1. Accountability and Contact Information

Visaro is responsible for personal information under its control. We have designated a Privacy Officer to oversee our privacy practices, respond to questions and complaints, and handle access or correction requests.

2. Scope

This Policy applies to personal information that we collect through:

• our website and online forms;
• our online booking, scheduling, order-management, payment, media-hosting, and delivery processes;
• email, SMS, telephone, voicemail, and customer-support communications;
• on-site photography, videography, floor-plan, drone, and related media services; and
• analytics, advertising, and customer-relationship tools used in connection with our website and services.

This Policy does not apply to information that is not personal information under applicable law, or to third-party websites and services that operate independently under their own privacy policies.

3. Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of information.

3.1 Contact and account information

This may include your name, business or brokerage name, job title, email address, telephone number, account credentials, communication preferences, and information used to identify or administer your customer account.

3.2 Booking and order information

This may include the property address, property type and size, appointment date and time, selected package and add-ons, access instructions, lockbox or entry information, preferred photographer, listing status, special instructions, service-area zone, promotional code, order history, and related customer-service notes.

Please do not include unnecessary sensitive personal information in access instructions, special instructions, or other free-text fields.

3.3 Payment and transaction information

Payments are processed by an authorized third-party payment processor, currently Stripe, or through the payment tools integrated with our booking platform. We may receive transaction identifiers, payment status, billing contact information, invoice information, amounts, taxes, refunds, disputes, and limited card-related information such as card brand and last four digits. We do not receive or store complete payment-card numbers on our own systems.

3.4 Communications and call information

We may collect emails, SMS messages, contact-form submissions, support requests, call logs, telephone numbers, dates, times, duration, voicemail messages, and voicemail transcripts.

Live calls answered by a person are not currently recorded as a standard practice. Voicemail messages may be recorded and automatically transcribed. If we introduce or enable an AI-assisted telephone receptionist or call-recording feature, calls handled through that feature may be recorded, transcribed, summarized, or analyzed to respond to inquiries, assist with bookings, improve customer service, and maintain business records. Where required, callers will receive notice and an opportunity to decline or use another contact method.

3.5 Property and media information

This may include photographs, video, audio captured as part of a requested production, drone footage, floor plans, measurements, virtual-tour content, property features, visible addresses, and information incidentally visible or audible at a property. Media may contain personal information if it identifies an individual or reveals personal belongings, documents, security systems, family information, vehicle plates, artwork, or other identifying details.

The client is responsible for preparing the property and removing or concealing items that should not be photographed or recorded, as further described in our Terms of Service.

3.6 Website, device, and advertising information

When you use our website, we and our service providers may collect IP address, approximate location derived from IP address, browser and device type, operating system, language, pages viewed, links clicked, referring page, date and time, session information, cookie identifiers, advertising identifiers, and interactions with our advertisements or website.

We may receive campaign information such as a Google Click Identifier ("GCLID"), UTM parameters, referring source, and conversion events, including calls, form submissions, booking-page visits, or completed orders when technically available and configured.

3.7 Information from other people or organizations

We may receive information from a brokerage, agent, property owner, occupant, assistant, referral partner, or another person arranging services. If you provide personal information about another person, you represent that you have authority to provide it and have given any notice or obtained any consent required by law.

4. How We Collect Information

We collect information:

• directly from you when you book, pay, call, email, submit a form, create an account, or communicate with us;
• automatically through cookies, pixels, tags, server logs, and similar technologies;
• from clients, brokerages, agents, property owners, occupants, or representatives who arrange or manage a service;
• from payment, booking, communications, analytics, advertising, and media-delivery service providers; and
• from publicly available sources where permitted by law.

5. How We Use Personal Information

We may use personal information to:

• provide quotes and respond to inquiries;
• create and administer customer accounts;
• schedule, confirm, perform, reschedule, and manage services;
• verify service areas, calculate travel fees, and administer promotions;
• communicate access instructions and job details;
• process payments, deposits, travel fees, refunds, invoices, and receipts;
• edit, host, deliver, re-deliver, archive, and support media products;
• provide customer service and resolve complaints, payment disputes, or technical issues;
• send transactional email or SMS messages about appointments, orders, invoices, delivery, account activity, and service updates;
• send marketing communications where we have the consent or other lawful authority required by CASL;
• operate, secure, troubleshoot, personalize, and improve our website and services;
• measure website use, advertising performance, leads, calls, and conversions;
• prevent fraud, misuse, security incidents, and unauthorized access;
• maintain tax, accounting, consent, contractual, and compliance records;
• establish, exercise, or defend legal claims; and
• comply with applicable law, regulatory requirements, court orders, and lawful requests.

