Draft · not yet reviewed by counsel

[DRAFT DISCLAIMER: This is a working draft prepared by an automated audit for internal review. It must be reviewed and completed by qualified legal counsel before publication. It is not legal advice, and it does not create an attorney-client relationship. Every value in square brackets is a placeholder that a human must confirm or fill before this document is published.]

Hitch Privacy Policy

Effective date: [EFFECTIVE DATE, to be filled before publication]
Last updated: [LAST UPDATED DATE, to be filled before publication]

[LEGAL NAME TBD] Inc., an Ontario (Canada) corporation ("Hitch," "we," "us," or "our"), provides Hitch, a destination-wedding planning and experience app for iOS (the "Service"). This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, how we protect it, and the choices and rights you have. It applies to users in Canada, including Quebec [and, if the still-open US market decision is confirmed, to users in the United States, including California].

Please read this policy together with any terms of service that govern your use of the Service. If you do not agree with this policy, please do not use the Service.

1. Who we are and how to contact us

Hitch is operated by [LEGAL NAME TBD] Inc., a corporation incorporated under the laws of the Province of Ontario, Canada, based in [CITY, Ontario, to be filled], Ontario, Canada.

  • Privacy matters: [email protected]
  • Support: [email protected]
  • Mailing address: [[LEGAL NAME TBD] Inc., mailing address, Ontario, Canada, to be filled before publication]
  • Privacy contact / responsible person: [name or title of the person accountable for privacy, for example a Privacy Officer, to be filled before publication]

For Canadian users, the individual accountable for our compliance with applicable Canadian privacy law can be reached at [email protected].

2. Scope of this policy

This policy covers personal information we handle through the Hitch iOS app and its supporting services. It does not cover the practices of third parties whose services or websites you may reach through the Service, and it does not cover information you choose to share directly with other people outside the Service.

The Service is offered in Canada (including Quebec) [and, if the still-open US market decision is confirmed, in the United States (including California)]. Where a specific law gives you specific rights, the relevant section below explains those rights.

3. A note on how weddings work in Hitch

Hitch is built around weddings. A host (typically a couple or a person planning on their behalf) creates a wedding and invites guests. Because of this structure, personal information in Hitch comes from two places:

  • Information you provide about yourself when you use the Service. See Section 4.
  • Information a host provides about their guests so the host can invite them and run the wedding. See Section 5.

Understanding this distinction matters, because your rights and our responsibilities differ slightly depending on which of these applies to you.

4. Personal information we collect from you

We collect the following categories of personal information directly from you when you use the Service.

4.1 Account and identity information

  • Email address (used for passwordless sign-in, see Section 6).
  • Name, including first name, last name, and display name.
  • Phone number. This is optional. We store it for future wedding broadcast features. We do not use it to send SMS text messages today.
  • Profile avatar selection.

4.2 Wedding information you enter

  • Couple names, wedding date, city, and venue.
  • Schedule, frequently asked questions, and other event details.
  • Budget figures you choose to record.

4.3 Communications and content

  • Messages, direct messages, and channel posts you send within the Service.
  • Photos you upload to the wedding photo wall. See Section 9 for important details about how photos are stored and shared.

4.4 Attendance and preferences

  • RSVP status.
  • Dietary preference and meal selection. This can include free text and options such as vegetarian, vegan, or gluten-free.
  • Number of children attending. This is a headcount only. We do not collect a child's name or identity through this field.

4.5 Information we do not collect today, but will collect later

The following will be collected only when the associated feature launches, and we will disclose the collection at that time:

  • Device push notification tokens, collected only when push notifications are wired into the Service.
  • Mailing or shipping address, collected only if you order a physical hardcover memory book.
  • Purchase and transaction data, collected only when in-app purchases or memory-book payments go live.

We do not collect these categories now, and this policy will be updated before we begin collecting any of them.

5. Personal information a host enters about guests

When a host sets up and runs a wedding, the host may enter personal information about their guests, specifically:

  • Guest name
  • Guest email
  • Guest phone number

This information is used to send invitations and to run the wedding. Hosts represent to us that they have permission to share their guests' contact information with Hitch for these purposes. Hitch processes this information on the host's behalf.

