PRIVACY POLICY

Your information deserves clear handling.

Last updated: October 6, 2026

This Privacy Policy explains how OTHEZA, operating as OTHEZA (“OTHEZA,” “we,” “us” or “our”), collects, uses, discloses, stores and protects personal information.

It applies when you visit our website, submit an enquiry, communicate with us, enter into a studio partnership, use an OTHEZA-operated service or otherwise interact with OTHEZA.

It also explains OTHEZA’s role when we process information on behalf of the portrait and boudoir studios we serve.

1. Who OTHEZA serves

OTHEZA provides consultation, virtual reveal, sales follow-up, client communication, payment-support and revenue-operations services to portrait and boudoir studios.

Depending on the interaction, we may handle information about:

- Website visitors

- Prospective studio partners

- Current and former studio partners

- Studio owners, employees and contractors

- Photography clients and prospective photography clients

- Vendors, service providers and professional advisers

- People who communicate with OTHEZA

2. OTHEZA’s privacy roles

OTHEZA may handle personal information in two different capacities.

Information collected for OTHEZA’s own business

When you visit our website, submit an OTHEZA form, request information about a partnership, communicate directly with us or become an OTHEZA partner, OTHEZA determines why and how that information is handled.

This Privacy Policy governs that information.

Information processed for a partner studio

When OTHEZA conducts consultations, virtual reveals, follow-up or related services for a partner studio, we may process information supplied by or collected on behalf of that studio.

In those circumstances, the partner studio generally determines the purposes for which its client information is collected and used. OTHEZA processes the information according to the studio’s instructions, our agreement with the studio and applicable law.

Questions about a photography studio’s privacy practices, including requests involving information controlled by that studio, should usually be directed to the studio first. We will reasonably assist the studio with valid privacy requests when required.

3. Personal information we may collect

The information we collect depends on how you interact with OTHEZA.

Contact and identity information

This may include:

- First and last name

- Email address

- Telephone number

- Business or studio name

- Job title or business role

- Mailing or billing address

- Time zone and location information you choose to provide

Studio and operational information

When evaluating or operating a studio partnership, we may collect:

- Studio service and product information

- Pricing, collections and payment-plan information

- Lead, consultation and reveal volume

- Scheduling and availability information

- Sales processes, scripts and policies

- Team-member and system-access information

- Performance, booking and sales data

- Service instructions and authorization limits

- Information submitted through onboarding documents and authority matrices

Photography-client information

When a studio authorizes OTHEZA to work with its clients, we may receive or collect:

- Client names and contact information

- Appointment and scheduling information

- Enquiry and consultation responses

- Portrait preferences and purchase priorities

- Booking, agreement and reservation status

- Reveal and image-selection information

- Product or collection selections

- Payment status and authorized payment-plan information

- Relevant communication history

- Notes reasonably required to perform the studio’s authorized services

OTHEZA does not need or request complete payment-card numbers through ordinary website forms, email or text messages. Payment-card information submitted through an authorized checkout is handled by the applicable payment processor.

Transaction and billing information

We may collect:

- Invoice and payment status

- Transaction amounts

- Billing contacts

- Refund, dispute or chargeback information

- Limited payment-method details supplied by our payment processor

- Records needed for accounting, taxation and fraud prevention

Communications

We may retain information contained in:

- Emails

- Text messages

- Calls or virtual meetings

- Contact forms

- Support requests

- Consultation and reveal notes

- Other communications with OTHEZA

If a call or meeting will be recorded or transcribed, we will provide notice or obtain consent where required.

Website and device information

When you use our website, we and our authorized technology providers may automatically collect:

- IP address

- Browser and device type

- Operating system

- Referring page

- Pages visited

- Approximate location derived from an IP address

- Date, time and duration of visits

- Form and button interactions

- Cookie and similar technology identifiers

Information from other sources

We may receive information from:

- Partner studios

- Individuals who submit forms or contact us

- Customer relationship management platforms

- Scheduling and communication platforms

- Payment processors

- Analytics and advertising providers

- Referral partners

- Publicly available business sources

- Vendors acting under our instructions

4. How we use personal information

We may use personal information to:

