplified Joint Stock Company (SAS) Share capital: 2,000 euros Registered office: Quai de la Douane, Building LE GRAND LARGE, 29200 Brest, France SIRET number: 889 608 790 00032 RCS number: RCS Brest B 889 608 790 Intra-community VAT number: FR04889608790

Publication Director: Loan TALVAT, President Capacity: President of the SAS

Contact:

• Email: [email protected]
• Phone: 02 55 99 59 78
• Postal address: Quai de la Douane, Building LE GRAND LARGE, 29200 Brest, France

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2. HOSTING OF THE SITE AND DATA

2.1 Hosting of the web application and showcase website

The Site https://pelli.io and the application https://app.pelli.io are hosted by:

OVH SAS Registered office: 2 rue Kellermann, 59100 Roubaix, France Phone: 1007 (from France, free of charge) Website: https://www.ovhcloud.com Server location: Gravelines, France (Data center certified SecNumCloud ANSSI)

2.2 Hosting of media storage (photos and videos)

The storage of user media (photos, videos) is provided by:

SCALEWAY SAS Registered office: 8 rue de la Ville l'Évêque, 75008 Paris, France Phone: +33 (0)1 84 13 00 00 Website: https://www.scaleway.com Storage location: Paris, France (Underground data center at 20m depth with ISO 27001, ISO 50001 certifications)

Type of storage: Object Storage (S3-compatible), redundant across multiple availability zones in France.

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3. INTELLECTUAL PROPERTY

3.1 Rights on the Site

The Site pelli.io and the application app.pelli.io, their general structure, as well as the texts, graphics, images, sounds, videos, software and all other elements composing the Site are the exclusive property of LUMY.MEDIA SAS (trade name: Pelli) or are subject to a usage authorization.

Any representation, reproduction, adaptation or total or partial exploitation of the contents, trademarks, logos and services offered by the Site, by any means whatsoever, without the prior, express and written authorization of Pelli, is strictly prohibited and would constitute infringement within the meaning of Articles L. 335-2 and following of the Intellectual Property Code.

3.2 Trademarks

The trademarks "Pelli", the Pelli logo, as well as other trademarks, trade names, logos, and distinctive signs reproduced on the Site are trademarks registered or in the process of being registered by LUMY.MEDIA SAS.

Any reproduction, imitation or use, total or partial, of these trademarks, logos and distinctive signs, without the express and prior authorization of Pelli, is prohibited and would constitute infringement sanctioned by Articles L. 713-2 and L. 713-3 of the Intellectual Property Code.

3.3 Rights on user-generated content

The content (photographs, videos, texts, descriptions, etc.) uploaded and published by Photographer users of the Service remains their exclusive property.

LUMY.MEDIA claims no intellectual property rights over content uploaded by users.

However, by using the Service, Photographers grant Pelli a non-exclusive, worldwide, free and revocable license to:

• Host, store, reproduce and display content strictly within the framework of the Service;
• Perform technical operations necessary for the proper functioning of the Service (compression, format conversion, thumbnail generation, image processing for optional AI features).

This license ends upon permanent deletion of content by the Photographer or account termination.

Pelli formally commits to NEVER:

• Use user content for advertising or commercial purposes on its own behalf;
• Sell, transfer or assign content to third parties;
• Use content to train artificial intelligence models (including models used for smart search and facial recognition, which operate exclusively in inference mode).

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4. PROTECTION OF PERSONAL DATA

4.1 Data Controller

The data controller for personal data collected on the Site is:

LUMY.MEDIA SAS with capital of 2,000 € RCS Brest B 889 608 790 Registered office: Quai de la Douane, Building LE GRAND LARGE, 29200 Brest, France Email: [email protected] Phone: 02 55 99 59 78

4.2 Data Protection Officer (DPO)

In accordance with Article 37 of the General Data Protection Regulation (GDPR), Pelli has appointed a Data Protection Officer (DPO):

DPO Name: [email protected] Email: [email protected] Postal address: Quai de la Douane, Building LE GRAND LARGE, 29200 Brest, France

You can contact the DPO for any questions regarding the protection of your personal data, the exercise of your rights (access, rectification, deletion, portability, opposition, limitation of processing), or for any complaint.

