Privacy Policy

1. Who we are and what this covers

fyndme ("fyndme", "we", "us", or "our") is a Philippine-based service, operated by ATA International Resources Inc. (registered address: Unit 3006, One Corporate Centre Bldg., Ortigas Center, Pasig City, Metro Manila, Philippines). fyndme uses facial recognition to match people at an event with photos of themselves.

This Privacy Policy explains what personal data we collect, why we collect it, who can see it, how long we keep it, and the rights you have under the Data Privacy Act of 2012 (Republic Act No. 10173, "RA 10173"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). It reflects our commitment to the DPA's core principles of transparency, legitimate purpose, and proportionality — we collect only what we need, use it only for what we told you, and keep it only as long as necessary.

2. The people this policy covers

fyndme is a two-sided service:

• Organizers — the account holders who create events and upload photos: photographers, event coordinators, and companies.
• Attendees — the people who appear in the photos and use a selfie to find and receive them.

For photos taken at an event, the organizer is the Personal Information Controller (PIC) — they decide to hold the event, take the photos, and publish them. fyndme acts as their Personal Information Processor (PIP) for that event content, and as a PIC in its own right for platform accounts, the facial-matching service, and our own operations. Section 11 sets out organizer responsibilities.

3. What we collect

3.1 From organizers

• Name and email address (from your sign-in), and an optional phone number.
• Company/business name, domain, logo, brand color, website, and role.
• Event details: name, type, date, and settings.
• Event photos you upload (originals, watermarked versions, and thumbnails).
• Billing and transaction records where you sell photos or subscribe to a paid plan (card details are handled by our payment processor, never stored by us).
• Messages and support requests you send us.

3.2 From attendees — including biometric (sensitive) data

• Selfie image — the photo you submit so we can search for you.
• Facial template ("face embedding") — a numerical representation of facial geometry derived from your selfie and from faces detected in the organizer's photos. Under RA 10173 §3(l) this is sensitive personal information because it is biometric data. We process it only with your consent, given when you submit your selfie.
• Optional registration details (name, email, mobile) if an event asks for them, used to deliver your photos.
• Purchase records where you buy or download photos.

3.3 Collected automatically

• Basic log data — IP address, approximate location, browser and device type, referral source, timestamps, and the actions you take — needed to run and secure the service. For each event, this visit data is also shown to that event's organizer as a traffic report, and is automatically deleted after a limited retention period (see Section 10).
• Strictly necessary cookies to keep you signed in (see Section 14).

4. How face matching works — and what happens to your selfie

1. An organizer uploads event photos. We detect faces and generate a facial template for each detected face.
2. When you submit a selfie, we generate a template from it and compare it against the event's photo templates. A match is recorded only when a strict similarity threshold is met, to avoid false matches. We may ask you to retake a low-quality selfie so matching is accurate.
3. We return your matching photos so you can view, download, or buy them.

Your search selfie is never stored. It is used only to generate the template for your search and is discarded immediately afterward. We do not keep it, we do not build a profile from it, and we do not create a permanent facial database.

At a private event, each attendee can access only the photos they were matched to. You cannot see other attendees' photos, names, or selfies.

5. Why we process your data and our legal basis

Purpose	Legal basis under RA 10173
Create and operate your account; provide the service	Contract / your request
Detect faces and match selfies to photos	Consent (sensitive personal information)
Deliver galleries and send transactional email	Contract; legitimate interest
Process payments and downloads	Contract; legal obligation (record-keeping)
Secure the platform and prevent abuse	Legitimate interest; legal obligation
Comply with law and lawful requests	Legal obligation

Where we rely on consent — which includes all facial/biometric processing — you may withdraw it at any time, without affecting the lawfulness of processing done before withdrawal.

6. What we never do

To be unambiguous, fyndme will never:

• Sell or rent your personal data to anyone;
• Use your face, selfie, or photos for advertising, or share them with ad networks or data brokers;
• Use your facial template for surveillance or to identify you anywhere outside matching you to an organizer's event photos;
• Keep your search selfie after the match runs; or
• Use advertising cookies or tracking pixels.

7. Who we share data with

We share personal data only as needed to run the service, with providers bound by confidentiality and acting on our instructions ("sub-processors"):

• Cloud hosting and photo storage;
• Facial-recognition processing (the software that detects faces and creates templates);
• Transactional email delivery;
• Payment processing (for photo sales and subscriptions).

We may also disclose data to professional advisers under confidentiality, to authorities where required by law or lawful NPC/government request, or in a business transfer (merger, acquisition, or sale of assets), subject to this Policy. A current list of sub-processors is available on request from dpo@atsourcepro.com. We do not authorize any provider to use your data for anything other than delivering fyndme to you.

8. Who can see your data

• Attendees at a private event see only the photos in their own results — never another attendee's photos, name, or selfie.
• Organizers can see, for their own events: the event's photos, how many photos each attendee matched, and whether galleries were delivered — plus any registration details an attendee provided to them. They cannot see attendees' facial templates.
• fyndme platform administrators have a dedicated admin console used only to operate the service — verifying accounts, providing support, enforcing these terms, and, where necessary for a data-privacy or legal issue, archiving or removing content. Administrator actions on content are logged in an internal audit trail. Administrators do not use attendee data for any other purpose.

