Privacy Policy and Privacy Notice

The Photonza platform is operated by Ali Mert Güleç (sole proprietorship, Türkiye). Address: Halıcıoğlu Mah. Dere Karşısı Yanı Sk. No: 3 İç Kapı No: 5, Beyoğlu / İstanbul. Email: info@alimertgulec.com. Phone: 0531 379 56 85. Website: photonza.com.

Photonza is the data controller for data relating to the operation of the platform: organizer and photographer accounts, guest participation records, the "Find Me" face-matching processing (including the face signature generated from a guest's selfie and the detection and comparison of faces in event photos and videos), security and usage logs, and cookies. Photonza determines the purpose and means of face matching.

For the collection and sharing of the photos, videos and notes uploaded to an event, the organizer who created the event (venue, event company, school, institution or photographer) is the data controller; the organizer decides who is invited, the event settings and content removal. Photonza is the processor that stores and displays this content on the organizer's behalf. You may send requests about event content to the organizer or directly to us; we forward them to the organizer where necessary.

As a guest (you join without an account, email or phone number):

• Your display name and participation record (which event you joined and when). The display name is the only mandatory field.
• Photos, videos and notes you upload; your likes.
• Your face signature (biometric data): created only if you use the "Find Me" feature with your explicit consent; in that case the signatures of faces in event photos that resemble you are also stored. Details are in a separate text: the Biometric Data Notice and Explicit Consent.
• Agreement acceptance and consent records: which version of a text you accepted and when.
• Your satisfaction answer (optional): the star rating you give after "Find Me" and, if you write one, your comment. Your comment may be published on the site with your display name only if you allow it with a separate box.

As an organizer or photographer:

• Business name, email address and an irreversible hash of your password.
• The events you create and their settings; credits you buy and payment records. Payments are collected by bank transfer; no card details are ever collected.
• Your IP address at registration (to prevent abuse).

If you contact us to buy a package or a photo (WhatsApp or email):

• Name or company name, phone number, email address and the content of the conversation.
• Invoicing details (Turkish ID or tax number, billing address) and the bank transfer sender details and amount. No card details are collected.
• If you buy as a consumer, the record that you confirmed the pre-contract information form and the contract.

For everyone (technical and security):

• Server and application logs: IP address, browser type, request time and the action performed (sign-in, upload, download, search). Used for rate limiting and attack prevention.
• Usage counts: per-event download, view and match counts, shown to the organizer as aggregate statistics.
• Visit measurement: aggregate page-view statistics via Vercel Web Analytics (page address, referring site, country/city, browser, operating system, device type). No cookies are used and no identifier is written to your device; details in the Cookie Notice.
• If you appear in an event photo or video (even if you do not use Photonza): your image, the position of your face in the photo and a small face crop cut out of the photo; the numeric signature of your face is computed only for a momentary comparison and is not stored unless it resembles a consenting guest. Details in Section 4.

"Find Me" is optional; without it you can still join the event, view the feed, and upload and download photos. The feature works with a selfie. Your selfie never leaves your device; a model running in your browser turns your face into a numeric signature (vector) and only those numbers are sent to the server. The signature is not a photo; a face image cannot be directly reconstructed from it. Matching happens only within the photos of the event you joined.

So that matching is possible, signatures of the same kind are also computed momentarily from the faces in photos and videos uploaded to the event; only the signatures of faces that resemble a consenting guest are stored. This processing and the rights of people who appear in photos are explained separately in Section 4.

Your own face signature is created only with explicit consent given via a separate checkbox and your declaration that you are at least 18; no signature is generated from your selfie unless you use the feature. Consent can be given with the optional box when entering the event or before the selfie. You can withdraw consent at any time with "Delete my face data" on the Profile page; this deletes your selfie signature and the signatures stored because they resemble you. Full details are in the Biometric Data Notice and Explicit Consent.

What is processed: 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. For each face the following is stored: 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). The crop is part of the event photo and on its own is not a face signature (biometric template); it is kept in our database, is not available at any public address and only our server-side service can access it. In addition, the numeric signature (vector) of each face is computed only in memory, momentarily, and compared with the selfie signatures of the guests who have given explicit consent for "Find Me" in that event. The signature is stored, linked to that guest, only if it resembles a consenting guest's selfie signature above a set similarity threshold; the signatures of all other faces are not stored and are discarded immediately after the comparison. This includes the faces of people who appear in a photo but have never used Photonza. Photos are not sent to any other face recognition service for this purpose.

