We are a photo and video booth software provider with offices (at the time of writing) in Canada.

For the purposes of applicable data protection law, Algoritmo Software Inc., is communicating with you, is responsible for this Policy and, to the extent relevant to applicable data protection law, is the controller of your personal information. In the context of an event, we may be acting as a processor on an Account Holder's behalf. Please do consult your Event Holder's privacy policy in addition to this one in such circumstances.

U.S. Residents: If you reside in the United States, please also see our US Annex below for your rights under applicable U.S. privacy laws, including but not limited to the California Consumer Privacy Act.

We will use the following terms regularly in this Policy. Here is what we mean when we use them here:

"Account Holder" means the individual or business that creates an account via the Website and/or in the context of using our Services. This includes those who use the Services on a "white label" basis within their own product.

"Client" means the business or individual for whom the event is being run. This may be the same entity as the Account Holder using the Services directly, or they may have agreed with the Account Holder to run their event, with the Account Holder using the Services on the Client's behalf.

"Personal Information" means any information that: (i) identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household; (ii) relates to an identified or identifiable natural person. An identifiable natural person, is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person.

"Photo Subject" means an individual captured within photos or videos.

We use different methods to collect information from and about you including through:

• Information you give us. This is information that you provide by accessing our Website and/or Services (including by being a Photo Subject), or by corresponding with us (for example by email or chat). It includes information when you register, download and/or subscribe to our Website and/or Services, make an order and when you report a problem with our Website and/or Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit our Website or use our Services we will automatically collect personal information including device, content and usage data. We collect this data using cookies and other similar technologies. As you interact with our Website, we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and/or
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources. We may receive information about you from various third parties as set out below:
  • Device data from analytics providers, advertising networks, search information providers;
  • Contact, financial and transaction data from providers of technical, payment and delivery services; and/or
  • Social media providers to the extent you allow (as a Photo Subject or Account Holder) access to your account for the upload of photos captured using the services.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal data in law if this data is anonymized so that it cannot directly or indirectly reveal your identity. For example, we may aggregate certain of your usage data to calculate the percentage of users accessing a specific Website feature. However, where we are able combine or connect aggregated data with your personal information so that it can still directly or indirectly identify you, the combined data remains personal information which will be used in accordance with this Policy.

The amount and type of information that we collect about you depends on the nature of your interaction with our Website and Services. We collect information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with us. Our use of Personal Information will vary depending on whether you are visiting our website, using our Services as an Account Holder, or interacting with our Service as a Photo Subject. The below table sets out the kinds of Personal Information collected:

We use your information for the purposes identified in this Policy at the time of collection or for a purpose related thereto, including to develop and provide the Website and Services. We will only use your Personal Information when the law allows us to do so. We will use your Personal Information for the following purposes:

We may also use automated decision-making (ADM). ADM is when a decision is made based solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. Automated processing is a form of automated processing of personal data to evaluate certain aspects relating to you, in particular to analyse or predict aspects concerning your personal preferences, interests, behaviour, location or movements. We only do this in the context of advertising shown in connection with Google Ads and the Google conversion tracking tool, with the practical effect being whether or not one of our adverts is shown to you as opposed to a different advertisement. Such processing is subject to Google privacy policies, including as set out here.

Opting out

Visitors to our site can set preferences for how Google advertises to you and tracks your conversions using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

Your withdrawal may restrict our ability to provide the Website and/or Services. There are limited circumstances in which we may collect, use or disclose personal information without your consent. They include but are not limited to: a) when the collection, use or disclosure of personal information is permitted or required by law; b) in an emergency that threatens an individual's life, health or personal security; c) when we require legal advice from a lawyer; e) for the purposes of collecting debt; f) to protect ourselves from fraud; or g) to investigate an anticipated breach of an agreement or a contravention of law.

We may disclose personal information to fulfill the purposes identified in this Policy, and for purposes related thereto, and to provide the Services, including as follows:

• within our organization, including with our affiliates particularly where necessary for product development, maintenance, and compliance purposes;
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including:
  • analytics and search engine providers that assist us in the improvement and optimisation of our Website and/or Services;
  • facilitate payment processing;
  • third parties to whom we may choose to, or with whom we are considering to, sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy; and/or
  • We reserve the right to disclose personal information if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with legal process, enforce our Terms of Use, respond to claims, or to protect the rights, property or safety of Algoritmo Software Inc., our affiliates, service providers, or the public.

We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We also take into account legal and regulatory requirements which require the retention of personal information for a minimum period of time, limitation periods for taking legal action, good practice and our general business purposes.

Specifically, with respect to biometric information (including face data processed for photo and video capture, enhancement, or tagging purposes):

• We retain such data for a maximum period of 2 years from the date of collection to allow event guests to continue accessing and browsing public event galleries and media shared through our platform. An Account Holder may instruct us to hold the data for a maximum of two additional years.
• Face data is processed solely for the intended use within the event experience and is not used for identity verification or any unrelated purpose.
• After the 2-year period, (and any additional period instructed by the Account Holder), this data is securely deleted or anonymized.

