Privacy Policy

1. Introduction

LegacyLens (“we,” “our,” or “us”) is committed to protecting the privacy of our users (“you” or “your”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and web service (collectively, the “Service”).

By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

2. Information We Collect

2.1 Account Information

When you create an account, we collect your email address, display name, and password (stored as a bcrypt hash — we never store your plain-text password).

2.2 Photos and Media

When you upload photos, we store the image files along with associated metadata including EXIF data (date taken, GPS coordinates, camera information). Photos are stored in encrypted cloud storage and are only accessible to you and the family members you explicitly share them with.

2.3 Face Data and Biometric Identifiers

Our face recognition feature detects faces in your photos and generates mathematical representations (512-dimensional embedding vectors) to identify family members across your photo collection. LegacyLens processes biometric identifiers solely for face recognition within a user's own account and for no other commercial purpose. This face data is:

• Generated on your device (iOS) using Apple's Vision framework and sent to our servers for matching
• Supplemented by AWS Rekognition for server-side face detection and age-range estimation when processing uploaded photos
• Isolated to your account — your face data is never shared with, compared against, or accessible to other users' data
• Used solely for the purpose of identifying family members within your own photo collection
• Never sold, leased, or disclosed to third parties for advertising, profiling, or any purpose unrelated to providing the Service
• Deletable at any time by removing the associated face profile from your account

Biometric data retention and deletion: Biometric data — including face embedding vectors and bounding box coordinates — is deleted when you remove a face profile or delete your account. Upon account deletion, all biometric identifiers associated with your account are permanently purged from our systems after the 30-day recovery period described in Section 8. We do not retain biometric data after its purpose has been fulfilled or after you withdraw consent by deleting the relevant profile or account.

2.4 Usage and Device Data

We collect the following data to protect your account, improve the Service, and diagnose technical issues:

• Security audit logs: Login events, account creation, access patterns, IP address, and browser user agent
• Login location: Country of origin derived from your IP address at login time
• Client error reports: App version, OS version, device model, and error details (automatically submitted when the app encounters issues)
• Push notification tokens: Device-specific tokens used to deliver notifications, deleted when you log out

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process and store your photos securely
• Enable face recognition and automatic tagging within your collection
• Facilitate sharing albums with family members you designate
• Execute legacy planning transfers according to your instructions
• Send you service-related communications (account verification, security alerts)
• Detect, prevent, and address technical issues and security threats

4. Data Storage and Security

Your photos are stored in Amazon Web Services (AWS) S3 with server-side encryption. Our database uses PostgreSQL with the pgcrypto extension for additional encryption capabilities. All data is transmitted over HTTPS/TLS.

Authentication tokens are short-lived (15-minute access tokens) with longer-lived refresh tokens. Passwords are hashed using bcrypt before storage.

5. Data Sharing

We do not sell, trade, or rent your personal information to third parties. Your photos and face data are never used for advertising or shared with external services. We may share information only in the following circumstances:

• With your consent: When you share albums with family members or designate legacy contacts
• Service providers: We use the following third-party services to operate the Service:
  • Amazon Web Services (AWS): Cloud infrastructure including S3 (photo storage), Rekognition (server-side face detection and age-range estimation), and general computing
  • Mailgun: Transactional email delivery (account verification, password reset, album invitations, legacy plan notifications)
  • Apple: App Store subscription management, Sign in with Apple authentication, and Apple Push Notification service (APNs)
  These providers process data solely on our behalf and are contractually bound to protect your information.
• Legal requirements: When required by law or to protect our rights, safety, or property

6. Legacy Planning

The Legacy Planning feature allows you to designate trusted contacts who may receive access to your photo collection in the event of extended account inactivity. You control who is designated as a legacy contact and can modify or remove these designations at any time. Legacy transfers are initiated only after a configurable period of inactivity and include notification attempts before any transfer occurs.

7. Your Rights

You have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and all associated data, including photos, face profiles, and embedding vectors
• Export: Download your photos and associated metadata
• Restrict processing: Request that we limit how we use your data

To exercise any of these rights, please contact us at [email protected].

8. Data Retention

We retain your data for as long as your account is active. When you delete your account, we perform a soft delete initially (allowing for a 30-day recovery period), after which all data — including photos, face embeddings, album data, and personal information — is permanently removed from our systems and cloud storage.

9. Children's Privacy

Account eligibility: The Service is not directed to children under the age of 13. Only individuals aged 13 or older may create a LegacyLens account. We do not knowingly collect personal information directly from children under 13 as account holders. If you believe a child under 13 has created an account, please contact us immediately and we will take steps to delete it.

Photos of children: LegacyLens is a family photo preservation app, and we recognize that users routinely upload photos that depict minors — including their own children, grandchildren, and other family members. All photos, including those depicting minors, are uploaded and managed exclusively by the adult account holder. Children do not interact with the Service directly. The account holder acts as the authorized adult responsible for any photos of minors within their collection.

Face recognition for minors: When the account holder uploads photos containing faces of minors, those faces may be detected and processed through our face recognition feature. This processing occurs solely under the authority and direction of the adult account holder. Face profiles for minors are created only when the account holder explicitly tags or confirms an identification. The account holder may delete any face profile — including those of minors — at any time, which permanently removes the associated biometric data.

COPPA compliance: Because LegacyLens does not permit children under 13 to create accounts or interact with the Service, and because all data concerning minors is provided and controlled by an adult account holder acting in a parental or guardian capacity, the Service operates in compliance with the Children's Online Privacy Protection Act (COPPA). We do not collect personal information from children — we process photos provided to us by adults who have authority over the depicted content. Parents and guardians who wish to have their child's face data removed may do so at any time by deleting the relevant face profile or by contacting us at [email protected].

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date. You are advised to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Email: [email protected]