Privacy Policy

Date of Last Revision: April 25, 2019

Thank you for using our Site and Services. We are committed to protecting the privacy of your data and this policy explains what we collect and how we use your personal information. This policy may be amended as we release new features, or when legal requirements arise. We encourage you to review this policy from time to time to stay informed of any changes that might affect you. By using the Site, You agree and consent to the Company's collection, use, and storage of Your data, including, but not limited to, biometric identifiers and information.

  1. Definitions

When we say the “Company”, “we”, or “us”, we are referring ESCHR Holdings LTD, its subsidiaries and affiliates. The Company provides users access to webs applications, website hosting services, and other tools and services (the “Site) to help them create and manage searchable photo galleries, manage customer data, and submit content for processing. When we say “Users”, “You”, or “Your”, we are referring to customers who are visiting our site or are using our Services.

  1. What information do we collect?

Account Information: To create an account, we collect information, such as your full name, email address, phone number, address, and password. For Users making a purchase or subscribing to services, we collect your credit card/debit card numbers and billing address information. To use the Services, we collect the information you voluntarily provided through your Account, including, but not limited to, athlete name, gender, age, race time, bib number, email address, event results, event media, and event details.

Log data: When you access or use our website or services, our servers will automatically record log data which may include IP addresses, device and browser configurations, date and time of access, browsing times and loading errors if applicable.

Usage data: We may collect data on how you or Visitors use the Services, such as gallery creation date and time, unique users, visits, time spent, etc.

Information from third party services: We may collect information through other services you integrate with (such as Mailchimp, Facebook, or Google Analytics), information collected will be all in accordance with the authorization procedures of the services.

Biometric Information: Your biometric identifiers and information, including a scan of Your face, will be collected, stored and used by the Company for the purpose of identifying image matches within photographs and videos. Your biometric identifiers and information will not be disclosed by the Company without your consent unless the disclosure is required by law or by subpoena. A copy of the Company's Biometric Information Security Policy is available upon request and the Company's website at the following address:

Additional information: We may collect additional information when you contact us for support, communicate with us via social media channels or contact us through third-party services.

  1. How do we collect your information?

Information you provided directly: When you sign up for an account or use the Services, you provide account and transaction related information. These may include, but are not limited to, your account information, contact information, billing information, event information, participant information, or information needed to integrate services.

Information from your use of the site and Services: When you visit the website or use the Services, we collect information of your activity and usage from your interaction with the site. These may include your IP address, browser and device information, timestamps of your interactions on the site. This information is mainly collected automatically using cookies or other similar technology. You can read more about our Cookie Policy here .

Information from other sources: We may collect information from other services such as third-party service providers, payment processors, or advertising services. These may include, but are not limited to, device and location information, limited information on your card used for payment, prior visits to our website, or whether you opened an email campaign.

  1. How do we use the information we collect?

We use the information collected primarily to provide you with the Services you signed up for and to support our legitimate interests in operating our Services and business.

To provide you with the services you signed up for: We will use the information for activities including, but not limited to, creating event galleries, identifying athletes, managing customer data, sending, and any other services requested by you. This also includes sharing this information with third-party service providers in order to provide the services (such as emailing). When we need to share information, we take the steps to ensure that only the necessary information is shared, and the information is protected and being used in accordance with this policy.

To maintain and improve our services: We use the information collected to analyze our site performance, improve our AI models, and measure the usage of features.

To verify your identity: When we need to authenticate your account to provide you support, or if concerns arise in regards to identity theft. We use the information to verify your identity.

To personalize your experience and advertise our services: We may use the information to conduct our advertising and marketing campaigns and referral program. You may opt out of certain ad targeting and retargeting services with the third-party advertising networks directly.

To communicate with you about our services: We will send you emails about transactions on your account, technical notices, and feature announcements. You may change your notification settings in your account, or contact us at any time.

To provide you with support: When you contact us for help, we will use the information to assist you in your use of the Services.