Where property media is used in our portfolio, website, social media, advertising, educational materials, or demonstrations, that use will be governed by our Terms of Service, any applicable consent, and any timely confidentiality request accepted by us.

We will not use personal information for a new purpose that is materially different from those described in this Policy without providing notice and obtaining any consent required by law.

6. Consent and Your Choices

We seek meaningful consent appropriate to the sensitivity of the information and the reasonable expectations of the individual. Consent may be express or implied where permitted by law. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may prevent us from providing a feature or service that depends on the information.

The following choices are treated separately where applicable:

• acceptance of the Terms of Service and acknowledgment of this Privacy Policy;
• consent to receive marketing email or SMS messages;
• preferences for non-essential analytics or advertising cookies;
• authorization or confidentiality choices relating to portfolio and promotional use of property media; and
• consent to call recording or AI-assisted call processing where required.

We do not make optional marketing consent a condition of purchasing our services.

7. Email and SMS Communications

We may send service-related messages needed to administer an inquiry, booking, appointment, payment, delivery, or customer account. These transactional messages are distinct from promotional messages.

We send commercial electronic messages only where permitted by CASL. Marketing messages will identify the sender and include an unsubscribe mechanism. You may unsubscribe from marketing email using the link in the message. You may opt out of marketing SMS by replying STOP or contacting us. We will process unsubscribe requests within the period required by law, although you may continue to receive necessary transactional or legally required messages.

We retain records of consent and unsubscribe requests where reasonably necessary to demonstrate compliance. We do not sell or rent SMS consent records or telephone numbers for another organization's independent marketing.

8. Cookies, Analytics, and Advertising Technologies

Our website uses cookies and similar technologies for essential website functions, security, preferences, analytics, advertising measurement, and campaign attribution. These technologies may recognize a browser or device over time and across websites.

Depending on our current configuration, service providers may include Google Analytics, Google Ads, Meta technologies, and HubSpot. These providers may receive device, browser, cookie, page-view, referral, interaction, and conversion information and may process information outside Canada under their own privacy terms.

We use:

• strictly necessary technologies to operate and secure the website;
• analytics technologies to understand website traffic and improve performance; and
• advertising technologies to measure campaigns, attribute leads or orders, build audiences, and deliver or evaluate advertising.

Where required, non-essential technologies will be controlled through a cookie preference tool and will not be activated until the required choice has been obtained. You may also adjust browser settings, delete cookies, or use platform-level advertising controls. Blocking some technologies may reduce functionality or make measurement less accurate.

Browser "Do Not Track" signals are not interpreted consistently across the industry. We respond to legally required preference signals where applicable and otherwise provide the controls described above.

9. How We Disclose Personal Information

We do not sell personal information. We may disclose information only as reasonably necessary for the purposes described in this Policy, including to:

• booking, scheduling, order-management, media-hosting, cloud-storage, and delivery providers;
• payment processors, banks, accountants, and fraud-prevention providers;
• email, SMS, telephone, voicemail, customer-support, and customer-relationship providers;
• website hosting, security, analytics, and advertising providers;
• editing, production, virtual-tour, floor-plan, drone, or other subcontracted service providers if engaged;
• a brokerage, agent, property owner, seller, assistant, or other authorized party connected with the order;
• professional advisers, insurers, auditors, or collection agencies where necessary;
• law-enforcement, regulatory, governmental, or judicial authorities where required or permitted by law; and
• a buyer, successor, or adviser in connection with an actual or proposed business transaction, subject to appropriate confidentiality protections.

Service providers are permitted to use personal information only to provide services to us or as otherwise allowed by law and their applicable agreements. Some providers may independently determine certain processing activities under their own terms, particularly payment, analytics, and advertising providers.