Purpose and limits:

• The sole purpose is to find the photos in which a guest who has separately given explicit consent for "Find Me" appears, by comparing them with that guest's face signature. If a guest gives consent and a selfie after photos have been uploaded, signatures are recomputed momentarily from the stored face crops and compared only with that guest's selfie signature (this usually takes a few minutes); those that do not resemble the guest are again not stored. To complete the results, the face signatures stored in the event may also be compared with each other; this comparison, too, is carried out only for the results of the consenting guest.
• Face signatures are not linked to any name or identity information. No processing is carried out to determine to whom a face belongs if it does not match a consenting guest.
• Signatures are not compared across events and are not used for profiling, identity verification, advertising, model training or any other purpose.
• Signatures are not shared with or sold to third parties; the organizer, photographer and other guests have no access to them. They are stored only with the infrastructure providers listed in Section 6, on our behalf.
• The organizer can turn face recognition off for the whole event; in events where it is off, no face detection takes place and no face signatures are generated.

Retention: Face positions and crops are deleted automatically with the photo and at the latest together with all event content 30 days after the event ends. Face signatures stored because they resemble a consenting guest are deleted when that guest withdraws consent ("Delete my face data") or leaves the event (unless they are also linked to another consenting guest), when the photo or video is deleted, or at the latest 30 days after the event ends.

Legal basis: Matching and storing the matching signatures rely, for the guest who wants to find their photos, on that guest's explicit consent under Article 6/2 of KVKK. The face signatures of people who do not use "Find Me" are not stored and are not used for identification; they are computed momentarily only to establish whether they match a consenting guest, and within the limits above. Storing face positions and crops is a technical operation tied to, and lasting as long as, the storage of the event photos.

Objection and deletion: If you know you appear in an event photo, you may request deletion of the records relating to your face (position, crop and any stored signature) and object to this processing even if you are not a Photonza user. Simply write to info@alimertgulec.com stating the event and, if possible, the photos you appear in. We delete the position and crop of your face in the photos you identify and any face signatures stored because it resembled a consenting guest; if you also want the photo itself removed, we resolve the request together with the event organizer. Requests are free of charge and answered within 30 days at the latest. We do not run biometric comparisons to find your face without your consent.

Informing attendees: Under the Terms of Service, the organizer must display, where attendees can see it, the information notice prepared by Photonza (photonza.com/organizer-notice) or an equivalent notice containing the same information at the event entrance.

Data is collected and processed electronically (web application, server logs) by automated means on the following legal bases listed in Articles 5 and 6 of KVKK (Articles 6 and 9 of the GDPR):

• Performance of a contract (Art. 5/2(c)): joining an event, collecting and displaying photos, downloads; managing organizer and photographer accounts; selling packages, credits and photos, payments and sales correspondence.
• Legal obligation (Art. 5/2(ç)): issuing invoices and keeping payment records under tax and commercial law; keeping pre-contract information and contract records for consumer sales under the Distance Contracts Regulation; keeping traffic logs under Law No. 5651; answering requests from competent authorities.
• Legitimate interest (Art. 5/2(f)): reviewing infringement notices and removing content, preventing abuse and attacks, rate limiting, debugging, aggregate statistics for the organizer, cookieless aggregate visit measurement (Vercel Web Analytics).
• Explicit consent (Art. 5/1 and Art. 6/2): creating your face signature for "Find Me", matching it against event photos and storing the signatures of faces in photos that resemble you (for faces in event photos see Section 4).

Photos you upload can be seen by the other guests of the event, the photographer and the organizer. If the event is in "private" mode, guests see only their own photos. The organizer sees guests' display names and event statistics, never face signatures.

We do not sell your data or share it for advertising. The following infrastructure providers process data on our behalf, on our instructions and only to provide the service:

• Supabase (US company; database servers in the European Union, Ireland): database, authentication, face signatures, face positions and crops.
• Cloudflare (US company; global infrastructure): photo and video storage (R2), content delivery, and face detection, face-signature computation and comparison for event photos.
• Vercel (US company; server-side processing in the European Union, Ireland): hosting of the web application, server-side processing and cookieless visit measurement (Vercel Web Analytics: page view counts; sets no cookies, no cross-site tracking).
• GoDaddy (US company): hosting of our info@alimertgulec.com mailbox; emails you send us (requests, purchase correspondence) are kept there.
• WhatsApp (Meta; USA/Ireland): only if you choose to message us on WhatsApp, to deliver the conversation. WhatsApp is subject to its own privacy terms for that conversation; you can do everything by email instead.

Within Türkiye: our accountant and e-invoice service provider for invoicing and bookkeeping; banks to receive payments; competent public authorities where legally required. If you buy a photographer's photo, the information needed to fulfil the order (your name and the photo ordered) may be shared with that photographer.

Uploaded photos are not sent to any other AI service for content moderation or face recognition. The providers above are established abroad or provide their services on infrastructure abroad; your data is therefore transferred outside Türkiye. For these transfers 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. Where legally required, data may be shared with competent public authorities.

