Privacy Policy & Biometric Ethics
Built on strict photographer data sovereignty. BestShots acts as a Data Processor for your clients' photos, facial analysis is isolated within each project with zero cross-account tracking, and we enforce a strict 30-day hard deletion protocol.
Photographer is Data Controller
You control client media. BestShots acts strictly as a Data Processor executing your instructions under Article 28 GDPR.
Isolated Biometric Analysis
SCRFD face detection and ArcFace 512-d embeddings are used solely for burst curation within that project. Never shared or matched across accounts.
No Behavioral Ad Tracking
We do not sell, rent, or share personal data or customer photos with third-party advertisers or data brokers.
Google Limited Use Certified
Strict adherence to Google API Services User Data Policy for Google Photos Picker media. Never used for model training.
30-Day Hard Erasure
When you delete a photo, project, or account, all underlying blobs, vectors, and database records are permanently purged within 30 days.
Cryptographic Isolation
FIPS 140-2 AES-256 encryption at rest, TLS 1.3 in transit, and short-lived Azure Shared Access Signature (SAS) tokens.
1. Introduction & Overview
BestShots.AI ("BestShots", "Company", "We", "Us", or "Our") respects the fundamental privacy of photographers and the individuals they photograph. This Privacy Policy details how we collect, process, store, and safeguard personal information and visual media across our web platform, APIs, and cloud infrastructure.
We are committed to operating in full compliance with global privacy regulations, including the European Union General Data Protection Regulation ("GDPR"), the United Kingdom Data Protection Act, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Illinois Biometric Information Privacy Act ("BIPA"), and the Google API Services User Data Policy.
2. Controller vs. Processor Separation
Data protection statutes establish clear legal distinctions between entities that determine the purposes and means of processing ("Data Controllers") and entities that process data on their behalf ("Data Processors"):
Customer Visual Media & Client Photos
Photographer is Data Controller: You determine which photos to upload and curate. You are responsible for obtaining lawful consent, model releases, and client authorization.
BestShots is Data Processor: We process Customer Photos strictly pursuant to your documented instructions to perform culling, thumbnail generation, and XMP export under Article 28 GDPR.
Account, Billing & Identity Data
BestShots is Data Controller: With respect to your photographer account credentials, name, email address, password hashes, IP addresses, subscription tier, and Stripe transaction logs, BestShots acts as an independent Data Controller.
3. Categories of Data Collected
We collect and process the following categories of data:
| Category | Examples | Source & Purpose |
|---|---|---|
| Photographer Identity | Full name, email address, hashed passwords, OAuth profile ID (Google/Microsoft) | Direct registration / authentication and account notifications |
| Billing & Credits | Stripe Customer ID, payment timestamps, credit balance, consumption logs (1 photo = 1 credit) | Payment processing, invoicing, tax compliance, atomic failure refunds |
| Customer Photos | Camera RAW files (CR3, ARW, NEF, DNG), JPEGs, WebP proxies, camera EXIF metadata | Uploaded by photographer solely for automated analysis and curation |
| Facial Embeddings | 512-dimensional vector embeddings, bounding boxes, facial landmarks (eyes, nose, mouth) | Generated ephemerally via SCRFD/ArcFace for project burst clustering and face filters |
| Telemetry & Usage | IP address, browser user-agent, operating system, culling hotkey telemetry | Session security, rate-limiting, and error diagnostics |
4. Biometric & Facial Analysis Disclosures
BestShots.AI incorporates computer vision technology to assist photographers in identifying closed eyes, expression flaws, focus sharpness, and grouping burst sequences. To provide complete transparency regarding our facial analysis pipeline:
Technical Architecture & Models
We utilize modern open-source neural network models: SCRFD for face detection and landmark localization, and ArcFace for generating compact 512-dimensional numerical vector representations. Inference is executed strictly in isolated Azure Functions v4 runtimes without transmitting image data to external commercial facial recognition vendors.
pgvector solely to enable subject filtering (e.g., clustering photos of the bride, groom, or keynote speaker) and burst-stacking within that specific project.WHERE user_id = :id AND project_id = :id. Face vectors from one photographer are NEVER compared against another photographer's projects.5. Irrevocable Prohibition on AI Model Training
BestShots.AI guarantees that Customer Photos, cropped faces, visual embeddings, and extracted metadata are NEVER used to train, fine-tune, distill, evaluate, or improve any artificial intelligence, neural network, or machine learning models.
Where cloud AI models (such as GPT-5-Mini via Azure AI Foundry / Azure OpenAI) are invoked to evaluate composition, sharpness, or expression nuance, processing is executed strictly under enterprise zero-retention agreements. Image payloads reside strictly in volatile memory for the duration of the HTTP inference round-trip and are discarded immediately upon response delivery.
