GeoSnapShot – Privacy Policy

Last updated 5th December 2023


1. GEOSNAPSHOT’S COMMITMENT TO PRIVACY

GeoSnapShot is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws (see below for further information about GeoSnapShot).

We understand the importance of being open and transparent with you in the way in which we collect, hold, store, use and share your personal information. We take protecting your privacy very seriously.

We strongly encourage you read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about GeoSnapShot’s handling of your personal information, please contact us using the relevant contact details set out in section 20.

2. ABOUT GEOSNAPSHOT

At GeoSnapShot Pty Ltd (ABN 62 163 982 189) (GeoSnapShot, we, our or us) we believe in the power of photography (photography meaning photos or videos) to capture a moment in time and eternalise your greatest achievements. Our company’s mission is to combine cutting-edge technology solutions with an unparalleled participant experience for events, sporting organisations and schools.

As both a marketplace that connects event organisers, photographers and participants, and a photo management platform where creatives can add their unique branding, watermarks and sponsor logos to their photos, GeoSnapShot is your all in one media management solution provider.

3. ABOUT THIS PRIVACY POLICY

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. It sets out how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online).

Other privacy terms and conditions may apply to you, such as:

  • the privacy terms and conditions contained in our GeoSnapShot Terms and Conditions (as applicable to you);

  • the collection notices and privacy statements which may be provided to you at the time your personal information is collected;

  • the privacy policies and terms and conditions of third party Service Providers we use, such as Amazon Web Services (if applicable to you, as explained below in this Privacy Policy); and

  • the privacy policies and terms and conditions of third parties’ websites, accessible through links contained on our website (Linked Sites).

4. DEFINITIONS

Amazon Web Services Artificial Intelligence Service (AWS AI Service) means the AI service that may be used by GeoSnapShot which utilises Face Analysis to match photography uploaded to the Platform by Photographers or Event Organisers (as applicable) from events with Selfies uploaded by Event Participants.

Event Organiser means an organisation or school that has signed up to the Platform in relation to an event they are running.

Event Participant means an individual participating in an event run by an Event Organiser.

Face Analysis means facial geometry analysis extracted from your Selfie. This is a type of biometric information.

Linked Sites mean third party websites accessible through links contained on our Platform.

Minor means any individual under the age of 18 years old.

Nominee means an individual who has been nominated to act, or make decisions, on behalf of an Event Participant (this could include parents or guardians).

Personal Information is defined in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not; and

  • whether the information or opinion is recorded in a material form or not.

Photographer means either:

  • a photographer(s) who has signed up to the Platform to promote their services; or

  • a photographer(s) being used by an Event Organiser for an event.

Platform means the platform operated by GeoSnapShot which is available at the domain www.geosnapshot.com.

Selfie means a photo of yourself optionally uploaded or provided through our Platform to use certain services.

Sensitive Information is as defined in the Privacy Act. It is a subset of personal information that attracts additional privacy protections, including biometric information (such as an individual’s facial features, fingerprints, iris, palm, signature, or voice).

Service Provider means a third party that provides goods or services to GeoSnapShot which may include processing personal information on our behalf.

Usage Data means data collected automatically from you in relation to your use of the Platform (for example, the duration of your visit to a page).

User means:

  • an Event Organiser;

  • an Event Participant;

  • a Photographer; or

  • or any other individual using the Platform or the goods and services provided through the Platform.

(together, Users, you, your).

5. WHEN WILL WE MEET YOU?

At GeoSnapShot we want to bring all parties involved in different stages of an event together through our Platform. What that means is that when we meet you will depend on what type of User you are or who you are.

For example, if you are an Event Organiser, you may be looking for a photographer to engage for the day, or simply want to use a platform where your team can upload and share their photos with the people who attended the event. When you sign up to the Platform, you can do just that.

If you are a Photographer, you might meet us when signing up to our Platform to try and promote your photos and connect with Event Organisers. Or, if you have already been hired by an Event Organiser for an event, the Event Organisers may invite you to their event page on our Platform, where you’ll be asked to sign up to upload your photos.

If you are an Event Participant, you might hear about us from the organisers of the event you just attended. If they have set up an event page on our Platform, they may upload photos from the event (including photos of you) to our Platform, and then direct you to the Platform so you can search for photos taken of you on the special day, and then purchase your own copy.

We also meet Users like you when you interact with us online (such as when you visit our website) or contact us (including through our Platform or social media channels), including to make an enquiry or give us feedback.

6. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT THIS INFORMATION?

The types of Personal Information that we collect or request from you and how we collect or request this Personal Information will depend on who you are and how we are interacting with you. Typically this includes the following:

Type of Personal Information

What this includes

How do we collect this information?

Event Organisers and Photographers

This may include your:

Personal information and contact details

  • full name;

  • email address;

  • phone number;

  • country; and

  • zip/post code.