4.3 Privacy Policy

For more information on the collection, processing, retention and protection of your personal data, please consult our detailed Privacy Policy available at: https://pelli.io/fr/privacy (French) https://pelli.io/en/privacy (English)

4.4 Supervisory Authority

In accordance with Article 77 of the GDPR, you have the right to lodge a complaint with the competent supervisory authority for data protection:

Commission Nationale de l'Informatique et des Libertés (CNIL) Address: 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France Phone: 01 53 73 22 22 Website: https://www.cnil.fr Online complaint form: https://www.cnil.fr/fr/plaintes

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5. COOKIES AND TRACKING TECHNOLOGIES

5.1 Cookie Usage Policy

Pelli uses cookies and similar technologies in compliance with applicable regulations (ePrivacy Directive 2002/58/EC and GDPR).

The cookies used by Pelli are exclusively technical cookies strictly necessary for the operation of the Site and the application. In accordance with Article 82 of the French Data Protection Act (Informatique et Libertés), no consent is required for these essential cookies.

Types of cookies used:

1. Authentication cookies: Allow maintaining your active user session (JWT token);
2. Preference cookies: Remember your language choices, theme (dark/light mode);
3. Security cookies: CSRF (Cross-Site Request Forgery) protection.

Pelli does not use any tracking, advertising or behavioral analysis cookies for marketing purposes.

5.2 Analytics Tools

Pelli uses PostHog for anonymized traffic and Site usage analysis. PostHog is installed in self-hosted mode on OVH servers in France, ensuring that no data is transferred to third-party servers or servers located outside the European Union.

Data collected by PostHog is anonymized and aggregated. No personally identifiable data is collected without your explicit consent.

You can disable PostHog by enabling the "Do Not Track" option in your web browser.

5.3 Managing Your Preferences

You can at any time:

• Delete cookies via your browser settings;
• Configure your browser to refuse cookies (warning: this may affect Site functionality);
• Use your browser's private browsing mode.

Cookie management guides by browser:

• Chrome: https://support.google.com/chrome/answer/95647
• Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies
• Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
• Edge: https://support.microsoft.com/fr-fr/microsoft-edge/supprimer-les-cookies

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6. LIABILITY

6.1 Limitation of Publisher Liability

Pelli strives to ensure the accuracy and updating of information disseminated on the Site. However, Pelli cannot guarantee the accuracy, precision or completeness of information made available on the Site.

Consequently, Pelli disclaims all liability:

• For any inaccuracy, inexactitude or omission relating to information available on the Site;
• For any damage resulting from fraudulent intrusion by a third party that led to modification of information made available on the Site;
• For any damage resulting from use of the Site or inability to access the Site.

6.2 User Liability

Users of the Site (Photographers and End Customers) are solely responsible:

• For the use they make of the Site and the application;
• For content they upload, publish or share via the Service;
• For compliance with applicable legislation (particularly regarding copyright, image rights, personal data protection, consumer law).

In particular, Photographers using the Shop Module are solely and entirely responsible for commercial transactions they conduct via Pelli. Pelli cannot be held liable for disputes between Photographers and End Customers concerning products sold.

6.3 Hyperlinks

The Site may contain hyperlinks to other websites. Pelli exercises no control over these third-party sites and disclaims all liability regarding their content, availability, or damage that may result from their use.

The inclusion of links to third-party sites does not in any way constitute approval or recommendation of these sites by Pelli.

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7. APPLICABLE LAW AND JURISDICTION

7.1 Applicable Law

This Legal Notice, as well as all Pelli legal documents (Terms of Service, Terms of Sale, Privacy Policy) are governed by French law.

In case of conflict between a translated version of legal documents and the French version, the French version prevails.

7.2 Competent Jurisdiction

In the event of a dispute relating to the use of the Site or the interpretation of this Legal Notice, and failing amicable resolution, French courts shall have sole jurisdiction.

For disputes involving consumers (within the meaning of the preliminary article of the Consumer Code), territorial jurisdiction is determined in accordance with Articles R. 631-3 and following of the Consumer Code.

For disputes involving professionals, the parties grant exclusive jurisdiction to the courts of the jurisdiction of the registered office of LUMY.MEDIA SAS, unless otherwise required by mandatory legal provisions.

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8. REPORTING ILLEGAL CONTENT

8.1 Reporting Procedure

In accordance with Article 6.I.7 of Law No. 2004-575 of June 21, 2004 on confidence in the digital economy (LCEN) and Article 16 of the Digital Services Act (DSA - EU Regulation 2022/2065), any person may report to Pelli the presence of manifestly illegal content hosted on the Service.

