Privacy Policy

RECURRENT VENTURES

PRIVACY POLICY

Last Updated and Effective Date: January 26, 2023

Introduction

Recurrent Ventures Inc., together with its subsidiaries and its affiliates, (“Recurrent,” “us,” “we,” or “our”) offers digital media services through a variety of online offerings (our “Websites”). This Privacy Policy applies to the websites which link to this policy and explains how Recurrent collects, uses, and discloses information about you when you visit our Websites or otherwise interact with us. Note that this Website and some of our applications may have supplemental terms which would govern in the event of a conflict with this Privacy Policy.

Our privacy practices are subject to the applicable laws of the places in which we do business, so we have added region-specific terms that only apply to customers located in certain geographic regions, or as required by applicable laws.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). Your continued use of the Website or Services following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

This Privacy Policy includes the following sections:

  1. Scope of This Notice

This Privacy Policy describes Recurrent’s practices for collecting, using, maintaining, protecting, and disclosing (“processing”) your personal information when you use our Services, which include when you:

  • Visit our Websites and any other sites or applications that link to this Privacy Policy.
  • Create and maintain an account with us.
  • Make a payment through us.
  • Make a purchase or other transaction with us.
  • Subscribe to or engage with our newsletters or other electronic communications.
  • Interact with our social media pages.
  • Click on our ads posted on third party sites.
  • Communicate with our service representatives or features (including via chat functions, email, text, or phone).
  • Otherwise interact with us.

 

This Privacy Policy also applies to personal information we collect from third parties about you.

 

This Privacy Policy does not apply to:

  • Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us, including social media services. We do not endorse any other websites and providers by providing such links, and our Privacy Policy applies only to your use of our Websites and Services. We are not responsible for the privacy policies of any websites and services we link to on our Website, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.
  • Workforce Members and Candidates. Our processing of the personal information of job applicants/candidates and workforce members is not governed by this policy.
  • Non-personal information. Our processing of information that cannot be linked to an identifiable or identified individual, including non-identifying aggregate information. We may process this data for any legitimate business purpose.
  1. Personal Data We Collect and How We Use It

Personal information (sometimes called “personal data”) is a broadly defined term whose legal definition varies across jurisdictions. When used in this Privacy Policy, “personal information” includes information that is reasonably capable of identifying a particular individual (including through their device) either alone or when combined with information from other sources.

The personal information we collect about you depends on the nature and context of your interaction with our Recurrent and our Services.  It may also depend on various choices you make about how to use the Services we offer, the functionality and features you choose or enable, your location, the devices you us to interact with our services, and applicable law.  The following describes the personal information we collect about you and the way we collect it.

  • Personal Information You Give to Us

We collect the following categories of personal information you provide to us, including the following:

  • Your personal details like your first and last name, email address, phone number, physical address, zip code, gender, job application information, and other contact information you provide.
  • Account and other identifiers like a username, screen name, handle, account ID, assigned user ID, customer number, or similar identifier that can be used to identify and user or account. We may also collect your consent to collect cookies.
  • Marketing and communications data. For example, your preferences in receiving marketing from us.
  • User content. For example, emails and text messages, photos, videos, audio recordings, customer support communications, comments/feedback, and any other content submitted or posted by you.
  • Survey data. We may contact some individuals to request participation in a survey, competition, promotion, or other general research. If you choose to take part in these, you may provide personal information, in or along with your survey responses, or in any other feedback or comments you give us. Through some features of the Services and through certain promotions, you may also submit information about other people. For example, you might submit a person’s name, mailing and/or e-mail address to send a gift or electronic greeting card.
  • Contests, sweepstakes, and prize drawings data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide personal information, feedback, or comments to enter, or as part of the contest, sweepstakes, or prize drawing.
  • Messages and email data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Services, including whether you have opened or acted on those communications.
  • Social media content. For example, interactions with social media providers, including content you post on our social media pages. If you use a social media provider to register or log into your Recurrent account, we will receive your personal information from them.
  • Other personal information you provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
  • Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you.
  • Chat modules. We may collect certain categories of personal information from you when you use our interactive chat module. By interacting with the chat box, you consent to our collection practices and understand and acknowledge that we may use this data to communicate with you about our products and services.
  • Payment processing information. For example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.
  • We can gather or infer your geolocation based on certain identifiers, you’re your IP address or mailing address. We use this information in part to determine which legal jurisdiction is applicable to you and your dealings with us. You may choose to grant our Services permission to access your device’s precise geolocation, which we may use to confirm your address and help us operate or personalize our Services, including by tagging posts, providing information on or adding information to a map, and helping us show you more relevant content or ads.
  • Personal Information We Derive Through Your Use of Our Services

We may allow others to provide analytics services and serve advertisements on our or their behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your visits to websites that use our Services and other websites and applications, This information may be used by Recurrent and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. Please review the “Your Privacy Preferences” section of this Privacy Policy to learn more.