This may include your:


Financial information

  • PayPal account name; and

  • bank account details (including account number, BSB, bank name, bank address, account type, routing number and SWIFT code).


We collect this information when you sign up to our Platform or make a payment via our Platform.

Organisation details

If you are part of an organisation (i.e. not an individual), this may include your:

  • organisation’s name;

  • organisation website URL; and

  • organisation Facebook page URL.

Event Participants

Personal Information and contact details

This may include your:

  • full name;

  • email address;

  • country; and

  • IP address.

We collect this information when you or your Nominee are at the checkout on our Platform (when purchasing your photographs).

Sensitive Information / Selfie

This may include:

  • your Face Analysis; and

  • a Selfie of you.

When your Event Organiser uploads photos from the event to our Platform, your Face Analysis may be captured using the AWS AI Service we use.


If you want to use the photo search functionality available on our Platform, we may request that you upload a Selfie when you attempt to search our database of photos using your Face Analysis. However, even though your Face Analysis is used, it is not collected or stored by us and we are not able to access your Face Analysis.


Please refer to section 7 below for more information on who collects this information.

Users and visitors to the Platform

Usage Data

This may include:

  • IP address;

  • data about visits to our Platform such as how many people have visited our Platform, how many people use the checkout on our Platform, the duration of a page visit, the pages of the Platform you visit, the time and date of your visit and the time spent on the pages of the Platform;

  • cookies as further set out in our Cookies Policy which can be found here. We may change which cookies are collected from time to time and will update the Cookies Policy accordingly;

  • browser type;

  • browser version; and

  • location data. You can enable and disable location services when you use our Platform at any time, through your device settings.

We collect this information when you access and use our Platform.

7. FACE ANALYSIS AND AWS AI Service

GeoSnapShot’s offering on our Platform may include our ‘Selfie-Search’ feature whereby you can upload a Selfie to the Platform, and quickly find other images that match you on the Platform. This feature is provided on the Platform using the AWS AI Service, which is provided by AWS, a third party provider, using Face Analysis.

In particular, when photos are uploaded to the Platform of Event Participants at events, the AWS AI Service automatically captures and stores biometric information related to that photo (i.e. the Face Analysis). This could include facial features that may be used to compare facial features with a Selfie uploaded by you for the purpose of finding photos that may contain a likeness to you quickly and easily. GeoSnapShot has no access to and does not collect, store or analyse any Face Analyses and all Face Analyses are collected, stored and analysed by AWS, our third party provider. GeoSnapShot does not, and has no way of correlating your Face Analysis with any other Personal Information handled or stored by GeoSnapShot.

The AWS AI Service is a universally trusted and secure partner for hosting global websites. As a managed service, the AWS AI Service is protected by AWS’ global network security procedures. Before uploading a Selfie you should feel comfortable with how the Face Analysis operates and you can find more information here https://docs.aws.amazon.com/ . By uploading a Selfie, you consent to AWS, collecting, using, disclosing, processing and otherwise handling your Selfie, Face Analysis (which is Sensitive Information) for the purpose of providing the AWS AI Service.

8. PROVIDING INFORMATION FOR SOMEONE ELSE

If you are providing Personal Information and/or Sensitive Information on behalf of someone else (for example if you are a Nominee), you must have the consent of that person to provide their Personal Information and/or Sensitive Information to us to be collected, used and disclosed in accordance with this Privacy Policy. You should also let them know about our Privacy Policy (including the information in this Privacy Policy). We may request evidence of this consent.

If you are providing Personal Information and/or Sensitive Information on behalf of a Minor, you must be that Minor’s parent or legal guardian and you must provide consent for the Minor’s Personal Information and/or Sensitive Information to be collected, used and disclosed in accordance with this Privacy Policy.

9. CAN YOU DEAL WITH US WITHOUT PROVIDING YOUR NAME?

Most of the time, we will need your real name as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. For example, this includes when providing you with access to our Platform. This means that if we do not collect your Personal Information, we may not be able to provide you with the products and/or services you have asked for.

In some circumstances however, you have the option of not providing your name, or using a fake name, when you deal with us (where it is lawful and practicable). This includes for example, when you make a general enquiry via our Platform.

10. WHY DO WE COLLECT, STORE AND USE YOUR PERSONAL INFORMATION?

We collect Personal Information that is necessary to provide you with access to our Platform and its functionalities, and to carry out our business. Such purposes are set out in further detail in the table below:

Purpose

Explanation

To provide you with information and notifications about updates to our Platform and our interactions with you

We may collect, store and use your Personal Information to communicate Platform updates to all Users. Depending on who you are, we may also collect, store and use your information for the following purposes:

if you are an Event Organiser:

  • to coordinate the event you are running with you; and

  • to connect you with Photographers; and

if you are an Event Participant, to:

  • communicate notifications in connection with the Platform (such as sending you confirmation emails in respect of photographs you have purchased and notifying you about the availability of event photos).

