Privacy Policy for Cosnap LLC

1. Information We Collect

We collect various categories of information to provide our photo-matching services:

• Account Information: Name, email address, and encrypted password are required. Country, Date of Birth, and Phone Number may be provided optionally.

• User Content: Photos you upload or capture, and event photos uploaded by photographers for matching purposes. This includes metadata such as timestamps and geolocation data (if provided).

• Biometric Data (Sensitive Information): This is our most sensitive data category and is central to our service.

• Facial Images: We temporarily store original facial images for processing. These are retained only as long as necessary to complete the matching process.

• Facial Embeddings: We derive mathematical representations of facial features (biometric identifiers) from your photos. These are stored persistently while your account is active to enable ongoing matching.

• Technical Data: We collect IP addresses, device types, operating system versions, and diagnostic error reports.

• Payment Information: Subscriptions are processed by third-party providers (Apple In-App Purchase); we do not directly collect or store your payment details.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Core Service Delivery: Processing facial images and embeddings to match and deliver event photos to your account.

• Service Improvement: Analyzing usage patterns to improve app functionality and fix technical issues.

• Legal Compliance: Complying with regulatory requirements and protecting the safety of Cosnap, our users, and the public.

What We Do NOT Do

We explicitly do NOT sell your data, use biometric data for marketing profiling, or use your facial images to train machine learning models outside of our matching service.

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We share information only with:

• Service Providers: We use Amazon Web Services (AWS) for cloud infrastructure. AWS is bound by strict data protection agreements and never uses your biometric data for its own purposes.

• Legal Necessity: Disclosure may occur if required by law, court orders, or subpoenas.

4. Data Storage and Security

• Location: All data is stored on AWS servers located in the United States.

• Security Measures: We implement industry-standard encryption, including AES-256 at rest (AWS S3) and TLS/SSL in transit.

• Access Controls: Strict controls limit data access to authorized personnel and necessary app functions only.

5. Data Retention and Deletion

• Biometric Identifiers: Facial embeddings are stored only as long as your account is active.

• Account Deletion: You can delete your account and all associated data through the app settings (Settings > Account > Delete Account).

• Purge Timeline: Upon deletion, embeddings, matched photos, and account information are removed from active systems within 30 days. Backup copies in disaster recovery systems are permanently purged within 90 days.

6. Your Rights and Choices

Depending on your location, you may have the following rights:

• Access & Portability: Request a copy of your personal data in a machine-readable format.

• Opt-Out: You can disable facial recognition in your Settings at any time, though this prevents core functionality.

• Marketing: Unsubscribe from promotional communications via the unsubscribe link in our emails.

7. Biometric Compliance (BIPA, CCPA, GDPR)

We comply with biometric privacy laws including Illinois BIPA, California CCPA/CPRA, and the EU GDPR. By enabling facial recognition and uploading photos, you:

• Consent to our collection and use of biometric identifiers as described.

• Represent that you have obtained necessary consent from any other individuals in photos you upload.

8. Children’s Privacy

Cosnap is not intended for children under the age of 13. We do not knowingly collect personal information from children.

9. Contact Us

If you have questions, concerns, or wish to exercise your data rights, please contact us: info@cosnap.ai / https://cosnap.ai / Subject Line: Please use "Privacy Request" for inquiries.