Privacy Policy

Privacy at a glance

• Photos stay on your phone or tablet unless you choose to upload them. Our Mobile Apps use PrivateContext™ Technology to create Memories.

• You choose when to upload Photos. We only upload them when you create a design or add them to a design, order Products, share a design or upload Photos into our Web App.

• You own your Photos. We do not sell them, claim their copyright or share them to train third-party models. We may use Photos you upload to improve our own models and Services; you can object to this at any time, as Section 4 explains.

• You control optional processing. You can switch off Face Recognition and object to other optional uses, and keep using design tools and ordering Products.

• Face Recognition needs separate explicit consent. It is off by default. You can withdraw consent and delete its data without losing other curation features or design tools.

• Research and editorial statistics. We may use aggregated and anonymised photo library metrics and photo Metadata to produce statistics for research and editorial publication.

• You can delete your account at any time. We delete account data within 72 hours, except limited records we must keep by law. Section 8 explains.

Our Terms of Service cover your use of Popsa and purchases. Reading or accepting this Policy does not itself give consent to optional processing.

Definitions

1) Who is responsible for your information

Popsa companies

Your contracting company for both digital Services and Products depends on your Home Country. Customers whose Home Country is the United States, Canada or Mexico contract with Popsa Inc. Customers elsewhere, including Europe, contract with Popsa International Limited. Popsa International Limited delivers the Services for Popsa Inc under an intercompany agreement.

Popsa Europe Limited collects payments for Popsa International Limited from customers whose Home Country is a European country that uses the euro, and manages those funds. It is not the customer supplier. The Terms explain the contracting and payment arrangements.

2) Information we collect and where processing happens

Information you provide or generate

3) Why we use information

The table explains our purposes and the lawful bases used under UK and EU data protection law. Contract means processing necessary to provide Services you request. Legitimate interests means a necessary, proportionate business or user interest that is not outweighed by your rights. Consent means a freely given, specific choice you can withdraw. Legal obligation means processing required by law. Sections 11 and 12 explain additional regional rights.

4) Face Recognition and your choices

Separate permission for Face Recognition

Face Recognition is off by default. Before it starts, we explain the Biometric Data involved, why it is used and how long it is kept. We ask you to take a separate affirmative action giving explicit consent. Accepting the Terms or granting general photo-library access does not enable it.

Face Recognition supports People Albums and people-based Memories, and helps you find photos of the same person. Face Embeddings are sent to Popsa's servers, which group similar faces; the groups appear in our Apps. We do not maintain a database matching faces across accounts, use it for surveillance, or sell, license or disclose its Biometric Data to anyone, other than the providers that host our Services under our instructions, or where the law requires. It is not used to identify people in unrelated contexts.

We assess its privacy risks and apply additional safeguards for Biometric Data. Under UK and EU law, using Biometric Data in Face Recognition to identify a person involves Special Category Data. The two consent requirements are set out in Section 3.

Face Recognition groups faces only within your own account, to help you find your own photos. You are responsible for using it in a way the people in your Photos would expect, and for any permission the law requires you to hold. We do not offer Face Recognition in Illinois or Texas.

Controls and withdrawal

5) Who receives information

We share only the information needed for the purposes described in this Policy. Providers acting for us must follow our instructions, keep information secure and use it only for the agreed work. Some recipients, including certain payment providers and public authorities, act as controllers under their own legal duties and privacy notices.

6) International transfers

Our group, hosting providers and Fulfilment Partners may process information outside your country. This includes Popsa Inc in the USA and Popsa International Limited's delivery of Services from the UK. Data sent abroad remains subject to appropriate protection.

For transfers covered by UK or EU data protection law, we rely on UK adequacy regulations or an EU adequacy decision where one applies, including the EU–US Data Privacy Framework and UK Extension for certified US recipients. Otherwise, including for Popsa Inc and Fulfilment Partners outside adequate countries, we use the EU Standard Contractual Clauses or the UK International Data Transfer Agreement or Addendum, with a transfer risk assessment and added safeguards where needed. These arrangements require recipients to protect information and give you enforceable rights. We do not rely on your consent for these transfers; the safeguards above apply instead.

