Privacy Policy

1. Who we are and what this policy covers

GroupFaces Tecnologia Ltda. (company number [CNPJ], registered at [ADDRESS]) runs a platform that organises event photography by facial recognition: the photographer uploads the event's photos, the platform groups them by person, and each person gets a link to find their own images. This policy explains what we do with personal data in two distinct situations — the data of whoever hires the platform, and the data of whoever appears in the uploaded photographs — and applies under Brazil's LGPD (Law 13.709/2018) and the EU GDPR (Regulation (EU) 2016/679).

2. Our role in each case

We are the CONTROLLER of account data: the customer's registration, their billing history, their access records and how they use the platform. We are a PROCESSOR for the photographs and the biometric data derived from them: the person who decided to photograph an event, uploaded the images and answers for the consent of the people portrayed is the customer who hired the platform, and we handle that material only to deliver the service they asked for, on their instructions. This distinction is not a formality: a request about one specific photograph should go first to the photographer or the event organiser, and we support them in answering it.

3. Data we handle

Over the course of the relationship we handle:

• Customer account data: name, e-mail, phone, tax identification and country — the country determines the currency and how billing is collected.
• Billing data: address and identification where required to issue the charge and the invoice. Card details are typed directly into the payment processor's environment and never pass through or rest with us; we keep only the brand and the last four digits, so you can recognise a saved card.
• Photographs uploaded by the customer and the biometric data derived from them (see section 4).
• Usage and device data: IP address, browser, pages visited and actions taken on the platform.
• Security records: sign-in attempts, open sessions and events relevant to auditing.
• Preferences: language, notifications and project settings.

4. Photographs and biometric data

To group photos by person, the platform detects faces and generates, for each one, a mathematical representation (an embedding) that allows faces to be compared. That is biometric data and, under the LGPD, SENSITIVE personal data — including for people who never opened an account here, because they were photographed. An embedding is not a photograph and cannot be turned back into a face, but it identifies a person and is treated with the same care as the original image. It exists only inside the project that produced it, is never used to train models, is never combined across customers, and is never sold or handed over for advertising, surveillance or profiling of any kind. The legal basis for handling the face of someone photographed is the consent obtained by the customer who uploaded the images, who states they hold it when hiring the service (see Terms of Use); when a project is deleted, its embeddings are deleted with it.

5. What we use it for

We handle personal data in order to:

• Deliver the service: process uploaded images, group them by person, and let each person find and receive their own photos.
• Charge for what was contracted: subscriptions, credits and the corresponding tax documents.
• Communicate the essentials: payment confirmation, due-date notices, processing progress and security alerts.
• Keep the platform running and improve it: measure performance, find failures and understand which features are actually used.
• Protect the platform: prevent fraud, abuse and unauthorised access.
• Comply with legal, tax and regulatory obligations, and respond to competent authorities when required.

6. Legal basis

We rely on: (a) performance of a contract, for everything necessary to deliver and bill the service; (b) consent, for the biometric data of photographed people — obtained by the customer who uploads the images — and for usage measurement, which happens only if you accept it in the cookie notice; (c) legitimate interests, for security, fraud prevention and product improvement, always weighed against what you would reasonably expect of us; (d) compliance with a legal or regulatory obligation, including retaining issued tax documents.

7. Who we share it with

We do not sell personal data and we do not use it for advertising. To function, the platform relies on providers who handle data on our behalf, under contract, limited to our instructions. We list them by CATEGORY rather than by name, so that this policy stays true when a supplier is replaced:

• Payment processing and charge issuing.
• Cloud storage for images and generated files.
• Facial-recognition processing, which receives the images and returns the groupings.
• Transactional e-mail delivery.
• Service-invoice issuing, where applicable.
• Platform usage measurement, only if you have accepted analytics cookies.
• Public authorities, where there is a legal obligation, a court order or a legitimate investigation.
• Successors, in a corporate reorganisation, merger or acquisition, conditional on their taking on this policy.

8. International transfers

Part of the infrastructure and some providers operate outside Brazil, which can mean an international transfer of data. Where that happens we require safeguards compatible with the LGPD and the GDPR — standard contractual clauses, or transfer to a country with an adequate level of protection — and we limit what leaves to what the purpose requires.

9. How long we keep it

Every project has a lifetime set by the plan under which it was created. Once it expires, an automated routine deletes that project's photographs, derived files and biometric data, and the record that the collection was deleted remains only as evidence of the deletion. The customer can also delete a project sooner, with the same effect. Account data and financial records are kept while the account exists and, afterwards, for as long as tax and civil law require; access records are kept for the applicable legal period. Once the purpose ends and those periods lapse, the data is erased.

10. Your rights

At any time you may:

• Confirm whether we handle data about you, and access it.
• Correct data that is incomplete, inaccurate or out of date.
• Request anonymisation, blocking or erasure of data that is unnecessary or handled unlawfully.
• Request portability of your data to another provider.
• Withdraw consent, including for usage measurement, without affecting what was lawfully handled beforehand.
• Object to handling based on legitimate interests.
• Be told who we share your data with, and what follows from refusing consent.
• Lodge a complaint with the data protection authority.

11. Cookies

We use two groups of cookies. The necessary ones keep you signed in, remember the language you chose and protect form submissions — without them there is no login, which is why they are not optional. The usage-analytics ones measure which screens get used and where people get stuck; they only come into existence after you accept, they are off by default, and they can be turned off again whenever you like, in Settings. No photograph and no biometric data ever enters usage measurement.

12. Security

Passwords are stored hashed and never in the clear; integration credentials are encrypted at rest; the platform requires authentication and traffic is encrypted. Public album and payment links carry a secret in the URL itself: whoever holds the link holds the access, so treat them like a password. No measure removes risk entirely, and we will report significant incidents to you and to the competent authority where the law requires it.

13. Children and young people

The platform is not intended for anyone under 18 and we do not allow them to open accounts. Event photography may, by its nature, include children and young people: in that case consent belongs to a parent or guardian, it is for the customer uploading the images to obtain it, and a deletion request concerning a minor is handled as a priority.

14. How to reach us

Requests about personal data, questions about this policy and the exercise of the rights above: privacidade@groupfaces.io. We answer within the legal deadline. If your request concerns one specific photograph, tell us the event or the link you received — that lets us locate the project and route it to the customer responsible for it.

15. Changes

We may update this policy. Significant changes are announced on the platform before they take effect, and the date at the top marks the version in force. Continuing to use the service afterwards means agreeing to the updated text.