Cosnap Photographer Compliance & Best Practices Guide

1. Understanding Your Role

As a Cosnap Photographer, you are the Data Controller for the images you capture. This means you have the primary legal responsibility for how you collect and use people’s data. Cosnap LLC acts as your Data Processor, providing the technology to fulfill your instructions.

2. The Golden Rule: Consent Before Upload

You must never upload a photo for biometric matching unless you have a legal basis to do so.

• Private Events (Weddings, Galas, Parties): You must obtain express, written consent from every identifiable subject or their guardian.

• Public/Commercial Spaces: Where individual signatures are impossible, you must place clear, physical signage at all entrances.

3. Jurisdictional "No-Go" Zones

Biometric laws vary significantly by location. You agree NOT to use Cosnap’s facial recognition features in jurisdictions where such technology is restricted or banned.

• Restricted Areas: Portland (Oregon), and specific municipal zones in Maryland and California.

• International: Be aware of EU "AI-Free" zones and highly regulated regions.

4. Signage Best Practices

If you are relying on signage for a public event:

• Visibility: Place signs at eye level at every entrance.

• Clarity: Use high-contrast text and clear headings.

• Digital Backup: Include a link to biometric policy on event registration pages.

5. Data Minimization and Retention

• Only Upload What You Need: Upload only images intended for matching and delivery.

• Manage Your Gallery: Periodically delete unused photos to reduce liability.

• Storage: Data is securely stored on AWS S3 using AES-256 encryption.

6. Handling Disputes or Withdrawals

• Right to Withdraw: You must remove content immediately upon request.

• Accuracy Appeals: Direct users to support for manual review.

7. Protecting Yourself (Indemnification)

You agree to indemnify Cosnap LLC against legal claims resulting from failure to obtain consent or provide proper notice. Maintaining consent records for at least three (3) years is strongly recommended.

Contact for Compliance Questions

Cosnap LLC Legal Team / info@cosnap.ai