Biometric Data Notice and Explicit Consent

This notice is prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. It also serves as the transparency information required by the GDPR where applicable.

The data controller for your face signature is Ali Mert Güleç, who operates the Photonza platform. Address: Halıcıoğlu Mah. Dere Karşısı Yanı Sk. No: 3 İç Kapı No: 5, Beyoğlu / İstanbul. Email: info@alimertgulec.com.

Your selfie face signature: A numeric vector (face template) generated from your selfie by a model running in your browser. This vector is special-category personal data (biometric data) under Article 6 of KVKK and Article 9 of the GDPR.

The selfie image itself never leaves your device; it is not uploaded to or stored on the server. Only the numeric signature is sent. The signature is not a photo and a face image cannot be directly reconstructed from it (see A.8 for the limits).

Signatures of faces in event photos that resemble you: If you have consented and taken a selfie, the numeric signature (biometric data) of each face in the event photos that resembles your selfie signature above a set similarity threshold is stored, together with a record of which consenting guest it resembles. Because matching is not perfect, these faces may occasionally include someone who looks very much like you; such a signature, too, is used only for your results and is deleted according to your consent (A.6).

Match results: Similarity scores indicating which photos may show you. These are deleted together with your face signature.

Other faces in event photos: In events where the organizer keeps face recognition on, the faces in every photo uploaded to the event and in frames sampled from videos are detected on our servers. The numeric signature of each face is computed only in memory, momentarily, and compared with the selfie signatures of the guests who have consented in that event; the signature of a face that resembles none of them is not stored and is discarded immediately after the comparison. This momentary processing also covers the faces of people who appear in photos and have never used "Find Me". These faces are not linked to any name and no attempt is made to determine who they are.

Face position and face crop: For each detected face, the face's position in the photo (its box and 5 points marking the eyes, nose and mouth corners), the detection confidence score and a small aligned face crop cut out of the photo (112×112 pixels, lossless WebP) are stored in our database. The crop is part of the event photo; on its own it is not a face signature (biometric template). It is not available at any public address and cannot be accessed by the organizer, photographers or guests; only our server-side service can access it. Its sole purpose is to allow the photos to be scanned again for a guest who consents after the photos were uploaded (A.3). Positions and crops are deleted when the photo is deleted or, together with all event content, 30 days after the event ends. The objection and deletion rights of people appearing in photos are described in Section 4 of the Privacy Policy.

The sole purpose is to compare your face signature with the faces in the photos uploaded to the event you joined, in order to find the photos you appear in. Photos uploaded after your selfie are compared with your signature when they are scanned. If you give your consent and selfie after photos have been uploaded, signatures are recomputed momentarily from the stored face crops of the event photos and compared only with your selfie signature (this rescan usually takes a few minutes); signatures already stored in the event for another consenting guest are also compared with yours. The signatures of faces that resemble you are stored; the others are again discarded without being stored. To complete the results, the faces that confidently match you may also be compared with other face signatures stored in the same event (only those stored because they resemble a consenting guest). Your face signature is not matched across events and is not used for profiling, identity verification, advertising or any other purpose. In "Find Me" you may use only a selfie of your own face; searching with another person's photo, a screenshot or a printed image is prohibited, and in that case the face signature and results concerned are deleted immediately (Guest Participation Agreement, Section 6).

The legal basis is your explicit consent under Article 6/2 of KVKK (and Article 9/2(a) of the GDPR). "Find Me" is optional and consent is not mandatory: if you do not consent, you continue to access the event gallery, view the feed and upload and download photos; you only cannot use "Find Me". Browsing the photographer's photos is on by default; if the photographer has turned it off, you can ask the organizer or the photographer for your photos. The feature is available only to people aged 18 or over. Consent can be given with the optional box when entering the event or before the selfie in "Find Me"; both create the same consent record (Section B). Your selfie face signature is generated electronically on your device while you take a selfie in the "Find Me" flow and is transmitted to the server; the signatures of faces in event photos that resemble you are generated automatically on our servers from the photos uploaded to the event (or from the stored face crops).

Your face signature is not shared with or sold to any third party and is not shown to the organizer. The organizer only sees how many guests used the feature.

Face signatures and face positions and crops are stored in the database of Supabase (US company; database servers in the European Union, Ireland), the infrastructure provider of the service, accessible only to our server-side service; face detection, crop extraction, signature computation and comparison for event photos are carried out by Photonza's own software running on Cloudflare (US company) infrastructure, and photos are not sent to any other face recognition service; your selfie signature passes through Vercel's (US company; server functions in the European Union, Ireland) server functions on its way to the database. This is a transfer abroad from Türkiye. For this transfer Photonza relies on the standard contract announced by the Personal Data Protection Board as the appropriate safeguard provided for in Article 9 of KVKK; completing the standard contracts with the providers and notifying them to the Board is in progress.