To provide you with marketing content

We may send Users marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing including via email or in-app notifications (in accordance with the Privacy Act or Spam Act 2003 (Cth) (Spam Act) (as applicable)). For example, we may send:

  • Event Organisers, marketing messages in respect of our new products and their features, pricing changes in respect of our products or services, and opportunities for Event Organisers to use the Platform to benefit their business;

  • Photographers, marketing messages in respect of event photography opportunities; and

  • Event Participants, marketing messages in respect of Photographer or Event Organiser subscriptions such as informing you when photographs of Event Participants are uploaded to the Platform, or about other products or services which may be of interest to you.

See section 13 for information on how we send you direct marketing communications and how you can opt out of these communications.

To create deidentified or aggregate data for data analytics activities

We may collect, store and use your Personal Information to create deidentified or aggregate data sets (which is no longer Personal Information). We do this by deidentifying or aggregating your information such as combining your information with information we have about our other individuals, for example purchasing information, and with data we obtain from other sources. We use this deidentified or aggregate data to assist with our business decisions, such as to:

  • help us in understanding trends in Event Participant and other individual behaviour (such as the success of our products and services);

  • improve the products, tools and services we offer; and

  • develop new products, tools and services that better meet the needs of individuals we deal with based on preferences and behaviours.

To provide support

We may collect, use and store your Personal Information to provide you with customer support in respect of the Platform and our goods and services.

To improve and customise our Platform

We may collect, store and use your Personal Information (such as location data) to improve and customise the Platform and our goods and services.

To assist with technical issues and knowledge

We may collect, use and store your Personal Information to:

  • assist us to detect, prevent and address technical issues in respect of the Platform or our goods and services; and

  • monitor your usage of the Platform which will assist us to understand how you use the Platform.

To allow you to participate in interactive features

We may use your Personal Information to allow you to participate in interactive features of our Platform when you choose to do so.


To promote our the Platform or our goods and services

We may use your Personal Information (such as photographs and videos which feature you) for advertising and marketing purposes including to promote our Platform and our goods and services. Before using photographs or videos of you for these purposes, we may use your Personal Information to contact you to confirm that you are happy for us to use such photographs or videos for these purposes.

11. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY?

We may share your Personal Information with third parties:

  • for the reasons for which we collect, store and use that Personal Information (see above in section 10) which may include for direct marketing purposes where we have the necessary rights or consents or we are otherwise allowed to do so under applicable law;

  • for other purposes explained at the time we collect your Personal Information;

  • where we are otherwise allowed or required to do so under applicable law;

  • to protect and defend the Platform;

  • to prevent or investigate possible wrongdoing in connection with the Platform; or

  • to protect the safety and wellbeing of Users or members of the public.

Some of the third parties we may share your Personal Information with include the following:

Recipient

Explanation

Our contractors, suppliers and other entities we do business with

We may share your Personal Information with our partners and other entities we do business with to assist in providing our products and services to you. If you are an Event Participant, this may include Amazon Web Services. Please see section 7 above for more information on this.

Our Service Providers

We may share your Personal Information with a variety of our Service Providers to assist us with providing, promoting, and managing our products and services. This includes Google Analytics (as further set out below), Intercom and may also include other third party service providers including our:

  • third party storage providers; and

  • professional advisors and consultants (such as legal, insurance and financial advisors).

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Platform available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms

web http://www.google.com/intl/en/policies/privacy/.

Face Analysis and AWS AI Service

As set out in section 7, you can upload a2 Selfie to the Platform and this is shared with AWS for the AWS AI Services. We do not have any access to the Face Analysis held by AWS.

For more information on the privacy practices of AWS, please visit the AWS Privacy Notice

https://aws.amazon.com/privacy/

Law enforcement agencies

We may share your Personal Information with regulatory bodies, and law enforcement bodies to comply with our legislative or regulatory obligations (such as to assist with police investigations).

12. DO WE SHARE YOUR PERSONAL INFORMATION OVERSEAS?

We generally collect your Personal Information in Australia. However, GeoSnapShot operates internationally and it is likely that we will share your Personal Information with overseas recipients located in the United States of America, the UK, Europe and Canada. These recipients include our Service Providers who may handle, process or store your Personal Information on our behalf.

For example, we may share your Personal Information with Service Providers who assist us with storing our data on secure data storage servers, or with improving our products and services (by analysing information and trends, such as Google Analytics).

We only ever share your Personal Information outside of Australia where we are permitted to do so under the Privacy Act. Generally this means we will take reasonable steps to ensure your Personal Information is treated securely and in accordance with the Privacy Act.

There are other circumstances where we may disclose your Personal Information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under other applicable laws.

