Thank you for choosing to be part of our community at Findphoto LLC ("Company", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regards to your personal information, please contact us at hello@findphoto.ai

When you visit our website https://findphoto.ai (the "Website"), use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as, any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. SPECIAL PROVISIONS REGARDING FACIAL RECOGNITION DATA

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES AND DATA SHARING?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

11. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us

In Short:
We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You.
We collect names; phone numbers; email addresses; passwords; usernames; contact preferences; contact or authentication data; billing addresses; debit/credit card numbers; photos; biometric identifiers and biometric information including faceprints, fingerprints and voiceprints; and other similar information.

This also includes data categories defined under Turkish Law No. 6698 (KVKK) and GDPR Article 4:
• Identity and Contact Data: name, surname, date of birth, gender, address, business information, and communication preferences.
• User and Transaction Data: membership ID, timestamps of service use, search/filter preferences, visited pages, invoice numbers, payment receipts, refund details, and account balance information.
• Facial Recognition (Biometric) Data: facial structure, hair attributes, face geometry, expressions, accessories, gender, age, or other appearance details captured via AWS Rekognition and stored only for up to 1 month for inactive users.

The event host and/or the photographer shall ensure that they have obtained the event attendee’s consent before sharing any personal information belonging to such event attendee with us.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short:
Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data.
Service-related, diagnostic, and performance data automatically collected by our servers when you access or use our Services.
This includes IP addresses, session tokens, device identifiers, system activity logs, error reports, and analytics.

Under KVKK and GDPR, this corresponds to:
• Transaction and Security Data: open/closed session information, masked passwords, IP identifiers, and cookie/session logs used for risk and fraud management.

Device Data.
We collect device data such as information about your computer, phone, tablet, or another device you use to access the Services.
This includes device and application identifiers, browser type, OS version, and carrier details.

Location Data.
We collect approximate or precise location information (GPS, IP, or Wi-Fi) depending on your device settings. You may refuse access or disable Location in your settings.

• Location Data (KVKK Art. 5(1)): approximate or precise geolocation data obtained only with your consent.

Information collected through our App

In Short:
We collect information regarding your geolocation, mobile device, and push notifications when you use our App.

If you use our App, we also collect the following information:

Geolocation Information.
We may request access or permission to track your location continuously or while you are using our App.

Mobile Device Access.
We may request permission to access your camera (for selfie verification), storage, SMS messages, or photo gallery — these are used only for event photo matching or account verification.

Mobile Device Data.
We collect device identifiers, OS version, network provider, and hardware model for system diagnostics.

Push Notifications.
We may send you account or app notifications; you can disable these anytime in your settings.

These also include User-Generated Content, such as:
• Event names, dates, and locations;
• Uploaded photos or shared visuals linked to event participation.

Information collected from other sources

In Short:
We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

This includes mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, and social media profiles, to ensure better event communication and partnership management.

• Marketing and Communication Data: user interests, push notification preferences, segmentation or targeting information, and cookie records.
• Complaint Management Data: support tickets, reports, and user-submitted inquiries via email or app interface.

Any personal information collected from social media depends on your platform privacy settings.

Privacy of Children

We recognize the importance of children's safety and privacy. We do not request or knowingly collect any personal information from children under the age of 18.
If a parent or guardian becomes aware that his or her child has provided us with personal information, they should contact us at the email address provided in clause 12.

2.  HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us at hello@findphoto.ai and be sure to include your name, testimonial location, and contact information.

Request feedback. We may use your information to request feedback and to contact you about your use of our Services.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To deliver and facilitate the delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences.

For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information. We will not use identifiable personal information without your consent.

3.  WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

 We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

We will share your personal information with our group companies and third-party service providers so that they may offer you our Service(s) and/or to send information or updates on the Service(s) if you are a user.

We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

When we process your order where you are a user, we may send your personal information to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.

We share personal information with our third-party service providers that host and maintain our Website(s), applications, backup, storage, payment processing, analytics and other services. These third-party service providers may have access to or process your personal information for the purpose of providing these services to us.

We may share your personal information with third-party providers who assist us in marketing and promotions in compliance with applicable laws.

We may also share personal information to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law.

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Offer Wall. Our App may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such a website. Accordingly, we do not make any warranty regarding such third-party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.

4.SPECIAL PROVISIONS REGARDING FACIAL RECOGNITION DATA

 Facial recognition and similar data may be considered special category personal data under applicable data protection laws.
Explicit consent is obtained from the data subject prior to the collection of any facial recognition or biometric data.