You can ask the Data Protection Officer for a copy of the relevant safeguards, with commercial details removed.

7) Marketing, Cookies and advertising choices

Messages from Popsa

We use your preferences and relevant purchase or usage information to make permitted marketing useful to you. You can stop email marketing through the unsubscribe link, reply STOP to marketing texts, change push-notification settings, or contact us about any channel. Telephone and postal marketing also respect objections and applicable preference registers.

SMS enrolment covers recurring messages, with frequency varying by programme; message and data rates may apply. Consent is not a condition of purchase. The Terms of Service, Section 16 contain the programme terms and cancellation details.

For existing-customer emails about our own similar Products, we may use the permission allowed by law where we collected your details during a sale or sale negotiation. We give an opt-out when collecting the details and in every message. Otherwise we obtain the consent required for the channel. We may also ask for service feedback by email, telephone or post, respecting your choices.

Order updates, receipts, security alerts and other necessary service messages continue when you unsubscribe from marketing.

Website Cookies

Necessary Cookies support functions such as sign-in, security, checkout and remembering your choices. Non-essential analytics and advertising Cookies require your prior consent. Our consent tool lets you accept, reject or choose categories.

Use the website's cookie preferences control to change or withdraw consent at any time. Rejection leaves necessary functions available. Browser settings can also remove Cookies, but do not replace the consent choices for future tracking.

Our Cookie Policy explains the Cookies and similar technologies used. Google also explains its use of information on sites using its services in Google's privacy information.

Mobile App tracking and diagnostics

SDKs support fault diagnosis, analytics and advertising measurement. Necessary diagnostics help keep the Apps secure and working. Optional analytics and advertising tracking follow your choices; declining them does not disable essential diagnostics.

On iOS, we request Apple's App Tracking Transparency permission before tracking you across other companies' apps or websites. You can change it in device settings. Android privacy settings let you control or delete the advertising identifier where supported. Device permission does not replace a separate consent required by data protection law.

We stop optional advertising tracking when you withdraw permission. This does not stop necessary security or error reporting that does not depend on that permission.

Sale, sharing and browser signals

We do not sell Personal Data for money or other valuable consideration. If you opt into advertising tracking, certain identifiers and interactions can be shared for advertising across different services. California law calls this cross-context behavioural advertising “sharing”, even where no money changes hands.

Use the website's Do Not Sell or Share My Personal Information or cookie preferences control to opt out. We honour GPC signals for the browser or device sending them and apply the choice to your account where we can associate it. We do not require an account or identity verification to process this opt-out. Other browser “Do Not Track” signals do not currently have a standard meaning we act on; the controls above remain available.

8) How long we keep information

We keep information for its stated purpose and delete it when it is no longer needed. The following periods apply to our copies unless a specific legal obligation requires limited retention.

9) Security and data breaches

Payment card details go directly to our payment partners. We do not store full card details; we receive the limited transaction information described in Section 2.

We use technical and organisational measures suited to the information involved. Biometric Data is subject to additional restrictions.

No internet transmission or storage system can be guaranteed completely secure. Protect your account credentials and tell support@popsa.com promptly if you suspect unauthorised access.

If a Personal Data breach occurs, we contain it, investigate, keep a record and take steps to reduce harm. Where UK or EU law requires notification, we notify the relevant authority within 72 hours of becoming aware of the breach, or explain any delay. We notify affected people without undue delay where the breach is likely to create a high risk to them. Other applicable local breach-notification duties also apply.

10) Your rights, requests and complaints

Your choices and legal rights

Section 4 explains your choices, and closing your account deletes your data as Section 8 describes. Under applicable data protection law you may also have rights to access, correct or delete your Personal Data, to receive the data you gave us in a portable format, to restrict or object to some of our processing, to withdraw consent, and to complain to a privacy authority. Direct marketing stops when you object.

To exercise these rights, email dpo@popsa.com. You do not need a Popsa account to contact us about your information, for example if you appear in someone else's Photos. We protect other people's information when responding, and if we cannot grant a request in full we explain the legal reason and how to challenge it.

