Photohawk Family: Face Data Policy

Version: 1.0
Effective date: 20 October 2026
Applies to: the Photohawk Family app for iPhone and Android (in the app stores as "Photohawk: Family Photos"; "the app") and its cloud face-matching service, made by CLOUDCONCUR LTD (company no. 13399913), trading as Photohawk ("Photohawk", "we", "us").
Published at: photohawk.com/face-data-policy/family

This is the Photohawk Family part of Photohawk's face data policy (photohawk.com/face-data-policy). Photohawk Studio, for event and business galleries, has its own section there. The two are separate: face data is never shared, mixed or matched between Photohawk Family and Photohawk Studio.

This policy explains what face data the app creates, why, where it is kept, and when it is destroyed. It is written to meet the Illinois Biometric Information Privacy Act (BIPA) standard for a publicly available written policy with a retention schedule and destruction guidelines, and similar laws elsewhere, even though the app is not offered with face grouping in Illinois.

1. What "face data" means here

When face grouping is on, the app creates, on your phone:

• Face templates: for each face it finds in a photo or video, a list of numbers (a mathematical representation of the face) that lets the app tell whether two faces are likely the same person. A face template cannot be turned back into a photo of the face.
• Face positions: where in each photo, and when in each video, the faces are.
• Groups: which faces the app thinks belong to the same person, the corrections you make ("not this person", merging two groups), and the names you give the groups.

When cloud face matching (below) is on and working, the grouping is done in the cloud and the phone makes face templates only if the cloud cannot be used.

If you also agree to cloud face matching (section 4), these are created in our cloud face-matching service as well:

• Face cut-outs: small pictures of each face the phone found (the face and a margin around it, 160 pixels across), sent in batches. Never whole photos or videos.
• Cloud face templates and groups: the templates the service makes from the cut-outs, and which of them are the same person.

Together these are "face data". Face data is a kind of biometric identifier or biometric information under some laws, and special category (biometric) data under the EU and UK GDPR.

The app also finds people (whole bodies, without identifying anyone) and things (like dogs or bikes) in your photos. That does not use face data and works whether face grouping is on or off.

2. Consent first

The app creates no face data unless you agree, and asks twice, separately:

1. Face grouping (on your phone): a consent screen explains this policy; you tick a box and turn face grouping on. If you choose "Not now", no face detection runs at all.
2. Cloud face matching: right after, a second screen explains in plain words that small face cut-outs (never your photos) go to our secure cloud face-matching service (Amazon Web Services), that we keep the face data there so new photos can be matched, and that it is deleted if you turn this off or delete your account. "Continue" turns it on; "Keep it on my phone only" keeps everything on your phone. You can change this at any time in Settings.

We rely on your explicit consent (GDPR Art. 9(2)(a), and the equivalent in other laws) for both. The app records, on your phone, that you agreed, when, and which version of the wording you agreed to; for cloud face matching our service also records the version and time, and where you told the app you live. If the wording changes, the app asks again. Face grouping and cloud face matching are part of the Personal and Family plans.

3. Purpose

Face data is used only to:

1. group your photos and videos by the people in them;
2. let you search your photos and videos by person; and
3. help you choose which photos to share with the people in them, if you decide to share.

Face data is never used for advertising, marketing, profiling, identity verification, to identify anyone to Photohawk or anyone else, to match faces across different users, or to train or improve models. It is never compared with, or added to, the face data of Photohawk Studio galleries.

4. Where face data is kept

On your phone. Face data made by the app is stored in the app's private storage, protected by the phone's app sandbox and storage encryption, and excluded from iCloud and iTunes/Finder backups on iPhone and from Android cloud backup and device-to-device transfer. Names and corrections stay only on your phone.

In the cloud, only with cloud face matching.

• The phone sends face cut-outs, in batches of up to 80, to Photohawk's service, which uses Amazon Rekognition (Amazon Web Services, EU (Ireland) region) as our processor.
• Each cut-out batch is deleted as soon as its faces are matched (within minutes; an automatic rule deletes anything left after a day).
• The face templates are kept in a store that holds only your faces; they are never compared with anyone else's faces or with Photohawk Studio's.
• We never receive your photos or videos, and the service never receives the names you give people.

Not in shares. When you share photos, only the photos you choose are sent (encrypted end to end). Face templates, face positions, groups and group names are never part of a share.

5. Retention schedule and destruction

Face data is kept only as long as needed for the purposes above, and is permanently destroyed at the earliest of:

Deletion on the phone removes the face templates, face positions, groups, names and corrections, and then securely compacts the app's database so the deleted records are overwritten. Deletion in the cloud removes your whole face store at Amazon Rekognition (every template) and our records of it. Deleting face data never deletes photos or videos.

Texas and Washington. Face data is destroyed as soon as its purpose ends (cloud face matching or face grouping turned off, the account deleted, a deletion request), and in any case within the periods above, which are shorter than the "reasonable time, no later than one year after the purpose expires" required by Texas (Bus. & Com. Code § 503.001) and the equivalent rule in Washington (RCW 19.375). In all cases face data is destroyed no later than 3 years after your last use of the app.

6. No sale, no disclosure

Photohawk does not and will not sell, lease, trade or otherwise profit from face data. Face data in the cloud is processed by Amazon Web Services only on our instructions, under its data processing terms, to provide cloud face matching to you. We don't disclose face data to anyone else unless the law requires it.

7. Not available in Illinois

Face grouping, and so cloud face matching, is not offered to people who tell the app they live in Illinois. Illinois law asks for written consent from everyone whose face is in your photos, not only from you, and the app cannot yet obtain that properly. The app asks where you live when you first open it. It does not use GPS or your IP address for this. If you say you live in Illinois, face grouping stays off (our service also refuses cloud matching for Illinois), and if you later change to Illinois, existing face data is deleted, on the phone and in the cloud.

8. Other people in your photos

Your photos and videos may include people who don't use Photohawk. The app creates face data for every face it finds, for your own use as described above: on your phone, and with cloud face matching in your own face store in the cloud. It is never used to identify anyone to Photohawk or to other users, and is deleted on the schedule above. Please use face grouping and sharing respectfully, and only share photos you have the right to share.

9. Your choices

• Turn face grouping on or off at any time in Sharing and privacy.
• Turn cloud face matching on or off at any time in Sharing and privacy; turning it off deletes the cloud face data and keeps grouping on your phone.
• Delete all face data (on the phone and in the cloud) at any time in Sharing and privacy, without turning the rest of the app off.
• Remove a face from a group ("not this person"), merge groups, hide or rename people.

Face data on your phone is under your control there. For face data in the cloud you can also ask us to access or delete it (support@photohawk.com); deletion requests are carried out by deleting your whole cloud face store.

10. Changes

If we change this policy in a way that affects face data, the app will ask for your consent again before creating or sending any more face data.

Version history: 1.0, 20 October 2026: first published version (until then this policy was a draft).

11. Contact

CLOUDCONCUR LTD (company no. 13399913), trading as Photohawk, 23 Caldey Gardens, Ingleby Barwick, Stockton-on-Tees, TS17 5HW, United Kingdom. Email: support@photohawk.com.