If you are a guest and a host has entered your contact information, you can request access to, or deletion of, that information by emailing [email protected]. Where the information is held on a host's behalf, we may need to coordinate with the host to honor your request, and we will act consistently with applicable law.

6. Authentication (passwordless)

Hitch uses passwordless authentication only. You sign in with a one-time code or a magic link sent to your email address. We do not collect, store, or require passwords. This reduces the amount of sensitive credential data associated with your account.

7. How we use personal information

We use personal information for the following purposes:

  • To provide the Service: create and manage your account, let hosts plan and run weddings, deliver messaging and the photo wall, and record RSVPs, meal selections, and headcounts.
  • To communicate with you: send account and transactional messages, and (when a host uses the feature) send invitations.
  • To maintain and secure the Service: operate our hosting and database, enforce access controls, prevent abuse, and protect the integrity of the Service.
  • To comply with law: meet legal obligations and respond to lawful requests.

We do not use your personal information for advertising, and we do not build advertising or cross-context behavioral profiles. See Section 8.

For Canadian users, we identify the purposes of collection at or before the time we collect your information, and we limit our use to those purposes or to purposes that are compatible with them, except where the law otherwise permits or requires.

8. Tracking, advertising, and "sale" or "sharing" of personal information

We want to be plain about this.

  • The Hitch app contains no advertising, analytics, attribution, crash-reporting, or tracking software development kits (SDKs).
  • We do not track you across other apps or websites.
  • We do not use the Advertising Identifier (IDFA).
  • We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising, as the terms "sell" and "share" are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).

Because we do not sell or share personal information as those terms are defined, we are not required to, and do not, provide a "Do Not Sell or Share My Personal Information" link. We claim that exemption on the basis that no such activity takes place.

9. Photos and the wedding photo wall

Photos you upload are used to provide the wedding photo wall, and they are shared with the members of that wedding.

Please read this honestly stated limitation. Photo storage today uses a public storage bucket. This means a photo's direct link is not access-controlled, and a person who obtains that direct link could view the photo even if they are not a member of the wedding. Please keep this in mind when deciding what to upload.

[EDITOR NOTE: This paragraph must be reconciled with the pending decision to move photo storage to a private, signed-URL bucket. If that migration is completed before publication, revise this section to describe access-controlled, signed-URL storage instead of a public bucket. Do not publish this policy without confirming which state is accurate at launch.]

After Dark photos. Photos in the After Dark area automatically delete 7 days after the wedding. See Section 10 on retention.

10. Data retention

We retain personal information according to the following criteria rather than an open-ended "as long as necessary" standard:

  • Account and wedding data are retained while the account or the wedding is active. When you delete your account, your account data is permanently deleted and you are removed from your weddings. See Section 11.
  • After Dark content automatically deletes 7 days after the wedding.
  • Legal and security holds. We may retain limited information for longer where we are required to by law, or where necessary to resolve disputes, enforce our agreements, or protect the security of the Service.

[EDITOR NOTE: A formal retention schedule is being finalized. It is expected to include criteria such as purging guest contact data and orphaned-wedding data a set number of months after the wedding date. Insert the finalized schedule here, with specific timeframes, before publication.]

11. Your rights and how to exercise them

Subject to applicable law, you have the following rights over your personal information:

  • Right to know and access: request the categories and specific pieces of personal information we hold about you.
  • Right to delete: request deletion of your personal information.
  • Right to correct: request correction of inaccurate personal information.
  • Right to data portability: receive a copy of your personal information in a portable, machine-readable format.

11.1 Deleting your account

In-app account deletion is available now. Go to Settings and choose Delete account. This permanently deletes your account and removes you from your weddings.

11.2 Downloading your data

A machine-readable export of your own data is available on request. An in-app Download my data action is being added. Until that action is live, email [email protected] and we will provide your export.

11.3 How to make a request

For any of the rights above, email [email protected]. We will verify your request in a manner consistent with applicable law, respond within the timeframes the law requires, and we will not discriminate against you for exercising your rights.

If a host entered your contact information as a guest, see Section 5 for how to make access or deletion requests for that information.