Handling requests

We try to handle requests free of charge, and charge a fee or refuse only where the law permits, explaining the decision. We may ask for proportionate information to confirm identity, used only for that purpose; advertising opt-outs do not need it. You may use an authorised representative, subject to permitted checks. For UK/EU requests we respond without undue delay and normally within one month; where the law permits an extension, we explain it within the first month. Sections 11 and 12 give regional timing. These periods do not replace our shorter account-deletion commitment.

Automated suggestions

Memories, captions and design suggestions come from automated analysis of your Photos and Metadata. You can review, edit or reject the results, and you can object under this Section. We do not make solely automated decisions with legal or similarly significant effects on you. Automated payment and fraud checks can affect whether we accept an order. If such a check declines your order, you can ask us to review it. Suggestions do not place an order without your confirmation.

Privacy complaints

Email the Data Protection Officer or write to our UK office. We acknowledge privacy complaints promptly, investigate, keep you informed and explain the outcome. This complaints process is separate from the response period for an access or other rights request.

You can complain to the UK's Information Commissioner's Office. EU/EEA residents can contact the supervisory authority where they live or work, or where an alleged infringement occurred. Regional contacts and rights are described below.

11) United States privacy rights

This section supplements the rest of the Policy for residents covered by US state privacy laws, including the California Consumer Privacy Act as amended. The rights available depend on your state and the law's application to the processing.

Categories and disclosures

The following categories correspond to the information and sources in Section 2. Section 3 gives the purposes; Sections 5 and 8 give recipients and retention criteria. The same categories describe our relevant collection and disclosure during the preceding 12 months, where the feature was offered and you used it.

12) Canada and Mexico

Canada

Popsa Inc is your service counterparty. Canadian privacy rights apply alongside the choices in this Policy, including applicable federal and provincial protections. We explain the information, purposes, recipients and meaningful consequences when requesting consent. You can withdraw consent, subject to legal or contractual restrictions that we explain; optional choices remain optional.

You can request access, correction and information about our practices through the Data Protection Officer. Under the federal Personal Information Protection and Electronic Documents Act, we normally respond to access requests within 30 days. We notify you within that period of any lawful extension and the reason. You can complain to the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

Québec

If you live in Québec, the person in charge of the protection of personal information is our Data Protection Officer, at dpo@popsa.com. Your information may be communicated outside Québec, as Section 6 explains. You can complain to the Commission d'accès à l'information du Québec.

Mexico

Popsa Inc's details are in Section 1. Account, order, delivery, security and legal-compliance purposes are necessary to provide the Services. Marketing and other optional uses are separate choices; refusing them does not prevent a purchase. Sensitive information requires the applicable express consent.

You can exercise access, rectification, cancellation and opposition (ARCO) rights, or withdraw consent and limit use or disclosure, through the Data Protection Officer. Include your name, contact details, request and information needed to establish identity or representation. We communicate an ARCO decision within 20 working days and implement an accepted request within the following 15 working days. A justified extension can be made once for the same period, with notice.

Section 5 identifies recipients and Section 6 describes transfers. We obtain separate consent where a transfer requires it. You can seek protection from the Secretaría Anticorrupción y Buen Gobierno under Mexico's private-sector data protection law. Section 13 explains how notice changes are communicated.

13) Changes and contact

We update this Policy when our practices or legal obligations change. We publish the revised text and date on our website and make it available in our Apps. For material changes, including new purposes, we also notify you through the Apps or another suitable direct channel before the change takes effect where required.

Existing consents and objections keep their scope. A policy update does not silently expand a permission or cancel an opt-out.

• Privacy questions, rights and complaints: dpo@popsa.com.

• Account and order support: support@popsa.com.

• Legal questions: legal@popsa.com.

• Post: Data Protection Officer, Popsa International Limited, Nightingale House, 46–48 East Street, Epsom, Surrey KT17 1HQ, United Kingdom.

Google Workspace APIs

We affirm that Google Workspace APIs are not used to train generalised AI and/or ML models.