The information we collect using these technologies includes:

  • Device and browser identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device.
  • Coarse location Information. A general approximation of your location that is not based on global position system (GPS) information.
  • Browsing and search history. Information about the content you view and searches you make on our Website(s).
  • Real-time website interactions. We or our service providers may capture and record your real-time interaction with our Websites, such as mouse movements, clicks, and user inputs, in a video format to provide insight into what works and what doesn’t work for users of the Website and/or platform and to identify and repair technical errors such as broken links that impair the website’s functionality.
  • Website log and usage data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type, and details about any links or communications with which you interacted.
  • Advertising and event metrics. Information about the advertisements you have viewed and your interactions with our Websites.
  • Video watching history. We may record your video-watching history on our Websites, including the description of the videos you have viewed, and share them with third parties.
  • Personal Information We Collect From Others

We mostly collect personal information directly from you or based on your interaction with our Websites, but we may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, and publicly available sources. Additionally, if you create or log into your account through a social media site or third-party service (like Facebook or Google), we will have access to certain information from that service, such as your name, email address, and profile picture, in accordance with the authorization procedures determined by such social media site or third-party service.

Even if you are not a registered user of our Services, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. Users may also post or comment with personal information about other users (though we discourage it).

  1. What We Do with Your Personal Information

We may use your personal information for a variety of reasons. Depending on how you interact with our Services, these include using personal information for:

  • Delivering our services to you, including providing the related customer support, communication, and security, sending your newsletters to which you have subscribed, adding you to our mailing lists, sending you communications about changes to your account and our Websites’ and services’ terms or policies, and allowing you to sign up for special offers from third parties through our Websites and Services.
  • Policy enforcement, including enforcing our terms of service, acceptable use policies, anti-spam policies, and similar policies.
  • Advertising and marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing testing, research and data analytics, product development, and perform similar activities.
  • Contextual and behavioral targeting to provide contextual customization of ads shown as part of an interaction with our Website or application, using tracking technologies like cookies and pixels, and to enable Website features such as geographically-specific pricing or logging.
  • Counting ad impressions and website interactions to audit interactions with our Websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
  • Customer service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
  • Fraud prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • Processing transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility, promotional benefits, and perform similar activities.
  • Public health and safety to conduct screening or temperature checks for COVID-19 symptoms or similar screening activities related to public health and safety.
  • Defending against claims and litigation to investigate, defend against, or respond to potential or actual disputes, claims, and litigation.
  • Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Determining employment eligibility to determine eligibility for employment, verify references and employment history, and conduct background checks.
  • Claims and benefits administration to process claims and administer benefits in accordance with applicable laws.
  • Employee and emergency contact communications to communicate with our employees or individuals listed as an employee’s emergency contact.
  • Reorganization, purchase, and sales activities to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about our Website users is among the assets transferred.
  • Other reasons described to you at the point of collection of your information or as otherwise set forth in the CCPA.
  1. Our Sharing of Your Personal Information

Besides using your personal information ourselves, we may share your personal information with the following:

With the parties whom you authorize. If you consent to or authorize us to share personal information with third parties.

Business services providers. These are those persons or entities with whom we have a relationship to provide business operations services and support. These providers may include the following:

  • IT operations providers. These include cloud computing service providers, website hosting providers, customer service providers, email delivery services, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
  • Operations providers. These include service providers with whom we partner to provide day-to-day business operations, including payment processors (like Stripe and Shopify), security vendors, business software service providers, banks, and others.
  • Professional advisors. These include lawyers, accountants, auditors, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

Marketing and advertising providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar service providers.

 

Affiliates. Between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

Legal compliance parties. Persons to whom we believe it is necessary or appropriate to provide information, such as pursuant to a subpoena or a court order, to respond to requests from public and government authorities including public and government authorities outside your country of residence, to enforce our Terms and Conditions, to protect our operations, to protect our rights, privacy, safety or property, and to allow us to pursue available remedies or limit the damages that we may sustain.

Reorganization. Persons involved in the consideration, negotiation, and completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

Authorized disclosures: To any party when authorized by the individual to whom it pertains to share it.

We reserve the right to use and disclose information that is non-personal Information in any manner permitted by law except as otherwise provided in this Privacy Policy.

  1. Publicly Posted Content

Recurrent users may have the ability to post content to one or more Recurrent forums or webpages, such as user-submitted pages, chat rooms, and bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.  You may request and obtain removal of such posted content by contacting us at info@photopopular.com and specifically identifying the content to be removed.  Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Recurrent forums.

  1. Data Retention

We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 unauthorized 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; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Data Security

We have implemented and maintained reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy.

  1. Our Clients

If you are a client or business partner of ours, then the contract between your company and Recurrent shall prevail over this Privacy Policy to the extent of any conflict.

  1. International Data Transfers

We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere our requirements and applicable privacy laws.

