European and United Kingdom Data Subject Privacy Notice

If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below. For a description of the type of third parties to which we disclose Personal Data, and the purposes for which we do so, please refer to the general Privacy Policy.

If you are a resident of the European Union ("EU"), United Kingdom (“UK”), Lichtenstein, Norway, or Iceland, you may have additional rights under the EU or EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below. For a description of the type of third parties to which we disclose Personal Data, and the purposes for which we do so, please refer to the general Privacy Policy.

For this Privacy Notice, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with Threads.

Where applicable, this Privacy Notice is intended to supplement, and not replace, the Company's Privacy Policy at https://threads.com/privacy (the "Privacy Policy"). If there are any conflicts between this Privacy Notice and the Company's Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at privacy@threads.com.

Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

We retain Personal Data about you as necessary to provide you with Threads or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in a de-identified or aggregated and de-identified form where that information would not identify you personally. If you have any questions about data security or retention, please contact us at security@threads.com. If you share Personal Data through a Threads organization, that shared Personal Data will be retained by the third-party administrator in accordance with that organization’s data retention policies.

For example:

We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Data we process or use.

Please note that while we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by emailing privacy@threads.com.

We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for Threads or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@threads.com.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with Threads. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

Examples of these legitimate interests include:

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of yourself or other data subjects, or if it is necessary for a task carried out in the public interest.

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@threads.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Threads is hosted and operated in the United States (“U.S.”), and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using Threads, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Threads in the U.S. and will be hosted on U.S. servers, and you authorize Threads to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

While the Privacy Shield is no longer a valid basis on which Threads may rely to transfer Personal Data from the EU to the U.S. pursuant to the GDPR, Threads continues to comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU and Switzerland to the U.S., respectively. For more information about the Privacy Shield Program, and to view Thread’s certification, please visit www.privacyshield.gov Threads is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU and Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage).

Threads compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Please contact us at {Email} with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we

have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the U.S. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

Jack Baylor, based in the Republic of Ireland, has been appointed as our representative in the EU pursuant to Article 27 of the GDPR.  He can be contacted at: Jack Baylor, 2 Ashton Place, Gardiners Hill, Cork, Ireland

If you have any questions about this Privacy Notice or our data practices generally, please contact us using the following information:

Name: Threads - Privacy

Physical Address: 2261 Market Street #4898 San Francisco, CA 94114

Email Address: privacy@threads.com

Designated representative and contact information: J.M. Doerr, 2261 Market Street #4898 San Francisco, CA 94114