- Respond to enquiries

- Evaluate potential studio partnerships

- Prepare proposals and agreements

- Onboard and support partner studios

- Provide consultations, virtual reveals and agreed sales follow-up

- Communicate with photography clients on behalf of partner studios

- Schedule and administer appointments

- Complete authorized booking and payment steps

- Maintain client and studio records

- Coordinate operational handoffs

- Produce performance and revenue reports

- Process payments, invoices, refunds and disputes

- Provide technical or account support

- Improve our website, services and internal processes

- Monitor service quality and train authorized personnel

- Protect our systems, users and business

- Detect fraud, abuse and security incidents

- Establish, exercise or defend legal rights

- Meet accounting, tax, regulatory and contractual obligations

- Send marketing communications where permitted

- Fulfil other purposes identified when the information is collected

We limit the collection and use of personal information to purposes that are reasonably necessary and appropriate in the circumstances.

5. Consent and other lawful authority

Where consent is required, we seek consent that is appropriate to the nature and sensitivity of the information and the way it will be used.

Consent may be express or implied, depending on the circumstances and applicable law. We may also collect, use or disclose information without consent where the law permits or requires us to do so.

You may withdraw consent for certain uses by contacting us, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may prevent us from providing some services.

When OTHEZA acts for a partner studio, the studio is responsible for establishing an appropriate basis for OTHEZA to process its client information, including providing required notices and obtaining required consent.

6. How we disclose personal information

We do not sell personal information for money.

We may disclose personal information in the following circumstances.

Partner studios

When we provide services on behalf of a studio, we share relevant appointment, communication, booking, reveal, payment-status and outcome information with that studio.

Personnel and contractors

Authorized employees and contractors may access information when reasonably required to perform their responsibilities. They are expected to protect confidential information and use it only for authorized purposes.

Technology and professional service providers

We may use service providers that support:

- Website hosting

- Customer relationship management

- Forms and scheduling

- Email, telephone and text communication

- Video meetings

- Payment processing

- Electronic signatures and documents

- Cloud storage

- Analytics and advertising

- Accounting and bookkeeping

- Cybersecurity and fraud prevention

- Legal, insurance and professional services

These providers may process information only as permitted by their agreements with us, their own applicable terms and the law.

Business transactions

Information may be disclosed as part of a proposed or completed financing, reorganization, merger, acquisition, transfer or sale of all or part of OTHEZA, subject to appropriate confidentiality and legal requirements.

Legal, safety and compliance purposes

We may disclose information where reasonably necessary to:

- Comply with applicable law, legal process or regulatory requirements

- Respond to lawful requests from courts, regulators or law-enforcement authorities

- Protect the rights, property or safety of OTHEZA, a partner studio, a client or another person

- Investigate fraud, security incidents, misuse or contractual violations

- Establish, exercise or defend legal claims

7. Service providers and international processing

OTHEZA may use service providers located in Canada, the United States or other jurisdictions.

As a result, personal information may be stored or processed outside the province, state or country where it was originally collected. Information processed in another jurisdiction may be subject to that jurisdiction’s laws and may be accessible to courts, law-enforcement authorities or government agencies in accordance with those laws.

Where required, we use contractual, administrative and technical measures intended to protect personal information handled by our service providers.

You may contact us for more information about the way service providers outside Canada handle personal information under our control.

8. Cookies and similar technologies

Our website may use cookies, pixels, tags, local storage and similar technologies.

These technologies may be used to:

- Operate and secure the website

- Remember preferences

- Understand website traffic and usage

- Measure form and campaign performance

- Improve website functionality

- Support advertising and remarketing, where permitted

Some technologies are necessary for the website to function. Others may be controlled through a cookie-consent tool, browser settings or the privacy controls provided by the relevant platform.

Blocking some cookies may affect website functionality.

Where required by applicable law, we will request consent before placing non-essential cookies or similar technologies.

9. Marketing communications

We may send service information or marketing communications where we have the consent or other legal authority required to do so.

You may unsubscribe from marketing emails by using the unsubscribe link included in the message or by contacting us at [email protected].

Unsubscribing from marketing does not prevent us from sending transactional, contractual, security, billing or service-related communications.

We maintain records of consent and honour valid unsubscribe requests in accordance with applicable law.