Once collected, such data is not shared with any third parties. However, anonymized and aggregated outputs — which contain no personally identifiable or facial information — may be shared with business partners or service providers solely for statistical analysis or service optimization purposes.

5.  DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may collect personal information automatically from you through cookies and similar tracking technologies (like web beacons and pixels). We also set cookies to collect information that is used either in aggregate form to help us understand how our Website(s) are being used or how effective our marketing campaigns are, to help customise the Website(s) for you or to make advertising messages more relevant to you.

Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, you may disable these by changing your browser settings, but this may affect how the Website(s) functions.

Analytics, Customisation and Advertising Cookies: We set these cookies to help us improve our Website(s) by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone.

If you choose to remove cookies or reject cookies, this could affect certain features or services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES AND DATA SHARING?

In Short:
We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.

The Services may contain advertisements or integrations from third parties that are not affiliated with us and which may link to other websites, online services, or mobile applications.
We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

Third-Party Data Processors and Transfers

In addition to general third-party websites, FindPhoto works with certain authorized service providers to ensure the secure operation of its Services.
Your personal data may be shared or processed by the following categories of third parties, always within the limits of necessity, proportionality, and purpose limitation principles:

• Technology Infrastructure Providers:
  Secure storage and image processing are handled by Amazon Web Services (AWS S3, AWS Rekognition). These services enable FindPhoto to host encrypted facial vectors and event photos safely in compliance with ISO 27001 standards.

• Payment Service Providers:
  Financial transactions are processed by İyzico (licensed under the Central Bank of Turkey).
  FindPhoto itself does not store or retain credit or debit card data. Payment information is transmitted directly to the payment processor through secure encrypted channels (PCI-DSS compliance).

• SMS and Communication Providers:
  Verification and notification messages (such as OTP codes or updates) are sent via Netgsm and similar licensed operators, used solely for account authentication or user notification purposes.

• Analytics and Advertising Technologies:
  Statistical, diagnostic, and marketing insights may be processed through tools such as Google Analytics and other lawful advertising partners, subject to explicit cookie consent. No raw or identifying biometric data is shared for marketing purposes.

• Business Partners, Event Organizers, and Suppliers:
  Data may be shared only to facilitate event-based photo uploads, technical support, or system integrations under written data processing agreements.

• Public Authorities and Legal Entities:
  We may disclose personal data to courts, regulators, or competent authorities if required by law, judicial order, or administrative enforcement.

All such transfers are made under strict confidentiality obligations and appropriate technical and organizational safeguards (

International Data Transfers

These parties may store or process your personal information in or outside of Turkey, including in data centers located in the European Union (Ireland) or United States (Virginia).
Whenever personal data is transferred internationally, FindPhoto applies lawful transfer mechanisms such as:

• GDPR Article 46: Standard Contractual Clauses (SCCs),

• GDPR Article 49: Explicit user consent where applicable,

• KVKK Article 9: Data transfer commitments approved by the Turkish Data Protection Authority (KVKK Kurulu),

• CCPA §1798.100(e): Reasonable security procedures and no sale of personal information.

All third parties are contractually bound to process personal data only for the specific purposes defined by FindPhotoand to delete or anonymize it after use.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Facial Recognition Data (Biometric Information):
For inactive users, facial recognition and biometric data (including face embeddings and vectors processed through AWS Rekognition) are automatically deleted within one (1) month from the date of inactivity or event completion.

Photo and Event Data:
Photo datasets, event archives, and image files associated with user activity are retained for up to one (1) year from upload or event completion, after which they are permanently deleted or anonymized unless a legal or regulatory obligation requires a longer retention period.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8.  HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational and technical security measures. 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, 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. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9.  WHAT ARE YOUR PRIVACY RIGHTS? 

In Short: You may review, change, or terminate your account at any time. 

1.     You can request us for access, correction, update or request deletion of your personal information.

2.     You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information to the extent mandated under applicable law.

3.     You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.

4.     Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we have conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

5.     You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

6.     If you seek access to, or wish to correct, update, modify or delete your personal information that we process, please contact us at the details provided in clause 12. We respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11.   DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@findphoto.ai or by post to:

Findphoto LLC
8 The Green STE B Dover, DE 19901

13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request to hello@findphoto.ai . We will respond to your request within a reasonable time frame and in accordance with applicable data protection laws.