SnapEntry Privacy Policy - v1.2.0

From time to time, the nature of our business dictates that we may collect personal information from our customers. Because we are committed to protecting your privacy rights and the information you provide to us, we have developed this Privacy Policy (“Privacy Policy”). This Privacy Policy sets forth how Whyle Labs Inc. collects, protects and uses the personal data of our customers.

Effective September 29, 2026. Our Privacy Officer is Kyle Loveless. For questions or requests about your personal data, email privacy@snapentry.ca, or write to the Privacy Officer, Whyle Labs Inc., 463 Eglinton Ave W Suite #209, Toronto, ON M5N 1A7, Canada.

1. COLLECTION AND USE OF DATA

• 1.1 Personal Data We Collect: Our primary reason for collecting data is to provide products and services to our customers. To this end, we collect data when you:
  1. Contact us;
  2. Request information about our products and services;
  3. Purchase and use our products and related services;
  4. Respond to surveys;
  5. Access our website;
  6. Use our application (web application, on-device application, building-access hardware or telephony);
• 1.2 Data we Collect: We collect the following data from you:
  1. Names/addresses/emails/phone numbers and other types of contact information;
  2. Use cases and other relevant information pertaining to how you use our products and related services;
  3. Application and product use data, including phone call conversations (at most only being retained and transcribed for 1-person conversations with a machine, or with explicit notice) and text exchanges. Our speech-to-text providers may also retain call audio under their own terms;
  4. Bank account information/ shipping address/ and other information needed to process orders;
  5. Technical data, such as the IP address and browser type of signed-in sessions, cookies, and the click ID of an advertisement you arrived from;
• 1.3 How we use the data we collect: We use the data we collect for the following:
  1. Fulfil contractual requirements;
  2. Improve upon our products and services;
  3. Communicate information about Whyle Labs Inc. to potential customers, customers, potential partners and partners (including Financial Institutions for processing payments);
• 1.4 Why we need the data we collect: We need the data we collect to:
  1. Provide services to you;
  2. Provide mailing offers, product information, event notifications, surveys, quotes/invoices, product demonstration, evaluation and delivery;
  3. Obtain customer feedback, respond to product inquiries, report/resolve support incidents;
  4. Communicate information about Whyle Labs Inc. to potential customers, customers, potential partners and partners;
  5. Improve our products;
• 1.5 Storage Location of the data we collect: Our application runs in Quebec, Canada. Our database and several of our service providers (see section 1.7) are in the United States, so your data is processed and stored in the United States as well as Canada, and may be accessible to authorities in either country. Some data is also stored on your device.
• 1.6 How long we store the data we collect: We retain personal data for as long as we need it to provide our services, and as required by law. You can ask us to delete your data at any time (see section 4). Deletion requests take some time to process, and may have limits on what is deleted - especially for group accounts.
• 1.7 Service providers: We use the following service providers, which process data on our behalf:
  1. Cockroach Labs, on Google Cloud (United States): our database;
  2. OVHcloud (Canada): our application servers;
  3. Vonage (United States): phone calls and SMS;
  4. Deepgram and OpenAI (United States): recognizing what people say when they call a SnapEntry intercom, such as an entry code. They may retain that audio under their own terms;
  5. Honeycomb (United States): monitoring and debugging the service. This data includes phone numbers, what callers say to an intercom, and the entry codes they enter;
  6. Amazon Web Services (United States): sending email;
  7. Google Workspace (United States): email correspondence with our staff;
  8. Google Cloud (United States and Canada): database backups;
  9. Advertisers, only as described in section 3.
  Our service providers change from time to time. We endeavour to update this list when they do, but it may not always be current.

2. TRACKING WHILE NOT LOGGED IN

• 2.1 Purpose: In addition to security and debugging, we track users even before logging-in or account creation in order to improve the product and to improve marketing.
• 2.2 Method: Tracking is done using technologies like cookies.
• 2.3 Not-individually identifiable: Our goal is to track users without the ability to identify them until they accept our EULA and privacy policy, thus avoiding the collection of "personal information" as defined by applicable privacy laws, including PIPEDA and the privacy laws of US states (excluding security and debugging).
• 2.4 Linking after logging in: While data collected before accepting the EULA and privacy policy are not intended to be individually identifiable, we may link previously collected information to an individual once they have created an account or logged in.

3. THIRD-PARTY ADVERTISERS

• 3.1 Sharing with third-party advertisers: We do not use third-party tracking pixels and similar services. The only potentially-personally-identifying information we share with third-party advertisers is conversions (e.g. this user signed up for a trial) using the advertiser-provided ID (e.g. a click ID). This is only for users that came to us from that advertiser and after being presented with an opt-out. We do not share additional personally-identifying information (e.g. email addresses). You can opt out of this sharing at any time from that prompt, or by emailing privacy@snapentry.ca.

4. CONTROL

• 4.1 Control: You can ask to see the personal data we hold on you, to know how it is used, to correct it if it is incorrect or incomplete, or to have it deleted. Email privacy@snapentry.ca; we will verify your identity and respond within 45 days. We will not treat you differently for making such a request. If you access our services under a group account, then you agree that any one of the groups using the service may access all information attached to the group account.
• 4.2 Children: SnapEntry is not intended for anyone under 18, and we do not knowingly collect their personal data.

5. DATA BREACH PRACTICES

• 5.1 Incidents of Breach: When Whyle Labs Inc. learns of a suspected or actual personal data breach, we perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to the rights and freedoms of data subjects, Whyle Labs Inc. shall notify the relevant data protection authorities without undue delay and, when possible, within 72 hours, and shall notify affected individuals as required by applicable law.