10. How long we retain information

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including to:

- Provide and administer services

- Maintain accurate operational and transaction records

- Meet legal, accounting and tax obligations

- Resolve disputes

- Enforce agreements

- Manage security incidents and legal claims

Retention periods vary depending on the type of information, its sensitivity, the relationship involved and applicable legal or contractual requirements.

When information is no longer required, we take reasonable steps to delete, destroy or anonymize it.

When OTHEZA processes information for a partner studio, retention and deletion may also be governed by our agreement with that studio and its lawful instructions.

11. How we protect information

We use administrative, technical and physical safeguards designed to protect personal information against unauthorized access, disclosure, loss, theft, alteration or misuse.

Safeguards may include:

- Access restrictions

- Unique user accounts

- Password and authentication controls

- Encryption provided by our platforms

- Confidentiality obligations

- Personnel and contractor training

- Vendor review

- Secure payment processors

- Data minimization

- Record-retention controls

- Incident-response procedures

- Periodic review of access and system permissions

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we take reasonable measures proportionate to the sensitivity of the information.

If a privacy or security incident occurs, we will investigate and take the notification, reporting and recordkeeping steps required by applicable law.

12. Accuracy of information

We take reasonable steps to keep personal information accurate, complete and current where it is used to make a decision or provide a service.

You are responsible for providing accurate information and notifying us when relevant information changes.

Partner studios are responsible for maintaining accurate information in the systems and records they control.

13. Your privacy choices and rights

Depending on where you live and the law that applies, you may have the right to:

- Ask whether we hold personal information about you

- Request access to personal information under our control

- Request correction of inaccurate or incomplete information

- Withdraw consent for certain uses

- Object to or restrict certain processing

- Request deletion where legally available

- Request information about our use and disclosure of your information

- Lodge a complaint with an appropriate privacy regulator

These rights are not absolute. We may need to verify your identity, and legal or contractual exceptions may apply.

If information was collected or is controlled by a partner studio, we may direct your request to that studio or assist the studio in responding.

To make a privacy request, email [email protected] with the subject line “Privacy Request”.

Please explain what you are requesting and provide enough information for us to locate the relevant records. Do not send government identification or highly sensitive information unless we specifically request it through an appropriate method.

We will respond within the period required by applicable law.

14. Children’s information

OTHEZA’s website and studio-partnership services are directed to businesses and adults. They are not directed to children.

However, partner studios may photograph children and families. In performing authorized services for those studios, OTHEZA may process limited information relating to a child, such as a name, appointment detail, family relationship, portrait preference or product selection.

The partner studio is responsible for obtaining consent from a parent or legal guardian where required. OTHEZA processes that information only as needed to provide the authorized service.

If you believe a child’s information was provided to OTHEZA improperly, contact [email protected].

15. Third-party websites and platforms

Our website or communications may contain links to websites, booking systems, payment pages, social-media platforms or services operated by third parties.

Their privacy practices are governed by their own policies. OTHEZA is not responsible for the privacy practices, content or security of independently operated third-party services.

We encourage you to review the privacy information presented by those services before providing personal information.

16. Automated tools and artificial intelligence

OTHEZA may use software-assisted tools to organize information, summarize communications, support workflow administration, improve internal processes or prepare draft materials.

We do not authorize automated tools to make final decisions about a person’s eligibility, financial status or legal rights without appropriate human involvement.

Where OTHEZA processes studio-client information, we use such tools only as permitted by our agreement with the applicable studio and our privacy and confidentiality obligations.

We do not intentionally use confidential studio-client information to train publicly available artificial-intelligence models.

17. Privacy complaints

If you have a question or concern about OTHEZA’s handling of personal information, contact our Privacy Officer.

We will review the concern and take reasonable steps to investigate and respond.

If you are not satisfied with our response, you may have the right to contact the Office of the Privacy Commissioner of Canada or another privacy regulator with jurisdiction over the matter.

18. Changes to this policy

We may update this Privacy Policy when our services, technology, legal obligations or privacy practices change.

The updated version will be posted on this page with a revised “Last updated” date. If a change is material, we may provide additional notice where appropriate or required by law.

19. Contact OTHEZA

Privacy Officer

OTHEZA, operating as OTHEZA

Hamilton,

Ontario, Canada

Email: [email protected]

For general enquiries: [email protected]

For enquiries about information controlled by a partner studio, please contact that studio directly. OTHEZA will assist the studio where appropriate and legally required.