PIC-TIME

BIOMETRIC DATA RETENTION POLICY

Last Updated : January 25, 2024

This biometric data retention policy ("Biometric Data Retention Policy" or "Policy") outlines the guidelines for the collection, storage, security, and retention of biometric data by Pic-Time Ltd. ("Pic-Time", "we", "us", or "our"). This Policy which is incorporated by reference in our Terms of Service , Privacy Policy, and any other terms or documentation (together "Terms"). Any capitalized terms used herein however are not defined herein shall have the meaning ascribed to it under the Terms.

CONTACT INFORMATION:

You may contact us and our privacy team by emailing our DPO: dpo@pic-time.com

BIOMETRIC DATA COLLECTION AND FOR WHAT PURPOSE :

Under this Policy "Biometric Data " means any data that is defined as "biometric data", "biometric information", "biometric identifier" or comparable term under state laws, including, but not limited to, "biometric identifiers" and "biometric information" as defined in the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq ("BIPA").

Data Processed. As part of Pic-Time's Services, Pic-Time offers Photographers the ability to group photos based on the character that appears in such photos (e.g., photos that include one or a couple of guests in the user’s wedding album). In order to enable such feature, we will process the photos and extract face data (e.g., the distance between the eyes, the shape of the nose, and other facial landmarks) that will allow us to group applicable photos.

Purpose. We will only use this information to provide you with our Services, provide the facial grouping feature.

Lawful Basis for Processing. We process such information to provide the face grouping feature, to comply with our contractual obligations towards the Photographers, and as part of delivering our Services to them. We will provide the face grouping feature subject to the Photographer enabling such feature in its sole discretion.

RETENTION PERIODS FOR BIOMETRIC DATA

Pic-Time will retain the Biometric Data for the period of the engagement between Pic-Time and the applicable Photographer. We will permanently and securely destroy the Biometric Data following the lapse of 3 years after the Photographer's account has been removed or deleted from our Platform, or earlier in case the Photographer requests to delete the account or the Biometric Data.

SECURITY MEASURES:

At Pic-Time, security is our highest priority. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards such as encryption using SSL, minimizing the amount of data that we store on our servers, restricting access to Biometric Data to Pic-Time's employees, contractors, and agents, etc. and providing access solely to authorized personnel with a legitimate interest for such access. To learn more about our security measures you can review our Security Policy .