12. California privacy rights (CCPA/CPRA)

[MARKET NOTE: This section is retained pending the still-open US market decision. If the Service launches in the United States, it applies to California residents; if the launch is Canada-only, counsel should confirm whether to keep, trim, or drop it before publication.]

This section applies to California residents and supplements the rest of this policy.

12.1 Categories of personal information we collect

In the past 12 months we have collected the following categories of personal information, as those categories are described under the CCPA/CPRA:

  • Identifiers: email address, name, display name, phone number (optional), and account identifiers.
  • Customer records information (California Civil Code section 1798.80): name and phone number.
  • Commercial information: RSVP status and meal selections. (Purchase and transaction data are not collected today and will be disclosed if in-app purchases or memory-book payments go live.)
  • Internet or other electronic network activity information: messages, direct messages, channel posts, and content you create within the Service.
  • Visual information: photos you upload to the wedding photo wall.
  • Other information you provide: wedding details, budget figures, dietary preferences, and children-attending headcounts.

12.2 Sources of personal information

We collect personal information directly from you, and, where you are a guest, from the host who invited you (see Section 5).

12.3 Purposes of collection

We collect and use personal information for the business purposes described in Section 7.

12.4 Disclosure of personal information

We disclose personal information to the service providers described in Section 14, solely so they can perform services for us. We do not disclose personal information for cross-context behavioral advertising.

12.5 Sale and sharing

Hitch does not sell or share personal information, as the terms "sell" and "share" are defined under the CCPA/CPRA. We have not sold or shared personal information in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16 years of age.

12.6 Your California rights

California residents have the right to know, access, delete, correct, and obtain a portable copy of their personal information, and the right not to receive discriminatory treatment for exercising these rights. To exercise them, see Section 11. You may use an authorized agent to submit a request on your behalf, subject to verification.

12.7 Non-discrimination

We will not deny you goods or services, charge you a different price, or provide you a different level or quality of service because you exercised your privacy rights.

12.8 Sensitive personal information

We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit its use under the CCPA/CPRA.

12.9 Other California residents

[EDITOR NOTE: Confirm whether a "Shine the Light" (California Civil Code section 1798.83) disclosure is needed. Because Hitch does not share personal information with third parties for their own direct marketing, this right is not expected to apply, but counsel should confirm before publication.]

13. Canadian privacy rights (PIPEDA and Quebec Law 25)

This section applies to users in Canada, including Quebec, and supplements the rest of this policy. We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for Quebec residents, the Act respecting the protection of personal information in the private sector, as amended by Quebec's Law 25. Hitch is an Ontario company; because Ontario has no general private-sector privacy statute, PIPEDA governs our commercial handling of personal information in Ontario and across Canada, alongside substantially similar provincial laws where they apply.

13.1 Purposes of collection

We identify the purposes for which we collect personal information at or before the time of collection. Those purposes are described in Section 7.

13.2 Meaningful consent

We collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise. By providing information and using the Service, you consent to the handling of your personal information as described in this policy. Where the information is sensitive, or where it is reasonable to do so, we seek express consent.

13.3 Withdrawing consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may mean we can no longer provide some or all of the Service to you. To withdraw consent, email [email protected]. Deleting your account (Section 11) is one way to withdraw consent for continued processing.

13.4 Access, correction, and portability

You have the right to access the personal information we hold about you, to ask us to correct it if it is inaccurate, and to receive a copy of the computerized personal information you provided to us in a structured, commonly used technological format. To exercise these rights, see Section 11.

13.5 Right to complain

If you have a concern about how we handle your personal information, please contact us first at [email protected] so we can try to resolve it. You also have the right to file a complaint with a regulator:

  • In Canada generally: the Office of the Privacy Commissioner of Canada.
  • In Quebec: the Commission d'acces a l'information du Quebec.

13.6 French-language version for Quebec

A French-language version of this policy will be provided for Quebec users.

[EDITOR NOTE: Provide the completed French-language version before making the Service available to Quebec residents, and keep both versions synchronized. Quebec Law 25 also has specific requirements regarding privacy governance, a designated person in charge of protecting personal information, and privacy-impact assessments. Counsel should confirm these are addressed before publication.]