If you would like your biometric data removed sooner, you may request deletion at any time by contacting us at info@snappic.com.

Access to the Website and/or the Services may be provided using resources and servers located in various locations, including the United States. Therefore, personal information about you may be transferred, processed, and stored outside the country where the Website and/or Services are used.

We transfer your Personal Information to third parties who provide services to us (for example data storage providers) including in some cases those who are situated outside of the European Economic Area (EEA), The United Kingdom (UK) or Switzerland. In particular, we use storage providers situated in the United States of America and transfer Personal Information to them.

We ensure that an equivalent degree of protection is implemented by only transferring Personal Information to countries with adequate data protection regimes or using appropriate safeguards, such as specific contracts approved by the European Commission or UK government (as applicable) which give Personal Information the same protection it has in the UK, the EEA, or Switzerland (e.g. European Commission: Standard contractual clauses for international transfers and the UK International Data Transfer Agreement or Addendum) or any data transfer mechanism approved by the European Commission or the UK authorities as appropriate, such as the EU-US Data Privacy Framework and the UK-US Data Bridge.

Please contact us if you want further information on the specific mechanisms used by us when transferring your Personal Information out of the EEA, UK or Switzerland.

We have put in place appropriate technical, organisational and security measures designed to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Any payment transactions carried out by us or our third party provider of payment processing services will be encrypted via Secure Socket Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website and/or our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where appropriate or where we are legally required to do so.

Our Website and Services are not designed for use by minors (persons under the age of 18 or under a lower age if restricted by the laws of their residence). Children are not permitted to be Clients or Account Holders. The Personal Information of children may be captured to the extent they are Photo Subjects. The handling of children's Personal Information is to be managed by parents or guardians as Account Holders and/or by Clients.

If you are aware that a minor has provided us with personal information, as an Account Holder or a Client, please contact us at info@snappic.com. If it comes to our attention that we have collected Personal Information from a minor, we may delete this information without notice.

What are "cookies" and do we use them?

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow it to do so) that enables the site's or service provider's systems to recognise your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of any e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

We use Microsoft Clarity, a user behavior analytics tool that helps us understand how users interact with our website and services. Clarity captures anonymized data such as mouse movements, clicks, scrolling, and interactions on our website. This information helps us improve our user experience and interface design.

Clarity uses cookies and other tracking technologies to collect this information. Data collected is processed by Microsoft in accordance with Microsoft's Privacy Statement.

You can opt out of Clarity by using standard cookie consent settings in your browser or through tools like Your Online Choices or Network Advertising Initiative.

Can I disable cookies?

Yes. You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser's (like Google Chrome) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify and/or disable your cookies.

Please note however that if you disable cookies in your browser some of our website's features that make your site experience more efficient may be disabled and some of our services may not function properly. You will however still be able to place orders through the Website.

This website and our Services may include links to third-party websites, plug-ins and applications, partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Accordingly, we have no responsibility for the content and activities of these linked sites and hereby disclaim any and all liability of any nature whatsoever and howsoever arising which may arise from the products and/or services procured from such third parties. Nonetheless, we seek to protect the integrity of our site and welcome any feedback our site visitors may have about these sites and their content.

If you are in Canada, we will not collect, use, or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing us with Personal Information to use our services as an Account Holder or a Photo Subject is implied consent to use such information. We will assume that you have consented to its reasonable collection and use of Personal Information consistent with the purposes for which the information was given.

You have certain rights depending on which Data Protection Laws apply to you in relation to your Personal Information. When provided for, and subject to limitations set forth, in applicable Data Protection Laws, you can:

• Access. To request a copy of the Personal Data we have collected about you by contacting us.
• Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
• Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
• Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.
• Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
• Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services.
• Right to Lodge a Complaint with a data protection authority. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority.

Your rights under other data protection laws may be similar or different to those above.

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your Personal Information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

To exercise any of the above listed rights, please contact us as set forth in section 13 and provide sufficient details so that we can respond appropriately – submitting your request in another way will make it harder for us to identify and respond to it. We will process any requests in accordance with applicable law and within a reasonable period of time (we aim to process all requests within thirty (30) days or provide notice if we require longer). We may need to verify the identity of the individual submitting a request before we can address such request. To the extent permitted by applicable law, fees may be charged to access information, but you will be notified of such in advance so you can choose whether or not to proceed.

If you have any questions about this Policy, need to exercise your rights, or wish contact us for any other purpose related to your Personal Information, please contact us by email at: info@snappic.com.

Algoritmo Software Inc.
222 Bay Street
Toronto, Ontario
M5K 1E7

This Policy is effective as of the date listed at the top of this page.