Data is deleted or anonymised automatically when the following periods end:

• Event content (photos, videos, notes, likes), face positions and crops, all face signatures (guests' selfie signatures and signatures stored because faces in event photos resemble consenting guests) and match results: 30 days after the event ends. This period lets guests download their photos; deletion is irreversible.
• The face signature generated from your selfie and the signatures stored because faces in event photos resemble you additionally: the moment you press "Delete my face data" or leave the event.
• Face positions, crops and stored signatures from event photos additionally: the moment the photo or video is deleted, or upon your objection and deletion request. The signatures of faces that do not resemble a consenting guest are never stored.
• Guest participation record and display name: together with the event. A guest account with no remaining events is deleted after 90 days.
• Satisfaction answer: if you allowed publication, your comment and display name until you withdraw that permission (info@alimertgulec.com); otherwise the comment and name are deleted with your account and only an anonymous star rating remains.
• Organizer and photographer accounts: until the account is deleted. On a deletion request the account and its events are removed; payment records are anonymised and kept for the statutory period.
• Payment and invoice records: 10 years under tax and commercial law.
• Sales correspondence and, for consumer sales, pre-contract information/contract confirmation records: 3 years (10 years where they support an invoice).
• Request and content-removal correspondence: 3 years from our answer.
• Application activity logs and IP addresses: 12 months (the minimum under Law No. 5651).
• Rate-limiting records (IP): 24 hours.
• Administrator action logs: 24 months.
• Agreement acceptance and consent records: 3 years for evidentiary purposes; anonymised when the user is deleted.
• Records kept in your browser (language preference, event session, upload drafts, etc.): the periods in the Cookie Notice.

The grounds for these periods, destruction methods and periodic destruction are described in the Personal Data Retention and Destruction Policy (photonza.com/data-retention).

Data is protected with TLS in transit and with the providers' disk encryption at rest. Database access is limited by row-level security rules: a guest reaches only the data of the event they joined; only the server-side service can access face signatures, face positions and crops. Photo URLs contain unguessable random keys. Passwords are stored as irreversible hashes. Administrator actions are logged.

If we detect a data breach, we notify the Personal Data Protection Board within 72 hours as required by KVKK and inform the affected people within the shortest reasonable time.

Under Article 11 of KVKK you have the right to:

• Learn whether your personal data is processed and, if so, request information.
• Learn the purpose of processing and whether the data is used in line with it.
• Know the third parties to whom it is transferred, in Türkiye or abroad.
• Request correction if it is incomplete or inaccurate.
• Request deletion or destruction under the conditions of Article 7 of KVKK.
• Request that corrections and deletions be notified to third parties the data was transferred to.
• Object to a result against you produced by analysis exclusively through automated systems.
• Claim compensation if you suffer damage due to unlawful processing.
• Withdraw explicit consent you have given, at any time (withdrawal does not affect the lawfulness of earlier processing).

If the GDPR applies to you, you also have the rights to data portability, restriction of processing and to object to processing, and you may lodge a complaint with the supervisory authority of your country.

What you can do from within the app: delete a photo you uploaded, delete your face signature, leave the event.

Under Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller, you may send your request in writing to the address above, signed with a secure electronic or mobile signature, or from an email address registered in our system to info@alimertgulec.com. Because guests and people appearing in photos are not in our system with a registered email address, we also process emails they send to info@alimertgulec.com; in that case we may ask for additional information to verify your identity. Your request must include:

• Full name; a signature for written requests.
• Turkish ID number for Turkish citizens; nationality and passport number (or ID number, if any) for foreign nationals.
• Residential or business address for notification; email address, phone and fax number for notification, if any.
• The subject of the request. If you are a guest, stating which event you joined and under which display name, or, if you are writing because you appear in a photo, the event and if possible the photos, helps us match your request quickly.

We conclude requests free of charge as soon as possible according to their nature and within 30 days at the latest. If the process incurs an additional cost, the fee set by the Board's tariff may be charged. If your request is refused, you find our answer insufficient or we do not answer in time, you may complain to the Personal Data Protection Board within 30 days of learning our answer and in any case within 60 days of your request.

The platform is not intended for people under 18; the "Find Me" feature is available only to people who declare that they are 18 or over (no identity check is made; the age declaration is a separate checkbox). The organizer must turn face recognition off at events where most participants are children. Children may appear in event photos; the organizer running the event is responsible for sharing that content and obtaining parental consent. The face signatures described in Section 4 may also be extracted from the faces of children appearing in event photos; they, too, are used only for matching with consenting adult guests and are deleted within the same period. If, as a parent or guardian, you want content or face signatures relating to your child deleted, just write to us; we handle such requests with priority.

Photonza only uses cookies and browser storage entries that are strictly necessary for the service to work; it uses no advertising, marketing or analytics cookies and therefore does not ask for cookie consent. The entries used and their durations are explained separately in the Cookie Notice.

When we update this notice we change the date on this page. We inform account holders of important changes separately.

To have a photo or video removed, see the Content Removal and Infringement Notice (photonza.com/content-removal); business details are on the Business Information page (photonza.com/legal-notice).

Questions: info@alimertgulec.com