Privacy Policy

1. Who we are

Foto is a photo and video delivery platform for photography studios. Studios upload event galleries, and our AI matches each guest with the photos they appear in. This Privacy Policy explains what personal data we collect, why we collect it, and the choices you have.

This policy covers two groups of people: the photography studios that hold an account with us ("Studios"), and the event guests who use a studio's shared gallery to find their own photos ("Guests").

2. Information we collect

We collect the following categories of information:

• Account information (Studios): name, email address, password or Google sign-in identifier, studio profile details such as phone number, address, website, and logo.
• Billing information (Studios): subscription plan and payment status. Card payments are processed by our payment provider, Stripe — we never store full card numbers on our servers.
• Uploaded content (Studios): the photos and videos a studio uploads, along with related metadata such as event name, date, location, and category.
• Biometric face data (Guests): to match a guest to their photos, our face-recognition provider analyses faces in uploaded photos and in the selfie a guest submits, producing numeric face templates. See the dedicated section below.
• Liveness check data (Guests): for face-protected galleries, a short liveness check confirms a real person is present. We retain only the result and timestamp, not the selfie frames.
• Usage and device data: log data such as IP address, browser type, pages viewed, and approximate location, collected to operate and secure the service.
• Cookies and similar technologies: see our Cookie Policy for details.

3. Biometric and face data

Because matching guests to their photos is the core of our service, we want to be especially clear about face data.

• When photos are uploaded, our face-recognition provider (Amazon Rekognition) detects faces and creates numeric face templates. These templates are mathematical representations — not images — and are used only to match a guest to the photos they appear in.
• When a guest searches a gallery, they submit a selfie. A face template is generated from that selfie and compared against the event's templates to return matching photos.
• Face templates are stored against the relevant event and are deleted when the studio deletes the photo, the event, or its gallery.
• We do not sell biometric data, and we do not use it to identify individuals outside of returning their own photos within the gallery they were invited to.

If you are a guest and want your face data removed, contact the studio that ran the event, or contact us using the details below.

4. How we use information

• To provide the service: host galleries, match guests to photos, and deliver downloads.
• To manage accounts, subscriptions, and billing.
• To secure the platform, prevent abuse, and troubleshoot problems.
• To communicate with Studios about their account, including service and transactional emails.
• To comply with legal obligations and enforce our Terms of Service.

5. Legal bases for processing

Where applicable law requires a legal basis, we rely on: performance of our contract with Studios; your consent (for example, the explicit consent a guest gives before submitting a selfie for face matching); our legitimate interests in operating and securing the service; and compliance with legal obligations.

6. How we share information

We do not sell your personal data. We share data only with service providers that help us run the platform, and only as needed:

• Amazon Web Services — face recognition (Rekognition) and related processing.
• Cloudflare R2 — secure storage and delivery of uploaded photos and videos.
• MongoDB — database hosting for account and event data.
• Stripe — subscription billing and payment processing.
• Email and infrastructure providers — to send transactional emails and operate the service.

We may also disclose information if required by law, to protect our rights, or in connection with a merger, acquisition, or sale of assets.

7. Data retention

We keep personal data for as long as needed to provide the service. Uploaded photos, face templates, and event data are retained until a Studio deletes them or closes its account. Account and billing records may be retained longer where required for legal, tax, or accounting purposes.

8. Your rights

Depending on your location, you may have rights to access, correct, delete, or export your personal data, to object to or restrict certain processing, and to withdraw consent. To exercise these rights, contact us using the details below. Guests should note that a studio controls the galleries it creates; we will work with the relevant studio to honour valid requests.

9. Security

We use technical and organisational measures — including encryption in transit, access controls, and trusted infrastructure providers — to protect personal data. No method of transmission or storage is completely secure, but we work to protect your information and review our practices regularly.

10. International transfers

Our service providers may process data in countries other than your own. Where we transfer personal data internationally, we take steps to ensure it remains protected in line with applicable law.

11. Children

Our service is intended for studios and adult users. It is not directed to children, and we do not knowingly collect personal data directly from children. Event photos may include minors; studios are responsible for having the appropriate rights and permissions for the content they upload.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the date at the top of this page and, where appropriate, notify you. Continued use of the service after changes take effect means you accept the updated policy.