13.7 Person in charge of personal information (Quebec)

The person responsible for protecting personal information for Quebec purposes can be reached at [email protected]. [EDITOR NOTE: Confirm the name or title of this designated person before publication.]

14. Service providers and sub-processors

We use a small number of service providers to operate the Service. Each receives only the information it needs to perform its function, and each is expected to protect it and use it only on our instructions.

14.1 Providers in use today

  • Supabase (application hosting, database, authentication, and file storage). Supabase processes essentially all account data. Region: United States.
  • Apple (App Store distribution, and in-app purchases when that feature launches).

14.2 Providers used only when the matching feature launches

The following providers are not active today. We will use them only when the associated feature launches, and this policy will be updated accordingly. We list them here for transparency:

  • RevenueCat may be used when subscription and purchase management launches, to manage subscriptions and purchases.
  • Stripe may be used when the physical memory book launches, to process payments.
  • Resend may be used when transactional and invitation email launches, to send that email.
  • Twilio may be used when SMS features launch, to send text messages. SMS is not currently active.
  • Expo may be used when push notifications launch, to deliver push notifications.

To be clear, none of the providers in Section 14.2 receive your personal information today.

15. International data transfers

Hitch is a Canadian (Ontario) company, but our primary infrastructure provider, Supabase, hosts data in the United States. Your personal information will therefore be transferred to and processed in the United States. We take steps consistent with applicable law, including PIPEDA's accountability principle, to ensure a comparable level of protection when personal information is transferred to and processed by service providers across borders. By using the Service, you understand that your information may be processed in the United States.

[EDITOR NOTE: Confirm whether additional cross-border transfer disclosures or safeguards are required for Quebec Law 25 (which requires a privacy-impact assessment before transferring personal information outside Quebec in certain cases). Counsel should confirm before publication.]

16. Security

We take reasonable measures to protect personal information, including:

  • Encryption in transit using Transport Layer Security (TLS).
  • Access controls, including row-level security in our database, so that data access is restricted to the appropriate users and weddings.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please also see the honestly stated limitation about public photo storage in Section 9.

Breach notification. If a security breach affecting your personal information occurs, we will notify affected individuals and the relevant regulators where required, consistent with our obligations, including PIPEDA's breach-of-security-safeguards provisions (sections 10.1 to 10.3: report to the Privacy Commissioner of Canada, notice to affected individuals, and breach record-keeping) and Quebec Law 25's confidentiality-incident obligations (including notice to the Commission d'acces a l'information) [and, if the still-open US market decision is confirmed, applicable US state breach-notification laws such as California Civil Code section 1798.82]. We will provide the information required by law and take reasonable steps to mitigate harm.

17. Children's privacy

The Service is not directed to children. You must be at least 13 years old to use the Service. We do not knowingly collect personal information from anyone under 13, consistent with Canadian privacy guidance treating minors' personal information as sensitive [and, if the still-open US market decision is confirmed, with the Children's Online Privacy Protection Act (COPPA), a United States law]. If we learn that we have collected personal information from a child under 13, we will delete it.

Photos taken at a wedding may include minors. A parent or guardian may request removal of a photo that includes their child by emailing [email protected].

[EDITOR NOTE: Confirm the minimum-age setting and whether any additional teen-privacy provisions are needed for the target markets before publication.]

18. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate or required by law, provide additional notice. Your continued use of the Service after an update takes effect means you have reviewed the current policy.

19. How to contact us

If you are in Canada and are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada, or, if you are in Quebec, the Commission d'acces a l'information du Quebec.

Governing law: the laws of the Province of Ontario and the federal laws of Canada applicable therein; forum Toronto, Ontario. [Counsel to confirm this recital and its interaction with mandatory privacy and consumer law in Quebec and other provinces, and in US states if the still-open US market decision is confirmed.]

Legal entity details: [LEGAL NAME TBD] Inc., incorporated under the laws of the Province of Ontario, Canada. [Confirm the exact legal name, Ontario Corporation Number, CRA business number, and registered office address, to be filled before publication.]

Questions

Anything unclear? Write to [email protected]. The terms of service live alongside this policy.