10. Processing Outside Canada

We use service providers that may store or process personal information in Canada, the United States, or other jurisdictions. This includes providers supporting booking, media hosting and delivery, payments, communications, analytics, advertising, cloud infrastructure, and customer support.

When information is processed outside Canada, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement, or national-security authorities in accordance with those laws. We use reasonable contractual, organizational, and technical measures appropriate to the circumstances, but we cannot prevent lawful access by foreign authorities.

Contact our Privacy Officer if you would like more information about our use of service providers outside Canada.

11. Retention and Deletion

We retain personal information only for as long as reasonably necessary for the identified purposes, legal obligations, dispute resolution, security, and enforcement of agreements.

• Booking, customer, transaction, and tax records: retained for the period required by applicable law, generally at least six years from the end of the relevant tax year, and longer where a legal hold, dispute, warranty, or other legitimate requirement applies.
• Media available through the delivery platform: completed media is generally made available through our third-party booking and media-delivery platform for approximately six months after delivery. Availability is not guaranteed beyond that period. Files may then be deleted, archived, or become unavailable without further notice.
• Customer responsibility: clients are responsible for downloading and securely backing up delivered media promptly. Long-term storage is not included unless agreed in writing.
• Portfolio and business records: selected media lawfully retained for portfolio, promotional, licensing, quality-control, dispute, or evidentiary purposes may be kept longer than the general delivery period.
• Communications and consent records: retained as reasonably necessary to administer services, document consent or withdrawal, handle complaints, and meet legal requirements.
• Voicemail, call, and AI-assisted records: retained only as reasonably necessary for customer service, booking, quality, security, and legal purposes, then deleted or de-identified in accordance with our retention practices.

When information is no longer required, we take reasonable steps to securely delete, destroy, or de-identify it. Backup copies may remain for a limited period until overwritten through normal backup cycles.

12. Safeguards and Privacy Breaches

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information. Measures may include access controls, account authentication, encryption in transit, payment-card processing by PCI-compliant providers, restricted access, vendor assessment, software updates, backups, and staff or contractor confidentiality requirements.

No system is completely secure. If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and report the breach to the appropriate privacy authority as required by law. We maintain records of security breaches for the legally required period.

13. Access, Correction, and Other Privacy Rights

Subject to applicable exceptions, you may request:

• access to personal information we hold about you;
• information about how it has been used and disclosed;
• correction of inaccurate or incomplete information;
• withdrawal of consent;
• deletion or de-identification where we are not legally or contractually required to retain the information; and
• information about our policies, service providers, and cross-border processing.

To make a request, contact our Privacy Officer. We may need to verify your identity before responding. We will respond within 30 days, unless a lawful extension applies, and will explain any refusal or limitation permitted by law. We may charge only a reasonable fee permitted by law and will notify you in advance if a fee applies.

14. Privacy of Property Occupants and Other Individuals

Our client may not be the property owner or occupant. The client is responsible for having appropriate authority to arrange access and the requested media services and for notifying owners, occupants, tenants, guests, employees, or other affected individuals where required.

Before a shoot, clients should remove or conceal personal documents, family photographs, medication, financial information, alarm codes, keys, computer screens, vehicle plates, children's information, and other sensitive or identifying items that should not appear in the media. If you identify a privacy concern in delivered media, contact us promptly so we can evaluate reasonable corrective steps.

15. Children and Minors

Our website and services are intended for adults and business users. We do not knowingly collect personal information directly from children for account creation or marketing. Children or other individuals may be incidentally present in property media only where the client has arranged the necessary permission. If we learn that personal information about a child was collected without appropriate authority, we will take reasonable steps to delete or restrict it.

16. Third-Party Websites and Services

Our website, booking process, or delivered media may link to or rely on third-party services. Their handling of information may be governed by their own privacy policies and terms. We are not responsible for independent third-party practices that are outside our control, but we remain accountable for personal information under our control as required by law.

17. Changes to This Policy

We may update this Policy to reflect changes in law, technology, service providers, or business practices. The "Last updated" date identifies the current version. If a change is material, we will provide additional notice where appropriate and obtain new consent where required. Changes do not retroactively authorize materially different uses of personal information without any consent required by law.

18. Questions and Complaints

Contact our Privacy Officer first if you have a question, request, or complaint. We will investigate and respond in a fair and timely manner.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca.