Privacy Policy

This policy is also available in Hindi: हिन्दी में पढ़ें. If you would like it in another Indian language, ask us and we will provide it. Earlier versions of this policy are available on request.

Who is responsible

FotoLama is operated by Swaggers Club LLP, a firm registered in Bengaluru, India. Two different roles apply, depending on the data:

• Your account, billing and support data. We decide why and how it is used, and we are answerable for it. The Digital Personal Data Protection Act 2023 calls that being the Data Fiduciary.
• The photographs in an event. The photographer or host who uploaded them decides why and how they are shared. We store and process them on that person's behalf, as a Data Processor. We still act on a request to remove a photograph when it comes to us directly.

What you agree to when you sign up

• Signing up asks you to accept our Terms of Use and this policy, and to confirm that you are 18 or over.
• We record that acceptance: which version you accepted, and when.
• If this policy changes in a way that matters, we ask you to accept the new version the next time you open the app.
• Once a year we email every account holder a reminder of the terms and of this policy.

What we collect, and why

• Your account. Your email address, your name, and a phone number if you choose to add one. We use them to sign you in and to email you about your account and the events you are part of. If you set a password we store only a salted hash of it, never the password itself.
• Sign-in with Google. If you use it, Google gives us your name, email address and profile picture. We use the email address to identify your account. We do not receive your Google password and we cannot see anything else in your Google account.
• Studio details, if you use FotoLama as a photographer: business name, logo, contact details and social links. These are shown publicly on the galleries you brand.
• Photographs you upload, and the information the camera wrote into each file: the filename, the date, the camera settings and, where the camera recorded it, the GPS location the photograph was taken at. We store the photographs to show them to the people the event's owner has given access to. The camera information is shown only to the event's owner and hosts.
• A selfie and face data — only if you enrol. The selfie you take, and a numeric signature of your face computed from it, used to find you in the photographs of events you belong to. The next section covers this in full.
• What you do in events. Which events you are a member of, the photographs you mark as favourites, and any photograph you report. We use these to show you your events and to act on reports.
• Payment and billing records. The plan you bought, the amounts, the invoices and the reference numbers Razorpay gives us. We use them to give you the plan you paid for and to keep the accounts the law requires. We never receive or store your card number.
• Messages you send support, so that we can answer you and see the history if you write again.
• A push token for your phone, if you install the mobile app, so that notifications reach that device.
• Technical logs. The IP address, the time, the page or request, and the device and browser type. We use these to keep the service secure and to investigate misuse.
• Google Drive and Google Photos imports. If you choose to import photographs, we keep the link you gave us so that we can copy those photographs into your event. For Drive you are asked for read-only access, which we use for one thing: to read the files you picked. We do not browse the rest of your Drive, we do not keep the access longer than the import needs it, and you can revoke it at any time from your Google account.
• Your settings, such as whether face matching is on and your preferred download quality.

Your selfie and face data

• Enrolling is optional. Before you enrol, the app shows what will happen and asks you to agree. We record that consent. Nothing is computed from your selfie until then.
• What happens to the selfie. It is sent to Modal, a computing service in the United States, which turns it into a numeric signature of your face. We store that signature with your account. The selfie itself is also your profile picture.
• One per account, not one per event. The same enrolment is what finds you in every event you join or host, which is why you are never asked for a second selfie.
• Other events — only if you turn it on. “Find me at other events” is off until you switch it on and agree. While it is on, your face signature is also compared with photographs at other FotoLama events you are not part of. If you appear in at least two, we tell you the event’s name, and nothing else: you see no photograph until the host approves your request to join. A host can stop their event being searched this way. Turning the setting off stops it immediately and forgets what was found.
• It is matched only against photographs in events you are actually a member of.
• Who sees the result. In an event you have joined, other members of that event may see you listed among the people in its photographs, together with the photographs you appear in.
• Removing it. “Remove selfie” in Profile deletes the selfie and the face data immediately. Turning off “Find me” stops the matching without deleting the selfie or the face data. Either one is a single tap, as easy as enrolling was.
• What changes if you do. The lists of “your photos” stop being built for you.
• We do not sell face data, and we do not use it for advertising.
• The law calls this biometric information and treats it as sensitive personal data. So do we: it is collected only because you chose to enrol, it is used only to find you in events you belong to (and, if you turn on “Find me at other events”, to tell you about events you appear in), and withdrawing your consent stops it the moment you ask.

Faces in the photographs of an event

• Matching needs both sides. To find anyone in an event, the faces in the photographs uploaded to that event are analysed and stored as numeric signatures tied to each photograph. That includes the faces of people who have no FotoLama account.
• Who decides. The photographer or host who uploads the photographs chooses to switch matching on for their event, and is responsible for having the right to share those photographs.
• When it is deleted. The face data of a photograph is deleted when the photograph is: permanently, 30 days after it goes to Trash, or when the event itself is removed.
• If you are in a photograph. Whether or not you have an account, you can ask us to remove the photograph, or to stop your face being matched. A parent or guardian can ask for a child. The contact page says how.

Who else handles it

We use a small number of services to run FotoLama. Each is given only what it needs to do its job, and may use it only to do that job for us:

• Cloudflare (a United States company) — stores the photographs and delivers them over its global network.
• Modal (United States) — computes the numeric face signatures described above. It receives the image and returns the numbers; it is not used for anything else.
• Zoho ZeptoMail (United States) — sends your sign-in code and account emails.
• Razorpay (India) — takes payment for plans. They receive your name, email address and the payment details you enter. We never see or store your card number.
• Google (United States) — sign-in with Google, the Drive and Photos import when you ask for one, push notifications to Android phones, and the typeface these pages are set in.
• Apple (United States) — push notifications to iPhones.
• WhatsApp (United States) — only if you choose to message us there.