Your selfie face signature and the signatures stored because faces in event photos resemble you are deleted at the first of the following:

• When you press "Delete my face data" on the Profile page, i.e. when you withdraw your consent (immediately).
• When you leave the event (immediately).
• 30 days after the event ends, together with all event content (automatically).
• When you write to us at info@alimertgulec.com (within 30 days at the latest).

A signature stored from a photo is also deleted when the photo is deleted. If a signature was stored because it resembles more than one consenting guest, withdrawing your consent deletes its link to you; the signature remains only for the other guest whose consent continues, and depends on that guest's consent. Face positions and crops (A.2) stay with the photo as part of the event photo; they are not rescanned for you unless you consent again.

Under Article 11 of KVKK you have the right to learn whether your data is processed, to request information if it is, to learn whether it is used for its purpose, to know the parties it is transferred to, to request correction and deletion, to object to a result against you produced by automated analysis, and to claim compensation if you suffer damage. You may withdraw your explicit consent at any time; withdrawal does not affect the lawfulness of processing carried out before it.

The application procedure is described in the "Requests" section of the Privacy Policy. Even if you have not used "Find Me", if you appear in an event photo you may request deletion of the position and crop of your face and of any signatures stored because it resembled a consenting guest, and object to this processing by writing to info@alimertgulec.com; requests are free of charge and answered within 30 days at the latest.

In line with the Turkish Data Protection Authority's Guideline on the processing of biometric data, you should know why this data matters and what could happen in a breach:

• Unlike a password, your face cannot be changed. If your face signature fell into the wrong hands it could be used to try to recognise you in other photos; deleting the signature does not remove that risk for those who already hold it.
• The signature is not a photo; however, research has shown methods for producing a rough likeness of a face from face signatures, so we cannot give an absolute guarantee that a face can never be derived from it.
• Face matching is not perfect: a photo of someone who looks like you may be shown as "possible", or one of your photos may be missed. Results are shown only to you; the same photos are already visible to participants in the event feed.
• To reduce these risks your selfie never leaves your device, the face signatures of people who have not consented are not stored (they are only used for a momentary comparison and then discarded), your signature is not linked to your name, is used only in this event, can only be accessed by our server-side service, is encrypted in transit and at rest, and is deleted no later than 30 days after the event ends. In the event of a breach we notify the Board within 72 hours as required by KVKK and inform you.
• If you do not want to accept these risks, do not consent: you can use the event gallery without "Find Me" exactly as before.

Explicit consent can be given with a separate checkbox, unticked by default, in one of two places: (1) when entering the event, with the optional box below the Guest Participation Agreement box; (2) before the selfie, when you first use "Find Me". If you do not tick the entry box you still join the event; if you later want to use "Find Me", consent is asked separately before the selfie and you cannot continue there without ticking the box. When you tick either box, your user ID, the event, the date, the language and the version of this text are recorded; if you already have a valid consent for this event, "Find Me" does not ask again.

Statement before the selfie: "Having read the Biometric Data Notice, I give my explicit consent for Photonza, for the "Find Me" feature, to store (1) the face signature generated on my device from my selfie and (2) the signatures of faces in this event's photos that are found to resemble my selfie signature (my biometric data), for the duration of this event and 30 days after it ends, and to process them solely to find the photos of this event in which I appear. I declare that the selfie is of me." An age declaration is also required on that screen: "I confirm that I am at least 18 years old."

Optional statement at event entry (includes the age declaration): "Optional: So that I can find my photos with "Find Me", having read the Biometric Data Notice, I give my explicit consent for Photonza to store (1) the face signature that will be generated on my device from my selfie and (2) the signatures of faces in this event's photos that are found to resemble my selfie signature (my biometric data), for the duration of this event and 30 days after it ends, and to process them solely to find the photos of this event in which I appear. I declare that the selfie will be of me. I confirm that I am at least 18 years old."

To withdraw your consent, simply use "Delete my face data" on the Profile page; consent given at entry is withdrawn with the same button, even if you have not taken a selfie yet. When you withdraw, your selfie face signature, the signatures stored because faces in event photos resemble you and your match results are deleted immediately. Withdrawing is as easy as giving consent and no reason is asked.