13. DO WE USE OR SHARE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

When you provide your Personal Information to GeoSnapShot, we may use that Personal Information to send you direct marketing communications to keep you informed about our Platform and its functionalities, and as further described at section 10 for the different types of Users.

We may communicate with you (and send these electronic messages and tailored advertising) through various channels, such as via regular mail, email, SMS, telephone, the Platform including via push notifications or social media (including through targeted advertisements on certain websites and social media channels).

We will only send these communications in accordance with applicable privacy and marketing laws (such as the Privacy Act (including Australian Privacy Principle 7) and the Spam Act), and only where you have not opted out from receiving such communications from GeoSnapShot.

If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

How can you opt out?

You are always in control of the direct marketing communications which you receive and can opt-out at any time. Generally you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as in the email or SMS message).

You can also contact us using the detail set out in section 20 to tell us you would like to stop receiving direct marketing communications from us.

Important points regarding opting out

Importantly, regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if we are required by law to provide you with information, or in relation to the services or products we are providing you with (for example, providing you with a purchase confirmation (if you are an Event Participant)).

14. HOW DO WE INTERACT WITH YOU VIA THE INTERNET?

Linked Sites

When you use our websites or receive communications from us, Linked Sites may be included (and are provided for your convenience). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any Linked Sites.

Website use

You may visit our websites without identifying yourself. If you identify yourself (for example, by creating an online account or making an enquiry), any Personal Information you provide to us will be managed in accordance with this Privacy Policy.

15. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?

We are committed to protecting your Personal Information, and ensuring that we securely store any Personal Information we collect (and in accordance with applicable privacy laws).

We take all reasonable steps to ensure that any Personal Information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Security and storage of Personal Information

We store electronic records in secure databases, using trusted third party storage providers. Unless you require your Personal Information to be stored in the territory in which it is collected (for example, for legal and/or compliance reasons), our default position is that we will store Personal Information in the United States of America. If requested, we will provide our available storage options to you. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores).

Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

How long do we keep your Personal Information?

We will only keep your Personal Information we store for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any applicable legal obligations, resolve disputes and enforce our legal agreements and policies.

When we no longer require your Personal Information (and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.

We may also retain your Usage Data for internal analysis purposes. However, Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of our Platform, or if we are legally obligated to retain this data for longer periods of time.

16. HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to request access to any of your Personal Information that we have. To make such a request, please contact us using the relevant contact details set out below in section 20.

We will take reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in the information we hold about you and informing us of any change in your personal details (for example, if your email address changes or if you move and change address).

If you consider any Personal Information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are also entitled to request correction of the information (again, please contact us using the relevant contact details set out in section 20). After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your Personal Information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision. In addition, in the case we refuse your request for correction, we will include a statement about your request with the Personal Information we store.

17. WHAT IF YOU HAVE ANY CONCERNS WITH ANY PHOTOGRAPHS OR VIDEOS UPLOADED TO THE PLATFORM?

As outlined in this Privacy Policy, GeoSnapShot is a photo management platform which enables third parties such as Event Organisers and Photographers to upload photos of Event Participants to the Platform. GeoSnapShot is not responsible for any photographs or videos which have been taken or recorded at an event or subsequently uploaded to the Platform.

If you have any concerns in relation to the photos or videos which have been taken or recorded at an event or uploaded to the Platform, you may contact us at any time using the relevant contact details set out below in section 20 and we can provide you with the contact details of the relevant Event Organiser who will be able to assist you with your concerns or complaint.

In accordance with our Website Terms and Conditions which are available here, we reserve the right to remove any photographs or videos from our Platform where GeoSnapShot considers it reasonably necessary in the circumstances.

18. HOW CAN YOU MAKE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

If you have any questions or concerns about this Privacy Policy or how we have handled your Personal Information, you may contact us at any time using the relevant contact details set out below in section 20.

Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur:

No

Step

1.

We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.


2.

If your complaint requires more detailed consideration or investigation:

  • we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly; and

  • we may ask you to provide further information about your complaint and the outcome you are seeking.

3.

We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.

4.

In most cases, we will respond to your complaint within 30 days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).

The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992, or you can fill out this form to make a complaint about our handling of your Personal Information. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au .

19. HOW ARE CHANGES MADE TO THIS PRIVACY POLICY?

We may make changes to this Privacy Policy from time to time, with or without notice to you. However, where we make a material change to the Privacy Policy, we will provide notice to you (including by updating our website, and, where appropriate, notifying you directly via email), prior to the change becoming effective. We recommend you visit this Privacy Policy regularly and check the “effective data” at the top of the Privacy Policy to keep up to date with any changes we make.

20. HOW CAN YOU CONTACT US?

You can contact us using the details below:

GEOSNAPSHOT
Email support@geosnapshot.com
Site Via the help service provided via the Site.