9. Where your data is processed (cross-border)

fyndme uses reputable cloud providers, some of which operate servers outside the Philippines. Where personal data is transferred abroad, we apply the safeguards required by RA 10173 §21, including contractual commitments that our providers keep your data confidential and protected to a comparable standard. By using fyndme you understand your data may be processed outside the Philippines for the purposes described here.

10. How long we keep your data

We keep personal data only as long as necessary, on these concrete schedules:

• Event photos and their facial templates: deleted 90 days after the event date by default. An organizer may delete them sooner, or extend within their account settings where available. When photos are deleted, their templates are destroyed with them — there is no separate, longer-lived copy of a template.
• Search selfies: never stored — discarded immediately after the match (see Section 4).
• Attendee registration details (name, email, mobile): deleted with the event they belong to, on the same 90-day schedule.
• Content archived by an administrator: hidden immediately from organizers, attendees, and public galleries, and permanently deleted within 30 days unless a longer hold is required to resolve a legal or safety matter.
• Event visit logs (IP, device, browser, source shown to the organizer as a traffic report): retained up to 24 months, then automatically purged.
• Organizer account data: kept until you ask us to delete your account.
• Tax and accounting records: kept for the period required by Philippine law.

You can request earlier deletion of an event at any time by emailing dpo@atsourcepro.com, and we will action it within 48 hours. Once deleted, data cannot be recovered.

11. Organizer responsibilities

As a PIC for your event content, you agree that you will:

• Have a lawful basis and the consents required to photograph attendees and to have their images processed by facial recognition on fyndme;
• Display a clear notice at your events that photography and facial-recognition photo-finding are in use, and how attendees can object;
• Handle any registration data you collect in line with RA 10173;
• Promptly honor attendee requests and cooperate with ours; and
• Upload only content you have the right to upload.

fyndme provides tools (archiving, deletion, private/face-gated events, watermarks) to help — but responsibility for lawful collection at your events rests with you.

12. Your rights under RA 10173

Under the Data Privacy Act you have the right to be informed, to access your data, to rectify it, to erase or block it, to object to processing (including withdrawing consent to facial matching), to data portability, to be indemnified in damages, and to file a complaint with the NPC.

To exercise any right, email dpo@atsourcepro.com from the address associated with your account or registration. We aim to respond within 15 calendar days (deletion requests within 48 hours per Section 10). We may need to verify your identity first. Where an organizer uploaded the photos, we may coordinate your request with them as the controller of that content.

13. Security and breach notification

We protect your data with technical and organizational measures — encryption in transit, hashed passwords, scoped credentials, role-based access controls, an administrator audit trail, and the short retention windows above — consistent with RA 10173 §20. No system is perfectly secure. If we learn of a personal data breach likely to create a real risk of serious harm (for example, exposure of selfies or facial templates), we will notify the NPC and the affected data subjects within 72 hours of becoming aware, in line with the DPA IRR.

14. Cookies and local storage

We keep this minimal. We use a session cookie/token to keep you signed in and short-lived local caches (for example, of a gallery you just viewed) to make the app fast. We use no third-party analytics, no advertising cookies, and no tracking pixels. You can control cookies in your browser; disabling strictly necessary ones may break sign-in.

15. Children and minors

fyndme accounts are for adults — organizers must be 18 or older. In the Philippines the age of majority is 18, and the NPC treats a minor's consent as requiring a parent or guardian. Attendees under 18 should not register themselves without a parent's or guardian's permission. Because minors appear in event photos (weddings, birthdays, family events), organizers are responsible for obtaining parental or guardian consent before processing photos in which a minor is identifiable. If you believe we hold a minor's data without proper consent, email dpo@atsourcepro.com and we will act promptly.

16. Marketing use of content

Without asking you again, we may use: anonymized screenshots or recordings of the app with names, emails, and recognizable faces blurred or replaced; and aggregate, non-identifying figures (e.g. "10,000 photos matched").

We will never use, without your specific written consent: your face, name, or any photo in which you are identifiable; the selfie you submitted; or your personal results gallery. If we'd like to feature you, we'll ask in writing first, and you can withdraw consent anytime by emailing dpo@atsourcepro.com.

17. Changes to this Policy

If we make a material change, we will post the updated Policy here with a new "Last updated" date and notify account holders and attendees with active galleries at least 30 days before it takes effect. Continued use after that date means you accept the updated Policy.

18. Contact

• Data Protection Officer: dpo@atsourcepro.com
• General support: support@atsourcepro.com
• Operated by: ATA International Resources Inc., Unit 3006, One Corporate Centre Bldg., Ortigas Center, Pasig City, Metro Manila, Philippines

You may also lodge a complaint with the National Privacy Commission — https://www.privacy.gov.ph — if you believe your data-privacy rights have been violated.