To meet legal requirements: We may need to use the information to comply with legal requests such as court orders, request by public authorities, and any other appropriate legal mechanisms.

  1. How do we share the information we collect?

Third-party Service Providers: We share your information with our third-party Service Providers who provide and support our Services. We will only share information that is necessary for the third-party to complete the service and require them to use the information a manner that is consistent with this policy. Examples of Service Providers include hosting and content delivery services, customer support management services, and payment processors.

User’s instruction: We will share and disclose the personal information only on your instruction, provided they are part of the functionality of the Services and they are in compliance with applicable law.

Change in business: In the case of a merger, acquisition, financing, reorganization or sale, information collected may be shared on the basis that it is subject to standard confidentiality arrangements.

To comply with the law: Information may be disclosed if it is deemed necessary to comply with the law and court order, to protect the rights of individuals and to fulfill law enforcement requirements.

Marketing: We may share information with third-party advertising networks (such as Amazon and Facebook) in order to deliver relevant advertisements to You and to manage our communications with you. We do not use your content for this purpose.

  1. How do we protect the information we collect?

The Company follows industry standards on the management of personal information. We employ technical and administrative safeguards intended to protect against accidental or unlawful destruction, loss, alteration and disclosure of personal information. We maintain security measures such as the use of redundancies and employ firewalls to protect against unlawful access and network vulnerabilities. No method of storage and transfer of information over the Internet is absolute secure, while we have safeguards in place, we cannot guarantee the absolute security of your personal information.

You agree to release us, any parent, any subsidiaries and affiliated entities and ours and their shareholders, officers, directors, employees and agents, successors and assigns from all claims, demands, damages, losses, liabilities of every kind, known and unknown, direct and contingent, disclosed and undisclosed, arising out of or in any way related to the theft, release, or use of such information by third parties, including, but not limited to a data breach. If you are a California resident, you waive California Civil Code Section 1542, which says: A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which, if known by him must have materially affected his settlement with the debtor.

  1. Data Retention

We will retain your information for as long as your account is active or as long as needed to provide you with the Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, to enforce our agreements and to protect our and others’ interests. We may continue to store your information for a reasonable amount of time after you cancel your paid subscription or becomes inactive, in the case that you wish to reactivate your account. Your biometric identifiers and information will be permanently deleted from the Company's systems no later than three years after your last use of the Site. You may delete your account and information by contacting us at, in which case your information will be deleted. Anonymized information that are not identifiable to a person might be retained to help us improve our Services.

  1. International information transfer

As part of providing the Services to you, your personal information might be transferred, stored or processed in a country other than where you are located. The Company will ensure the transfers will be completed in compliance with mechanisms that is recognized under the relevant Data Protection Legislation as providing an adequate level of protection for data transfers. Specifically, for residents of the EEA, we will ensure the data transfer is completed in accordance to the Standard Contractual Clauses (EU Model Clauses) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

  1. Your Rights

You have the rights over your personal information. Subject to any exemptions provided by law, we take reasonable steps to allow you to access, correct, amend, delete, port, or limit the use of your personal information. You can usually manage your information simply by logging into your account and editing your information directly in the dashboard. If you cannot perform these actions yourself, you can contact us at for assistance. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request.

If you are located in the European Economic Area (EEA), we will normally collect personal information from you only where, a) we have your consent to do so, b) where we need your personal information to fulfill a contract with you, or c) where the processing is in our legitimate interest in providing the services. In most cases, if you do not provide the requested information, we will not be able to provide the service to you.

If you are a User and wish to exercise these rights, please reach out to us at If you are a Customer or Participant of a User and wish to exercise these rights, please contact the User you interacted with directly -- we serve as a processor on their behalf, and can only forward your request to them to allow them to respond.

  1. Contact information

If you have any questions about this Privacy Policy or the Company's practices, or if you are looking to exercise any of your rights. You may contact us at