  1. Your Privacy Preferences

You can control the collection and use of personal information for some of our processing activities. This includes:

  • Adjusting Communication Preferences

Emails from Recurrent: During the registration for a Website, you should be presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, or email Recurrent at info@photopopular.com to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt you out of all emails—we may need to send you transactional or similar emails related to your Recurrent account, purchases, legal or contractual updates, or similar topics. You are not able to opt-out of these emails.

Text messages: You may opt out of automated text notifications at any time by replying “STOP,” or any alternative keyword we have shared with you. You may still receive communications from Recurrent regarding safety issues, such as messages related to your account, even if you have opted out.

  • Blocking Cookies

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

Safari (Desktop) and Safari Mobile (iOS).

Firefox

Chrome

Microsoft Edge

Brave

Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google. To learn more about how Google uses personal information visit: www.google.com/policies/privacy/partners/.

For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit Your Ad Choices and Manage My Browser’s Opt-Outs. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes. If you opt-out, you will still receive advertisements, but they will not be delivered to you by such companies from whom you have opted-out based upon your behavioral data possessed by the companies from whom you have opted-out. The opt-out process through the Digital Advertising Alliance relies upon the placement of an opt-out cookie on your device, and you must repeat this process on each device or if your cookies are purged from your device.  Cookie-based opt-outs are not effective on certain mobile services. Users may opt-out of certain advertisements on mobile applications or reset advertising identifiers via their device settings.

To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, click on the following links:

iOS – https://support.apple.com/en-us/HT202074

Android – https://support.google.com/ads/answer/2662922?hl=en

  1. Your Privacy Rights

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:

  • Access and Portability. The right to know (or confirm) what personal information a business has collected about you, and to receive a copy of it.
  • Deletion/Restriction. The right to request that a business delete personal information it has collected from you or restrict how it is used, subject to certain exceptions.
  • Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business.
  • Opt-Out of the Sale/Sharing of Your personal information. The right to opt-out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt-out of the use of personal information for targeted advertising purposes.
  • Revoke Consent. Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time.
  • Object to Processing. Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
  • Limitation/Restriction. The right to limit or restrict a business’s use or disclosure of certain personal information.
  • Opt-out of Profiling/Automated Decision-Making: The right to opt- out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law, including, but not limited to, by (i) denying you goods or services, (ii) charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) providing you a different level or quality of goods or services, or (iv) suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • The right to lodge a complaint with the appropriate governmental authority.

Recurrent will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.

Exercising Your Privacy Rights

You may make a request at any time to exercise your access, deletion, correction, and restriction rights listed above by using our Privacy Portal or emailing us at info@photopopular.com.  We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

  1. Children’s Privacy

Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us with their personal information, please contact us at info@photopopular.com.

  1. Jurisdiction-Specific Privacy Disclosures
    • Members of the European Economic Area, the United Kingdom, and Switzerland

Our Legal Grounds for Processing Your Personal Information

When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations.

To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Services.

Under European data protection laws, Recurrent is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

  • Performing our agreement. Recurrent processes your information as is necessary to perform our contract with you. For example:
    • We use your information to create your account and set you up as a registered user on Recurrent.
    • We transfer your information outside of the EU to the United States to provide our Services.
  • Your consent. Recurrent processes certain information based on your consent, which you may revoke at any time. For example:
    • We and our partners use cookies and similar technologies, based on your consent.
    • Where you choose a method of verification to confirm your address, we do so in accordance with your consent.
    • If you decide to use location services in the context of Recurrent, we collect and process such location information based on your consent.
    • We rely on your consent to tailor ads based on your activity and information on other websites and partner data, such as inferred interests.
    • We will send you marketing communications where you have consented to receive such communications in accordance with applicable law.
  • Legal obligation. Recurrent may process your information to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
    • We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g., a subpoena, search warrant, court order, or other binding requests from the government or law enforcement).
    • We may retain and process your information where it is necessary for compliance with applicable tax laws.
  • Vital interests. Recurrent may process your information in certain circumstances when it is necessary to protect your vital interests or those of others. For example:
    • We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person or the general public.
    • We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.
    • We may share your personal data with disaster relief agencies, first responders, and other individuals to facilitate disaster or emergency response efforts.
  • Legitimate interests. We may process your information where it is necessary for the purposes of Recurrent’s or a third party’s legitimate interests, such as those of creators. We process your information in furtherance of the following legitimate interests:
    • Providing, improving, and developing our Services. We use your information to provide our Services, including any personalized services, and to understand and improve our business and our user relationships.
    • Providing ads, measurement, and analytics services. We use your information to provide personalized ads both on and off Recurrent and to measure and analyze the success of those ads to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests of marketing and monetizing our Services.
    • Sending marketing communications. We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
    • Sharing information for legal and safety reasons. Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.
    • As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

You may lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law. If the complaint relates to provisions of the EU and UK GDPR, or Swiss data privacy laws, you can lodge such complaint with a supervisory authority in the Member State of your place of residence, your place of work, or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can lodge such complaint with the Information Commissioner’s Office. For contact details of your local Data Protection Authority, please see:  https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm