PRIVACY POLICY
BACKGROUND:
This Policy applies as between you, the User of this Web App and Martin W Smith Consulting Ltd, the owner and provider of this Web App. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web App and any Services or Systems therein.
1. Definitions and Interpretation
1.1 In this Policy the following terms shall have the following meanings:
2. Scope of this Policy
2.1 This Policy applies only to the actions of Martin W Smith Consulting Ltd and Users with respect to this Web App. It does not extend to any websites that can be accessed from this Web App including, but not limited to, any links we may provide to social media websites.
3. Data Collection and Usage
3.1 Without limitation, any of the following Data may be collected by us from time to time:
3.1.1 Name;
3.1.2 Contact information such as email addresses and telephone numbers;
3.1.3 IP address (automatically collected);
3.1.4 Web browser type and version (automatically collected);
3.1.5 Operating system (automatically collected);
3.1.6 A list of URLs starting with a referring site, your activity on this Web App, and the site you exit to (automatically collected).
4. When We Collect Information
4.1 We collect information from you when you:
4.1.1 Register on our site
4.1.2 Enter information on our site
4.1.3 Interact with our services
5. Use of Your Information
5.1 We may use the information we collect from you to:
5.1.1 Personalize your experience
5.1.2 Improve our website
5.1.3 Administer contests, promotions, surveys or other site features
5.1.4 Send periodic emails
6. Data Protection
6.1 We implement various security measures to maintain the safety of your personal information when you:
6.1.1 Enter, submit, or access your information
6.1.2 Your personal information is contained behind secured networks
6.1.3 Access is limited to a small number of persons with special access rights
6.1.4 All sensitive information is encrypted via SSL technology
7. Cookies
7.1 We use cookies to:
7.1.1 Understand and save user preferences for future visits
7.1.2 Compile aggregate data about site traffic and interactions
7.1.3 Improve site experiences and tools
8. Third-party Disclosure
8.1 We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties.
9. Google
9.1 We use Google AdSense Advertising on our website.
9.2 We have implemented the following Google services:
9.2.1 Remarketing with Google AdSense
9.2.2 Google Display Network Impression Reporting
9.2.3 Demographics and Interests Reporting
10. California Online Privacy Protection Act (CalOPPA)
10.1 According to CalOPPA, we agree to:
10.1.1 Allow users to visit our site anonymously
10.1.2 Have a link to our Privacy Policy on our home page
10.1.3 Notify users of Privacy Policy changes on our Privacy Policy Page
10.1.4 Allow users to change their personal information by logging into their account
11. Children Online Privacy Protection Act (COPPA)
11.1 We do not specifically market to children under the age of 13 years old.
12. Fair Information Practices
12.1 In case of a data breach, we will notify users via:
12.1.1 Email within 1 business day
12.1.2 In-site notification within 1 business day
13. CAN SPAM Act
13.1 We collect your email address to:
13.1.1 Send information, respond to inquiries, and/or other requests
13.2 In accordance with CANSPAM, we:
13.2.1 Do not use false or misleading subjects or email addresses
13.2.2 Identify the message as an advertisement when applicable
13.2.3 Include our physical business address
13.2.4 Monitor third-party email marketing services for compliance
13.2.5 Honor opt-out/unsubscribe requests promptly
14. Data Storage and Security
14.1 Your data will be stored in our secure servers located within the European Economic Area ("EEA").
14.2 We take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
14.3 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
15. Data Retention
15.1 Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or until you request that the Data be deleted.
15.2 Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
16. Your Data Protection Rights Under GDPR
16.1 If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
16.2 You have the following data protection rights:
16.2.1 The right to access – You have the right to request copies of your personal data.
16.2.2 The right to rectification – You have the right to request that we correct any information you believe is inaccurate.
16.2.3 The right to erasure – You have the right to request that we erase your personal data.
16.2.4 The right to restrict processing – You have the right to request that we restrict the processing of your personal data.
16.2.5 The right to data portability – You have the right to request that we transfer your data to another organization.
16.2.6 The right to object – You have the right to object to our processing of your personal data.
17. Subscription Data
17.1 For users with paid subscriptions, we collect and process additional data related to your subscription, including:
17.1.1 Subscription tier (Free, Basic, Premium, or Pro) and status
17.1.2 Subscription start and end dates
17.1.3 Payment history and billing information
17.1.4 Payment method information (processed and stored by our payment processor)
17.2 We use third-party payment processors to handle all financial transactions. These processors may store your payment information according to their own privacy policies and security standards. Currently, we use Stripe as our payment processor.
17.3 Subscription data is used to:
17.3.1 Process subscription payments and renewals
17.3.2 Provide appropriate access to subscription-based features such as increased photo upload limits and paid photowalk capabilities
17.3.3 Send notifications about subscription status, including renewal reminders and payment issues
17.3.4 Analyze subscription usage and patterns to improve our services
17.4 Your subscription data is retained for as long as you maintain an active subscription and for a reasonable period thereafter for accounting, legal, and business purposes. You can request deletion of this data by contacting us, subject to our legal obligations to retain certain financial records.
18. International Data Transfers
18.1 We may transfer your personal data to countries outside the EEA. Where we do so, we will ensure that appropriate safeguards are in place to protect your data.
18.2 By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
18. Changes to This Privacy Policy
18.1 We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically.
18.2 Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
19. Contact Information
19.1 For questions about this privacy policy, contact us at:
Martin W Smith Consulting Ltd
3 Field Drive
Crawley Down, West Sussex RH10 4AE
United Kingdom
Email: info@photowalk.me
Website: www.photowalk.me
Last Updated: 2025-04-24