We review this Policy regularly and have the discretion to update this Policy at any time. You can verify if this Policy has changed by checking the last updated date that appears at the beginning of this Policy. We encourage you to frequently check this page for any changes to stay informed about our practices with respect to the collection, use, disclosure and protection of the Personal Information we collect.

We may, but are not obligated to, provide you with notice in case of any material changes made to this Policy. Your continued use of the Website and/or Services after any changes in this Policy will constitute your acceptance of such change.

Applicable laws may give you additional rights that are not described in the Policy.

The US Annex of this Policy has been compiled for the benefit of those visitors to our website and/or customers who are concerned with how their Personally Identifiable Information ("PII") is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read the Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle the PII which we obtain from your visits to our website and/or use of our products.

1. What PII do we collect from the people that access our Website and/or Services?

This is set out at Section 2 of the Policy.

2. When do we collect PII?

This is set out at Section 1 of the Policy.

3. How do we use the PII which is collected?

This is set out at Section 3 of the Policy.

4. How do we protect PII?

This is set out at Section 8 of the Policy.

The following table explains as required by California privacy laws whether we have collected, disclosed or sold certain categories of PII in the past 12 months. We do not sell PII in the dictionary definition of the word (i.e. we do not receive money from any party in exchange for providing them with PII).

However, certain data collection on our Website and via our Services by third parties for purposes of interest-based advertising and social media tools may be a "sale" or "sharing" under California privacy law.

Where the table below says we have sold or shared categories of PII, we will have only have done so in the context of data collection for the purposes of interest-based advertising, as set out at Section 3 of the Policy.

Your Rights: You have the right to request that we disclose to you what information we collect, use, disclose, and sell. You also have the right to request that a business delete any PII about you which the business has collected about you. To submit either of the above requests, you may call us toll-free at (833) 670-9797. You may also submit via email at info@snappic.com. Please note for your protection, any request sent to us to delete your PII will be subject to the following verification procedure: Customers must provide their Snappic login email address and user name, and provide explicit consent that they would like their account and all associated data permanently deleted. You have the right to direct us to not sell your information.

If you opt to exercise your privacy rights, we are required to verify your identity in order to prevent unauthorized access of your data. This may require us to ask you certain questions to confirm your identity or require you to provide state-issued identification. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of the reasons we are unable to honor your request.

Right to Know and Access Information: You may access information we maintain about you using the methods provided below. If we grant your request, we will provide you with a copy of the PII we maintain about you in the ordinary course of business. This may include what PII we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law.

Deletion of Information: You may request that we delete your PII. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in our business records. You may submit a deletion request using the methods provided below.

We shall not discriminate against you for exercising any of your above rights.

You may designate an authorized agent to make a request to exercise your rights on your behalf. For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.

5. Do you disclose the PII you collect to Third-Parties?

We do share certain of the PII gathered from Photo Subjects who open an account with the relevant Account Holder. The PII which is shared in this regard includes a user's name, screen name or user names, phone number and/or email address. These details are made available to the Account Holder for download so that they can have a better understanding of what demographic has attended their event. Please note however that this PII is only shared with the Account Holder if the user of our Services has consented to such information being shared.

6. Does our website allow third party behavioural tracking?

We do allow third-party behavioural tracking for Data Analysis and Optimisation as set out in Section 3 above. By default, this is done on the basis of aggregated or anonymised data.

7. COPPA (Children Online Privacy Protection Act)

When it comes to the collection of PII from children under 13, the Children's Online Privacy Protection Act ("COPPA") puts parents in control. The Federal Trade Commission, the United States of America's 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.

In compliance with the provisions of COPPA, we do not specifically market our products to children under the age of 13.

Fair Information Practices Principles

The Fair Information Practices Principles form the backbone of privacy law in the United States of America and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect PII.

In order to be in line with the Fair Information Practices Principles, should a data breach occur we will notify the affected parties of such data breach via email within seven business days of such data breach occurring.

We also agree to the Individual Redress Principle which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

8. CAN-SPAM Act

The CAN-SPAM Act is a law that:

• sets the rules for commercial email;
• establishes requirements for commercial messages;
• gives recipients the right to have emails stopped from being sent to them; and
• spells out tough penalties for violations.

To be in accordance with the CAN-SPAM Act we agree to the following:

• we will NOT use false or misleading subject lines or email addresses in any communications with you;
• in the event that our message to you is an advertisement, we will identify the message as an advertisement in some reasonable way;
• we will include the physical address of our business or site headquarters in all communications with you; we will monitor third party email marketing services for compliance with the CAN-SPAM Act, if such third party email marketing service is used;
• we will honour opt-out/unsubscribe requests quickly; and we will allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails from us, you can email us at info@snappic.com and we will promptly remove you from ALL correspondence.