PRIVACY NOTICE

1. WHAT INFORMATION DO WE COLLECT?

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, use our features, or contact us. The personal information we collect may include the following:

• Email addresses
• Facial photos — uploaded to generate your ID photo. These photos may constitute biometric data.

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 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, 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.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user
• To fulfill and manage your orders
• To respond to user inquiries and resolve issues
• To send administrative information (confirmations, download links)
• To improve our Services via user behavior analysis
• To comply with our legal obligations

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. 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.
• Service Providers. We share your data with our technical providers: Stripe (payments), Google Cloud Platform (AI hosting and photo storage), Google Analytics (analytics), Google Ads (advertising), Vercel (hosting), Supabase (database), Resend (emails).

4. 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 use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

We do not currently offer social media login. Authentication is handled exclusively by email via Supabase.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States and the European Union. If you are accessing our Services from another region, please be aware that your information may be transferred to these countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not necessarily have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law. Transfers are governed by the European Commission's Standard Contractual Clauses.

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).

In particular: your photos are deleted within 24 hours of processing unless you explicitly consent to longer storage. Account data is retained as long as your account is active. Analytics data (Google Analytics) is retained for 26 months. Billing data is retained for 10 years.

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, we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@get-passport-photo.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or your country, you may have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time. If you would at any time like to review or change the information in your account or terminate your account, you may contact us. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us. This will not affect the lawfulness of processing before its withdrawal.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority, including the CNIL in France (https://www.cnil.fr).

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 "Last updated" date at the top of this Privacy Notice. 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 contact us by email or by post:

Serhat Y.

get-passport-photo.com

Paris, France

contact@get-passport-photo.com

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, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit a request by email to contact@get-passport-photo.com.