Privacy Policy

Effective Date: April 6, 2026

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BY USING THE SERVICE OR BY AGREEING TO OUR TERMS OF SERVICE, YOU ARE AGREEING TO BE BOUND BY THIS PRIVACY POLICY. 

This Privacy Policy applies to Adventure Soup Inc. (“Picsaurus”, “we” “us” or “our”) services, including but not limited to the Picsaurus website, available at www.picsaurus.com as well as the Picsaurus app, platform or any other product or service we choose to apply this Privacy Policy to (collectively, the “Service”), and details how we collect, use, and disclose data, including personal data about you (together, “you” or “your”).

IF YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND THE ORGANIZATION TO THIS PRIVACY POLICY AND ARE AGREEING TO THIS PRIVACY POLICY FOR THAT ORGANIZATION. WHERE YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, “YOU” AND “YOUR” REFERS TO THE ORGANIZATION.

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1. HOW WE OBTAIN PERSONAL DATA

We collect and process personal data from our users, including you, which is information about you or that identifies you. 

We obtain personal data that we collect either directly from you when you choose to provide it to us or when you use the Service. Your provision of personal data to us is governed by this Privacy Policy and our Terms of Service (“Terms”) which you must agree to in order to use the Service. If you have any questions or concerns about the disclosure of your personal data, please contact us at your convenience using the contact information found below. Subject to legal, contractual and technical requirements, you may choose not to provide Picsaurus with certain data or request the deletion of certain data, which may impact the Service features available to you or essential operations of the Service.

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2. PERSONAL DATA WE COLLECT 

We collect and process certain personal data when you begin using the Service. The following is a description of the personal data that we may collect, use and process in connection with the Service:

• your full name, address, date of birth, phone number, sign-up information and email address (“Contact Information”);
• tour operator business information, including company/organization/entity name, location, website, social media handles, services provided, prices, offerings, booking dates and such other information the operators choose to provide (“Tour Operator Information”);
• Contents of emails you send directly to us, answers to feedback, referral information, surveys and questionnaires and additional information related to the tours provided or that you may be participating in, including reviews and tour operator links (“Content Details”);
• cookies and similar tracking technologies to track activities on the Service (“Tracking and Cookies Data”);
• your financial information, if you choose to provide it to us, which is processed via one of our third-party payment processors, including Stripe (“Banking Details”); and
• basic geolocation data, information about your computer, phone, mobile device, web-connected devices or other devices used to connect to the Service including but not limited to, operating system information, feature usage, request timestamps, error logs, your computer's Internet Protocol address (i.e. IP address), browser type, browser version, operations performed on the device, time and date of Service use, time spent on Service, other diagnostic date and/or unique tokens and identifiers that may identify you over time and across different websites including unique device identifiers (collectively, “Usage Data”).

Picsaurus may also collect anonymous data that does not identify you, including but not limited to responses to anonymous surveys and feedback requests, metrics and other types of statistical data, which could be derived from your use of the Service and analytical data concerning the Service. We may also aggregate, anonymize and/or de-identify the personal data we have collected about you for the same purposes. We have implemented commercially reasonable security measures to properly encrypt, anonymize and/or de-identify such data and we do not attempt to re-identify any previously anonymized or de-identified data.   

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3. PROCESSING OF YOUR PERSONAL DATA

We process your personal data for our legitimate business purposes. These uses may include but are not necessarily limited to:

• providing the Service to you, including tailoring the Service to your needs based on the data that you provide;
• facilitating account creation, authentication and management;
• processing and managing your subscription, billing and payment information
• understanding your needs and improving the quality of the Service, including providing customer support and feedback, providing additional support, analyzing functionality and technical issues, tracking use of the Service and generating internal reports and data models that we use to improve the Service; 
• gaining a better understanding of Service use and activity and understanding how the Service can be modified or improved;
• contacting you for various reasons, including when providing customer support for the Service or requesting feedback when necessary; 
• saving or protecting an individual’s vital interest, such as to prevent imminent risks of harm; 
• investigating improper or suspicious use of the Service or objectionability activity on the Service; 
• for contractual, legal, regulatory or audit obligations, including responding to requests from law enforcement or a government agency asserting lawful authority to obtain the data or where Picsaurus has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending Picsaurus in a legal, regulatory or administrative proceeding or in a contractual dispute or providing information to our legal counsel.