We do not sell personal data. We do not share it for advertising. We do not use your photographs or your face data to train anyone's models.

FotoLama'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.

Where it is kept

FotoLama is run from India, and that is where the database and the application servers are. The services above that are based in the United States process data outside India — Cloudflare stores photographs on its global network, Modal and Zoho operate from outside the country, and a push notification goes through Google or Apple. Where data leaves India it is under a contract that holds the service to the same handling described here.

How long we keep it

• Your account and profile — until you delete the account.
• Your selfie and face data — until you remove the selfie or delete the account, whichever comes first.
• Photographs — until the person who uploaded them deletes them, or the event is deleted. A photograph moved to Trash is removed for good after 30 days.
• Photographs over a plan's storage limit — if an account ends up holding more than its plan allows, after a downgrade or a plan that lapsed, everything stays fully available for 30 days. After that the excess is deleted, whole galleries at a time. This is set out in our Terms of Use.
• Sign-in code records — 7 days.
• Data-export files and album ZIP files — 7 days after they are made.
• Support and grievance messages — 3 years.
• Payment and invoice records — 8 years, as tax and company law require.
• Security and access logs — 1 year.
• Backups — a rolling 14 days. Something you delete can remain in a backup until that backup is 14 days old.

The owner of an event is emailed before its photographs are removed, whether that is because the event has reached the end of its time or because the account is over its storage.

We do not erase an account because it has been inactive. If that ever changes, we will email you at least 48 hours before anything is erased.

How we keep it safe

• Everything between your device and FotoLama travels encrypted (TLS).
• Passwords and sign-in codes are stored only as salted or keyed hashes, never as the original.
• The link to a photograph is short-lived and is issued only to someone with access to that event.
• Card details go straight to Razorpay and never reach us.
• Staff access is limited to named operators, and every operator action on a customer's account is recorded in an audit log.
• Backups are taken daily and are encrypted in transit.
• You can sign out of every session at once from Account Settings.

Cookies and tracking

We set no advertising cookies and use no third-party analytics on this site or in the app. When you sign in, your browser stores a session token so that you stay signed in. The full list is on our Cookie Policy page.

Deleting your account

Delete your account at any time with “Delete account” in Account Settings, or write to hello@fotolama.com.

• What goes. Your account and profile, your selfie and your face data, your notifications, your device tokens and your sign-in code records. Your name and contact details are stripped from past support messages. An active subscription is cancelled, every session is signed out, and we email you a confirmation.
• Events you own go with it. Deleting your account also deletes the events you own and the photographs in them, for everyone who had access. If an event should outlive your account, transfer it to someone else first.
• Photographs in other people's events stay with the event. They belong to the photographer or host who runs it, so deleting your own account does not remove them from that event's album.
• What we keep. Payment and invoice records, for the period stated above.

Having a photograph of you removed

There are two routes, and you may use either. Ask the photographer or host who runs the event — they can remove any photograph from it, and that is often the quickest way. Or ask us directly, through the contact page. You do not need an account to do so.

Your rights

The Digital Personal Data Protection Act 2023 gives you these rights over your data, and this is how to use each one:

• See it — Account › Privacy & Security › “Download my data” gives you a file with everything held on your account. This page lists who else handles it.
• Correct, complete or update it — in Profile and Account Settings, or write to us for anything you cannot reach there.
• Erase it — “Delete account”, as described above. You can also ask us to erase specific data without closing the account.
• Withdraw consent — “Remove selfie” or “Find me”, as described under face data. Neither requires deleting your account.
• Nominate someone — Account › Privacy & Security › “Nominee” lets you nominate a person who can exercise these rights for you if you die or become incapacitated.
• Raise a grievance — with our Grievance Officer, whose details are on the contact page.

We answer a request about your data within 30 days. A grievance is acknowledged within 24 hours and resolved within 15 days. Both are shorter than the outer limit in the Digital Personal Data Protection Rules, which is that a request is dealt with within 90 days.

If you have used our grievance route and are not satisfied with the outcome, you may complain to the Data Protection Board of India.

We ask you to write from the email address on the account, because that is how we know the request is yours.

If something goes wrong

If personal data on FotoLama is breached, we tell the people affected and the Data Protection Board of India without delay — what happened, what was affected, and what we are doing about it — and send the Board a full report within 72 hours. We also report the incident to CERT-In within 6 hours of noticing it.

Children

• Accounts are for people aged 18 or over, and we ask you to confirm that when you sign up. We do not knowingly hold an account for a child, and we delete one if we learn of it.
• No tracking of anyone. FotoLama carries no advertising, no tracking and no behavioural monitoring, of children or of anybody else.
• Children in event photographs. Photographs taken at an event can include children. The host is responsible for sharing them. A parent or guardian can ask us to remove a photograph of their child, and we treat that request with the same 24-hour urgency as a complaint about intimate imagery.

Changes

If this policy changes, the updated version appears on this page with a new date and version at the top. If the change is a material one, we email you and ask you to accept the new version in the app. Earlier versions are available on request.

How to reach us

Swaggers Club LLP (LLPIN ACC-7320, GSTIN 29AFCFS1172E1Z3), E1602, Sattva East Crest, #41 Old Madras Road, Bandapura, Bengaluru, Karnataka 560049, India.

Questions about this policy, or about the data on your account: hello@fotolama.com. To escalate a complaint, our Grievance Officer and Data Protection contact is on the contact page.

See also our Terms of Use, Cookie Policy and contact details.