Privacy policy

1. Who we are and who this covers

This policy explains how Brakket Technologies Ltd. (“Brakket”, “we”) handles personal information. We are a Canadian business and follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and the provincial privacy laws that apply to us, including Quebec's private-sector privacy law.

It covers three groups of people:

• Studios: photographers and media businesses who hold a Brakket account, and their team members.
• Clients: the agents and others who book or receive media from a studio through Brakket.
• Property owners and occupants: people whose homes appear in media a studio uploads.

When a studio uses Brakket to serve its clients, the studio decides what client information is collected and why, and Brakket handles that information on the studio's behalf as its service provider. For that information, the studio's own privacy practices also apply.

The person responsible for privacy at Brakket is [Name or title of privacy officer], who can be reached at [privacy email].

2. What we collect

• Account details: name, studio name, email address and a password, which we store only in hashed form.
• Booking details a studio collects: a client's name, email, phone number and brokerage, the property address, square footage and access notes such as lockbox codes.
• Media: the photos, video and files a studio uploads, and technical details stored in them such as dimensions. Photos of a property can show the inside of someone's home.
• Payment information: handled by Stripe or Square. We receive confirmation that a payment was made and limited billing details. We never receive or store full card numbers.
• Messages: a record of the emails the service sends on a studio's behalf.
• Usage and device information: pages visited, actions taken, IP address and browser type.
• Cookies: a cookie that keeps you signed in, and short-lived cookies needed to connect a payment account. We do not use advertising or cross-site tracking cookies.

We collect this information directly from you, from the studio you deal with, and automatically when you use the service.

3. Why we use it

• To provide the service: take bookings, schedule shoots, deliver media, publish property websites and process payments.
• To send service messages about a booking, delivery or payment.
• To keep accounts secure, prevent misuse and fix problems.
• To understand how the service is used so we can improve it.
• To train and improve our image-editing and AI tools, as described in the box below.
• To meet our legal and tax obligations and to handle disputes.

We do not use personal information to make decisions about people by automated means alone.

4. Consent

We rely on your consent to collect, use and share personal information, which you give when you create an account, make a booking or otherwise give us information, and which is implied where the purpose is obvious and you provide the information voluntarily. You may withdraw consent at any time, subject to legal or contractual limits and reasonable notice. If you do, we may not be able to provide some or all of the service.

5. Who we share it with

We do not sell personal information. We share it only with:

• The studio and its clients, as needed to complete a booking or delivery.
• The public, only for a property website that a studio has chosen to publish.
• Service providers who work for us under contract and may use the information only to provide their service: payment processors (Stripe, Square), hosting and storage providers, and our email provider.
• Authorities, where the law requires or permits it, or to protect people's rights and safety.
• A successor, if Brakket is sold, merged or reorganised, under protections at least as strong as these.

6. Where it is stored

Our service providers may store and process information outside your province and outside Canada, including in the United States. While it is in another country, it is subject to that country's laws and may be accessible to its courts and authorities. We require our providers to protect it to a standard comparable to this policy.

7. How long we keep it and how we protect it

We keep personal information only as long as needed for the purposes above. Account and order records are kept while the account is open and for up to seven years afterwards for tax, legal and dispute purposes. Media may be removed from the live service 30 days after an account closes. Media retained for model training and reference may be kept longer, as described in our Terms.

We protect information with safeguards suited to its sensitivity, including encrypted connections, hashed passwords, encryption of stored payment-account tokens, and limits on who can access what. No system is perfectly secure. If a breach creates a real risk of significant harm, we will notify the people affected and the Privacy Commissioner of Canada, and any provincial regulator where required, and we keep a record of every breach.

8. Your rights and choices

You have the right to:

• ask whether we hold personal information about you and to see it;
• have inaccurate or incomplete information corrected;
• withdraw your consent to our use of it;
• where the law provides, receive a copy in a commonly used format, and ask that it no longer be disseminated; and
• complain about how we have handled it.

To make a request, write to [privacy email]. We may need to confirm your identity. We will respond within 30 days, or tell you if we need longer and why. There is no charge for a reasonable request.

• Clients of a studio: the studio controls your booking information, so it is usually the best place to start. We will pass on any request we receive.
• Property owners and occupants: if media of your home is on Brakket and you want it removed from the service or excluded from model training, write to us with the property address. We will act on your request and work with the studio where needed.
• Studios: you can turn off AI training use in your dashboard at any time.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada, or the privacy regulator in your province, such as the Commission d'accès à l'information du Québec.

9. Email

We send messages about your account and about bookings, deliveries and payments. These are part of the service and are not marketing. If we send you promotional email, it will be with your consent as required by Canada's anti-spam legislation (CASL), will identify us, and will include a way to unsubscribe.

10. Children

Brakket is a business tool and is not intended for anyone under 18. We do not knowingly collect information from children.

11. Changes and contact

We may update this policy and will post the new version here with a new date. For significant changes we will notify account holders directly before the change takes effect.

Privacy questions, requests or complaints: [Name or title of privacy officer], [privacy email], or by post to Brakket Technologies Ltd., [Mailing address].