Face data policy

1. What face data is made

• Face templates: numerical representations of the faces detected in a gallery's photos, held in that gallery's face-search index (Amazon Rekognition) or, for galleries on one of our own face models, as face vectors.
• The face archive: small face crops kept privately so a gallery's face search can be rebuilt without re-reading the original photos. It is never shown to anyone or served publicly.
• Selfies used to search are not face data we keep: a selfie is compared with that gallery's face templates and then discarded. It is not stored and no face template is made from it.

Finding people in photos (whole bodies, without identifying anyone) and reading bib numbers and text do not use face data. Bib/number search is not affected by this policy.

2. Where it is processed

• In Photohawk's cloud on Amazon Web Services in the European Union (Ireland, eu-west-1), after a photo is uploaded.
• Each gallery has its own face-search index (an Amazon Rekognition collection). A selfie is only ever searched against the gallery it was taken for.
• To save time, Photohawk Studio's upload apps may find faces on the computer or phone doing the upload and send small face crops with the photo. Face templates are always made in our cloud.

3. What it is used for, and never used for

Face data is used only so that people can find their own photos in that gallery with a selfie.

It is never sold, never used for advertising, never used to identify anyone outside the gallery, and never mixed with or matched against Photohawk Family's face data.

4. How long it is kept, and when it is deleted

From 1 November 2026 face data is permanently deleted at the earliest of:

• 12 months after the photo was uploaded (photo by photo, even if the gallery stays online);
• 30 days after the gallery is closed or deleted, or after face search is switched off for it (cancelled if the administrator reopens it or switches face search back on within those 30 days);
• 30 days after a person asks us to delete their face data or withdraws their consent;
• 45 days after our yearly review finds it is no longer necessary.

Until 31 October 2026, face data is deleted when a gallery ages out (within about 60 days) and when a gallery is deleted. Face templates are not backed up, so a deletion is final; our database backups hold only references to faces (never templates) and are purged within 35 days. Photos, sales, downloads and bib search are not affected.

The full retention schedule and how deletion works: Biometric data retention policy

5. Legal basis and consent

Face data is special category (biometric) data under the EU and UK GDPR, and is processed on the basis of the individual's explicit consent (Art. 9(2)(a)). For people in a gallery, the gallery's administrator is the controller and is responsible for obtaining that consent before switching face search on; Photohawk processes the data on their behalf, under a data processing agreement. Before a selfie is used, the person searching is asked to consent and can decline. Consent can be withdrawn at any time (see §8).

6. Illinois and other US states

This policy and the biometric data retention policy are our public written retention schedule. The deletion limits in §4 fall within the deadlines of the Illinois Biometric Information Privacy Act (BIPA: when the purpose is satisfied or within 3 years of the person's last interaction), the Texas CUBI, the Colorado Privacy Act and Washington's RCW 19.375. The 12-month limit is Photohawk's own choice; no law prescribes it.

7. Who processes it

Amazon Web Services (Amazon Rekognition and storage), EU (Ireland) region, as our sub-processor, only on our instructions. We don't disclose face data to anyone else unless the law requires it.

8. Requests and contact

• In the gallery: open selfie search and choose “Make a request”. It goes to the gallery's administrator and to Photohawk.
• By email: support@photohawk.com, telling us which gallery or event it concerns. We act on the request within 30 days.
• CLOUDCONCUR LTD (company no. 13399913), trading as Photohawk, 23 Caldey Gardens, Ingleby Barwick, Stockton-on-Tees, TS17 5HW, United Kingdom. Email: support@photohawk.com.

1. What face data is made

• With face grouping on, on your phone: face templates (a list of numbers for each face found), where the faces are in each photo or video, and which faces belong to the same person. The names and corrections you add stay only on your phone.
• With cloud face matching on as well: small face cut-outs (never whole photos or videos) and the face templates and groups our cloud service makes from them.

Finding people (whole bodies, without identifying anyone) and things in your photos does not use face data and works with face grouping off.

2. Where it is processed

• On your phone: faces are found on the phone, and face data is kept in the app's private storage, excluded from phone backups.
• In the cloud, only with your consent to cloud face matching: face cut-outs go to your own face collection at Amazon Rekognition (Amazon Web Services, EU (Ireland) region), which holds only your faces. The cut-outs are deleted as soon as they are matched (anything left is deleted after a day).
• Without that consent, everything stays on your phone. We never receive your photos or videos, and never the names you give people.

3. What it is used for, and never used for

Face data is used only to group your photos and videos by the people in them, to let you search by person, and to help you choose which photos to share.

It is never sold, never used for advertising, profiling or identity checks, never used to identify anyone outside your own photos, never matched across different users, never used to train models, and never mixed with or matched against Photohawk Studio's face data. It is never part of a share.

4. How long it is kept, and when it is deleted

On your phone, face data is kept until you turn face grouping off (or tap “Delete all face data”), delete the app, or don't use Photohawk for 3 years. A photo's face data goes when the photo leaves your phone.

In the cloud, face data is deleted when you turn cloud face matching or face grouping off, when you delete your Photohawk account, when you ask us to (within 30 days), after 3 years without using Photohawk, and 30 days after your plan ends unless you subscribe again before then.

Cloud deletion removes your whole face collection. Deleting face data never deletes photos or videos.

5. Legal basis and consent

We rely on your explicit consent (GDPR Art. 9(2)(a), and the equivalent in other laws), asked for twice and separately: first for face grouping on your phone (the box starts unticked; “Not now” means no face detection at all), then for cloud face matching (“Continue”, or “Keep it on my phone only”). You can change either at any time in the app's settings. If the wording changes, the app asks again.

6. Illinois

Face grouping, and so cloud face matching, is not offered to people who tell the app they live in Illinois (the app asks; it does not use GPS or your IP address). Our service refuses cloud matching for Illinois too, and if you change where you live to Illinois, existing face data is deleted on the phone and in the cloud.

7. Who processes it

Only with cloud face matching: Amazon Web Services (Amazon Rekognition), EU (Ireland) region, as our processor, only on our instructions. Face data on your phone is never sent to anyone.

8. Requests and contact

• In the app: turn cloud face matching or face grouping off, or tap “Delete all face data”.
• By email: support@photohawk.com, to access or delete your face data in the cloud.
• CLOUDCONCUR LTD (company no. 13399913), trading as Photohawk, 23 Caldey Gardens, Ingleby Barwick, Stockton-on-Tees, TS17 5HW, United Kingdom. Email: support@photohawk.com.