We may disclose your personal data to our parent companies, affiliates, subsidiaries, employees, contractors and business partners for the same purposes described above. We require such parties to protect the confidentiality and privacy of your personal information and use such information only for the requisite purposes described above.

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4. THIRD-PARTY SERVICES

This Privacy Policy only applies to personal data that Picsaurus collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties through third-party services, including but not necessarily limited to BugFender, Postmark, Twilio, Heroku, Bluehost, Stripe, Cloudfare, Fareharbor, Wherewolf, Rezdy, Smartwaiver, Peek, Close, Retool, Google, Apple and Helpdocs.io which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service. In many cases, third-parties may collect personal data about your online activities over time and across different websites and services. We strongly recommend that you read each third-party privacy policy carefully before using the Service. Please contact us directly using the information found below if you would like to learn more about third-party data practices.

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5. COOKIES AND TRACKING TECHNOLOGIES 

The Service uses tracking technologies, such as cookies and web beacons, to collect data about you, such as your IP address and device information. Based on this data, third-parties may be able to resolve your identity across multiple devices. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Certain Service features may rely on tracking technologies and by declining to accept cookies or by changing certain settings on your device, you may not have access to these features. You may opt out of certain cookies by directly adjusting your cookies and privacy settings in your web browser or by contacting us at support@picsaurus.com. 

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6. OBTAINING, RECTIFYING AND CONTROLLING YOUR PERSONAL DATA

Where permitted by the laws of your jurisdiction, you may contact Picsaurus to obtain a copy of any personal data we collect about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact Picsaurus to correct inaccurate personal data or to complete incomplete personal data.  

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital for:

• the performance of contractual obligations, such as our Terms of Use/Service or certain legal obligations;
• protecting your interests or those of another person; and
• our legitimate interests or the legitimate interests of a third-party,

and may do so by requesting deletion by contacting us using the contact information found below.

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7. Data Storage and Retention

While Picsaurus is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world. By using the Service you hereby authorize Picsaurus and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country. 

We have implemented various measures to protect your personal data, including by ensuring the use of the European Commission’s Standard Contractual Clauses for transfers of personal data between us and the majority of our third-party providers and partners. These clauses require all recipients to protect all personal data that they process originating from the EEA, UK or Switzerland in accordance with European data protection laws and regulations.

When we have no ongoing legitimate business need to process your personal data and/or your relationship with Picsaurus comes to an end, we will promptly return, delete or anonymize any other personal data and confidential information we have on file, in line with our legal obligations. Where returning, deleting or anonymizing your personal data is not possible, we will securely store your personal data and isolate it from any further processing until deletion is possible. Any personal data that has been requested to be returned, deleted or anonymized and is stored on a data backup will be held only temporarily and automatically purged after set expiration periods. Please email support@picsaurus.com to request deletion of any personal data of yours that we hold. 

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8. DO NOT TRACK DISCLOSURE

Do Not Track (“DNT”) is a web or device setting that allows you to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug-in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards and, as a result, we do not respond to DNT requests. 

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9. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GENERAL DATA PROTECTION REGULATION

If you are from the European Economic Area (“EEA”), or other jurisdictions in which substantially similar laws apply, such as the UK, Picsaurus’ legal basis for collecting and using the personal data as described in this Privacy Policy depends on the type of personal data Picsaurus’ collects and the context in which it collects it.

The categories of personal data Picsaurus collects and the legal basis for its processing are set out below:

Personal Data 

Picsaurus may process, collect and uses

Please see Sections 3, 4 and 5 for more information on personal data. The specifics of the personal data will depend on the context, but could include the following:

Legal Basis for Processing

• Content Details

Pursuant to GDPR Article 6(1)(a), you have opted-in and provided your consent for us to process your personal data for one or more specific purposes and not subsequently revoked such consent.