Types of illegal content concerned:

• Child pornography content (Article 227-23 of the Criminal Code);
• Incitement to racial, ethnic or religious hatred (Articles 24 and 33 of the Law of July 29, 1881);
• Apology of terrorism (Article 421-2-5 of the Criminal Code);
• Content violating human dignity (Article 227-24 of the Criminal Code);
• Content manifestly infringing the intellectual property rights of others;
• Defamatory or insulting content (Articles 29 and 33 of the Law of July 29, 1881).

8.2 Reporting Methods

Reports must be sent by email to: [email protected]

The report must contain:

1. Identity of the notifier: Name, surname, email address, postal address (if natural person) or company name and registered office (if legal entity);
2. Precise description of facts: Nature of illegal content, date of observation;
3. Content location: Exact URL of the gallery or incriminated content;
4. Reason for report: Legal basis invoked (article of law, case law);
5. Evidence: Screenshots, supporting documents.

In accordance with Article 6.I.4 of LCEN, any abusive or bad faith report exposes its author to the sanctions provided for in Article 226-10 of the Criminal Code (slanderous denunciation) and Articles 29 and following of the Law of July 29, 1881 (defamation).

8.3 Processing of the Report

Upon receipt of a report:

1. Acknowledgment of receipt within 24 business hours;
2. Analysis of the report by Pelli's moderation team (deadline: 48 to 72 hours);
3. Decision:
   • If manifestly illegal content: immediate removal of content and account restriction of the responsible Photographer;
   • If disputed content but not manifestly illegal: notice to the Photographer to remove the content within 48 hours;
   • If unfounded report: case closed with notification to the notifier.

In accordance with Article 6.I.2 of LCEN, Pelli cannot be held civilly or criminally liable for hosted content, as long as it acts promptly to remove or make inaccessible any manifestly illegal content brought to its attention.

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9. DIGITAL ACCESSIBILITY

Pelli is committed to making its Site and application accessible in accordance with Article 47 of Law No. 2005-102 of February 11, 2005 on equal rights and opportunities, participation and citizenship of persons with disabilities.

9.1 Compliance Status

The Site pelli.io and the application app.pelli.io are partially compliant with the General Accessibility Improvement Framework (RGAA) version 4.1, due to the non-compliances and exemptions listed below.

Accessibility test results:

• Compliance rate: Not yet conducted
• Date of last audit: Not yet conducted

9.2 Non-Accessible Content

Identified non-compliances:

• Audit in progress

Exemptions for disproportionate burden:

• Content uploaded by Photographers (photos, videos) is not under Pelli's control and may not meet accessibility criteria;
• Integrated third-party content (Gleap support widget, Spotify player) is not under Pelli's technical control.

9.3 Continuous Improvement and Contact

Pelli is committed to progressively improving the accessibility of its Site and application.

If you experience access difficulties: Email: [email protected] Phone: 02 55 99 59 78

In case of unsatisfactory response, you can contact the Défenseur des droits (Rights Defender):

• By mail (free, no postage): Défenseur des droits, Libre réponse 71120, 75342 Paris CEDEX 07
• By phone: 09 69 39 00 00 (cost of a local call)
• Via the online form: https://formulaire.defenseurdesdroits.fr/

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10. CREDITS

10.1 Design and Development

The Site pelli.io and the application app.pelli.io were designed and developed by LUMY.MEDIA SAS.

Technologies used: Next.js, React, TypeScript, and infrastructure hosted in France (OVH, Scaleway)

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11. MODIFICATIONS TO THE LEGAL NOTICE

Pelli reserves the right to modify this Legal Notice at any time, particularly to adapt it to legislative and regulatory developments, technical developments of the Site, or developments in the services offered.

Modified Legal Notices will take effect upon being posted online on the Site.

Date of last modification: October 6, 2025

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12. CONTACT

For any questions, complaints or requests for information concerning the Site, you can contact Pelli by the following means:

General email: [email protected] Personal data email: [email protected] DPO email: [email protected] Illegal content reporting email: [email protected] Accessibility email: [email protected]

Postal address: LUMY.MEDIA SAS with share capital of 2,000 € RCS Brest B 889 608 790 Quai de la Douane, Building LE GRAND LARGE 29200 Brest, France

Phone: 02 55 99 59 78

Customer support hours: Monday to Friday: 9:00 AM - 6:00 PM (Paris time, GMT+1/GMT+2) Saturday and Sunday: Closed (except emergencies reported via [email protected])

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Document written and updated on October 6, 2025. Version 1.0