6. Google User Data Policy Limited Use Disclosure
BestShots.AI provides an optional Google Photos integration allowing photographers to import shoot galleries directly into their BestShots workspace using the Google Photos Picker API.
When connecting your Google account, BestShots requests access solely to the following sensitive OAuth scope:
BestShots.AI's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements:
- Specific Item Access Only: We only access and ingest media items that you explicitly select through the Google Photos picker interface. We never access your broader Google Photos library or albums.
- No Third-Party Transfers: Google user data is never transferred to third parties, advertisers, or data brokers.
- Zero Advertising Use: Google Photos data is never used to serve targeted, personalized, or retargeted advertising.
- Zero Model Training: Google Photos data is never used to train, retrain, or improve any generalized artificial intelligence or machine learning models.
- Human Inspection: Human personnel do not inspect your Google Photos unless specifically requested by you for technical support or as required by law.
7. Purposes of Processing & Legal Bases (GDPR)
Under European data protection laws, we process personal data only when a recognized legal basis applies:
8. Cloud Infrastructure & Authorized Subprocessors
To deliver a resilient, enterprise-grade culling platform, BestShots engages trusted third-party infrastructure providers ("Subprocessors"). Each Subprocessor is bound by strict Data Processing Agreements (DPAs) incorporating Standard Contractual Clauses:
| Subprocessor | Function | Location | Retention Policy |
|---|---|---|---|
| Microsoft Azure | Cloud storage (Blob Storage), queue orchestration (Queue Storage), serverless execution (Azure Functions), and ephemeral AI inference (Azure AI Foundry / GPT-5-Mini) | United States & Global Regions | Zero Data Retention (ZDR) for inference; project lifecycle for blobs |
| Neon Inc. | Serverless PostgreSQL relational database hosting and pgvector similarity index storage | United States (AWS us-east-2) | Active account lifecycle + 30-day hard deletion purge cycle |
| Vercel Inc. | Web application hosting, edge network routing, SSL termination, and Next.js server-side rendering | Global Edge Network | Ephemeral HTTP logs (purged within 30 days) |
| Stripe Inc. | Secure credit pack payment processing, PCI-DSS compliant credit card tokenization, and tax calculation | United States & Global | Statutory accounting and tax record requirements (up to 7 years) |
| Resend Inc. | Transactional email delivery (email verification, password resets, account security notices, credit receipts) | United States | Transient delivery logs (30 days) |
| Atlassian Inc. (Jira Cloud) | Bug reporting, user feedback triage, and support ticket coordination (applies strictly to user-submitted feedback and diagnostic metadata) | United States & Global Cloud | Engineering resolution and support ticket lifecycle |
9. Data Retention & 30-Day Hard Deletion Protocol
We practice data minimization. Visual media and metadata are retained only as long as necessary to fulfill curation workflows:
photo_faces vector embeddings from PostgreSQL pgvector and delete original blobs and thumbnails from Azure Blob Storage.10. Your Rights (GDPR, CCPA/CPRA & Global Privacy)
Depending on your jurisdiction, you possess fundamental statutory rights regarding your personal information:
To exercise any of these rights, submit a verified request to privacy@bestshots.ai. We do not discriminate against photographers for exercising their privacy rights.
11. Technical & Cryptographic Security Measures
We maintain rigorous physical, electronic, and procedural safeguards:
- Encryption: All storage volumes, database clusters, and backups use AES-256 encryption. All web and API traffic is enforced over TLS 1.3.
- Access Control: Zero static public URLs for client photos. Access tokens (Azure SAS) expire in minutes.
- Tenant Segregation: Row-level query filtering and cryptographically isolated blob paths guarantee no cross-tenant exposure.
- Password Hashing: Credentials stored using salted bcrypt with high work factors.
12. International Data Transfers
BestShots.AI servers are hosted primarily in the United States. If you access the Service from the European Economic Area, the United Kingdom, or other regions with laws governing data collection that differ from United States law, your data will be transferred to the United States. We ensure appropriate safeguards are in place, including standard contractual clauses (SCCs) approved by the European Commission.
13. Children’s Privacy
The Service is not intended for or directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If you believe a minor has registered an account without parental consent, please contact privacy@bestshots.ai to initiate immediate deletion.
14. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices or applicable legal requirements. We will post the updated policy on this page with a revised "Last Revised" date and notify registered users of material changes via email or dashboard alert.
15. Data Protection Officer & Contact Information
For inquiries regarding this Privacy Policy, your biometric data, or to exercise your statutory privacy rights, contact our Data Protection Officer and Privacy Team:
BestShots.AI Privacy & Security Team
Your photos stay yours. Always.
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