• Contact Information
• Tour Operator Information
• Banking Details
• Any information you give Picsaurus during direct inquiries
• Other information you choose to share with Picsaurus and/or insert into the Service

Pursuant to GDPR Article 6(1)(b), processing is necessary for the performance of a contract to which you are a party or is necessary in order to take steps at your request prior into entering into a contract.

• Tracking and Cookies Data
• Usage Data

Pursuant to GDPR Article 6(1)(f), processing is necessary for the purposes of the legitimate interest pursued by Picsaurus.

We may also process your personal data for additional reasons as they become apparent to comply with the law, or if it is in our legitimate interests so long as that interest is not overridden by your rights. This can include but is not limited to protecting the Services and you against illegal activity, inappropriate behavior and actions that violate our Terms. Picsaurus shall update this Privacy Policy and provide you notice where the scope of personal data being processed changes.

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10. RESIDENTS OF THE EUROPE ECONOMIC AREA and the UK

If you are a resident of the EEA and/or the GDPR or substantially similar laws such as the UK GDPR apply to you, you have certain rights regarding your personal data. These rights include:

• A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances.
• A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by contacting Picsaurus using the e-mail contact listed herein.
• A Right to Erasure. You have the right to obtain deletion of your personal data under most circumstances. In most cases, you may simply request the deletion by using the contact information found below. Please be careful as deletion of data in this manner is permanent and the data cannot be recovered.
• A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or if your personal data was collected based on your consent according to Article 6(1)(a) of the GDPR, you have the right to object to this processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular, if the personal data is necessary for the establishment, exercise or defense of legal claims or if personal data is required for the provision of the Service and you still wish to use the Service.
• A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction.
• A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR.
• A Right to Personal Data Portability. You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR.
• A Right to Post-Mortem Control of Your Personal Data. Certain jurisdictions grant post-mortem controls of your personal data and if such rights are applicable in your jurisdiction, you may have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death through a will or through your estate.
• A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. If you receive any marketing e-mails from us, you can exercise your right to stop such communications by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails Picsaurus sends you. To opt-out of other forms of marketing, please contact us using the contact details provided below.

11. Children

Picsaurus complies with the U.S. Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. The Service is not directed to children and we do not intentionally collect any personal data on individuals under the age of 13 in any jurisdiction. If we learn that we inadvertently collected personal data from a child under the age of 13 beyond allowable legal exceptions, we will delete that data as quickly as possible. If you are a parent or guardian of a child under the age of majority in your jurisdiction, who you believe provided Picsaurus with personal data without your consent, please contact us at support@picsaurus.com

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12. CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code 1798.83 grants you the right to request disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below. Please note that you may only make this request once per year.

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13. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale and sharing of your personal information to third parties. Currently, Picsaurus does not sell or share your personal information to third parties and as such no opt-out of the sale or sharing of such personal information is necessary. Although Picsaurus does not sell or share your personal information to third parties, Picsaurus does provide a general opt-out right to all of our users. If you have any other questions about our privacy practices, please email us at support@picsaurus.com.

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14. Change of Ownership or Business Transition

In the event of, or in preparation for, a change of ownership or control of Picsaurus or a business transition such as the sale of some or all Picsaurus’ assets, we may disclose and/or transfer your personal data to third parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy. Picsaurus will only disclose such personal data where the disclosure is subject to adequate privacy and confidentiality protections to ensure the security of your personal data in any proposed change of ownership or business transition.

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15. Security

We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process. Despite our safeguards and security, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment.

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16. Contact Preferences

We will communicate with you through your email address, phone or other digital methods in order to conduct the Service and to respond to support requests or comments. If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

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17. Updates

Picsaurus reserves the right, in its sole discretion, to modify this Privacy Policy at any time (each an “Update”) and shall make each Update available on our website. You are deemed to accept an Update by continuing to use the Service. Unless Picsaurus states otherwise, an Update is automatically effective 30 days after posting on the website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of Picsaurus and such Update is made only to correct a typographical, formatting or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the website.

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18. Contact Us

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Privacy Officer or our Privacy Team at support@picsaurus.com.