Biometric Information & Facial Recognition Privacy Notice
Wil the Photographer, LLC
Effective Date: September 5, 2026
Last Updated: September 5, 2026
PURPOSE AND SCOPE OF THIS NOTICE
This Biometric Information & Facial Recognition Privacy Notice (“Biometric Notice”) explains how Wil the Photographer, LLC (“Wil the Photographer,” “we,” “our,” or “us”) may collect, create, process, use, retain, protect, disclose, and delete facial feature information in connection with optional photo-search features available through https://wilthephotographer.com (the “Site”).
This Biometric Notice supplements our Privacy Policy and Terms and Conditions. If this Biometric Notice provides greater protection for facial or biometric information than a more general provision in another policy, we intend to follow this more specific Biometric Notice to the extent required by applicable law.
Depending on applicable law, some of the facial feature information described in this notice may be considered “biometric information,” a “biometric identifier,” “biometric data,” or “sensitive personal information.”
FACIAL PHOTO SEARCH IS OPTIONAL
You are not required to use facial photo search. You may browse available Photo Store albums, search albums by other available methods, purchase photographs, create an account, purchase event tickets, attend events, and use transportation services without submitting a selfie for facial photo search.
Where the Site presents a facial-search consent control, the consent must be affirmatively selected before a selfie is submitted. Acceptance of our general Terms and Conditions, purchase of a ticket, creation of an account, or attendance at an event does not by itself constitute consent to submit a selfie for facial photo search.
WHAT FACIAL INFORMATION MAY BE PROCESSED
Depending on the feature being used, we may process or maintain:
- A selfie or other image that you voluntarily submit for facial photo search.
- A temporary normalized copy of a submitted image created solely to perform the requested search.
- Mathematical facial feature information, face vectors, face identifiers, and related matching metadata generated by Amazon Rekognition.
- Anonymous identifiers linking indexed faces from eligible event photographs to the applicable Photo Store photo record.
- For an optional saved “Photos of Me” or new-photo-alert profile, a face identifier linked to your Site account together with the date and version of the applicable consent record.
- For a temporary live-event search, a temporary face identifier and session information necessary to continue checking for newly uploaded matching photographs during the stated session period.
- Similarity scores and possible-match results produced when a search is performed.
HOW EVENT PHOTOGRAPHS MAY BE INDEXED
When facial photo search is enabled, eligible photographs in published, publicly searchable Photo Store albums may be analyzed to detect faces and create mathematical facial feature information associated with the applicable photo. A single photograph may contain multiple people and therefore may produce multiple face identifiers.
The face index is designed to use Photo Store photo identifiers rather than customer names for ordinary event-photo indexing. The indexed facial feature information is used to make possible photo matches available when a person later performs an authorized facial photo search.
Because biometric laws differ by jurisdiction, we may limit, delay, exclude, or disable facial indexing or facial-search functionality for particular photographs, events, individuals, users, or jurisdictions when additional notice, authorization, consent, or other legal requirements apply.
HOW A ONE-TIME SELFIE SEARCH WORKS
When you voluntarily submit a selfie for a one-time facial search, the Site prepares the image for processing and sends the necessary image data to Amazon Web Services (“AWS”), including Amazon Rekognition, to compare the submitted face against facial feature information associated with eligible searchable photographs.
The search may return photographs that the system determines are possible matches. Facial matching is probabilistic. A result may incorrectly identify a photograph as a match, and the system may fail to find a photograph that actually contains you.
A facial-search result is not identity verification. We do not use this feature as a government identification system, security credential, background check, credit decision, employment decision, insurance decision, or other eligibility determination.
SELFIE RETENTION
For a normal one-time facial photo search, Wil Photo Store is designed to delete the uploaded selfie file and any temporary normalized copy after the search request has been processed.
We do not use a selfie submitted only for facial photo search as a public photograph, advertisement, promotional image, or product merely because the selfie was submitted to the search feature.
OPTIONAL SAVED FACE PROFILE / “PHOTOS OF ME”
If you are signed in and separately choose to save a face profile for an optional feature such as “Photos of Me” or new-photo alerts, the Site may create a persistent Amazon Rekognition face identifier or face vector linked to your account.
The selfie image itself is designed to be deleted after processing. The saved face identifier may then be used to compare your profile against newly indexed photographs and to provide possible-match results or alerts that you requested.
You may pause new-photo alerts without necessarily deleting the saved face profile. If you choose the available “Delete Face Profile” control, Wil Photo Store is designed to request deletion of the corresponding stored face vector from the Rekognition collection and remove the associated saved-profile record and related photo-alert records from the Site.
TEMPORARY LIVE-EVENT PHOTO SEARCH
If a live-event facial search is offered, you may be given the option to keep a temporary face vector active for a limited period so that the page can periodically check newly uploaded photographs for possible matches.
The Site displays the applicable live-search duration when the feature is used. The current system is designed to allow a live-search period of no more than 24 hours and to delete expired temporary live-search face vectors through an automated cleanup process.
PURPOSES FOR WHICH FACIAL INFORMATION IS USED
We use facial information described in this Biometric Notice only as reasonably necessary to:
- Operate an optional facial photo-search service.
- Locate possible photographs of the person who authorized the search.
- Provide an optional saved “Photos of Me” profile or new-photo alerts requested by the account holder.
- Provide temporary live-event photo matching when requested.
- Maintain, troubleshoot, secure, and improve the reliability of the facial-search feature.
- Delete or de-index face information when a photo, profile, or temporary session is removed or expires.
- Prevent fraud, abuse, unauthorized access, or misuse of the facial-search system.
- Comply with applicable law, legal process, or valid governmental requirements.
AMAZON WEB SERVICES / AMAZON REKOGNITION
We use Amazon Web Services, including Amazon Rekognition, as a service provider for facial analysis and matching. Amazon Rekognition may create and store mathematical representations of faces, commonly referred to as face vectors, in a Rekognition face collection.
Amazon Rekognition assigns technical identifiers to indexed faces and uses the stored mathematical feature information to perform face-search and matching operations. Wil Photo Store also maintains limited records necessary to connect an indexed face identifier to the corresponding Photo Store photo or, when you affirmatively save a personal profile, to your account.
AWS processes information according to its applicable service terms, privacy and security practices, and the configuration of our AWS account.
NO SALE, LEASE, OR THIRD-PARTY ADVERTISING USE
We do not sell, lease, trade, or provide facial feature information or stored face vectors to advertisers, data brokers, or unrelated third parties for their own advertising or marketing purposes.
We do not separately offer face vectors or biometric information for sale as a data product. Photo Store may, however, sell photographs or other products that a customer chooses to purchase after using an optional search feature.
DISCLOSURE OF FACIAL INFORMATION
Facial information may be disclosed or made available only as reasonably necessary:
- To AWS or another authorized service provider operating the facial-search service on our behalf.
- At your direction or with your authorization.
- To complete or provide a service you expressly requested.
- To investigate or prevent fraud, abuse, security incidents, or unlawful activity where permitted by law.
- When required or expressly permitted by applicable law, court order, warrant, subpoena, or other valid legal process.
- To protect the rights, safety, property, or legal interests of Wil the Photographer, LLC, our customers, or others where permitted by law.
SECURITY OF FACIAL INFORMATION
We use reasonable administrative, technical, and organizational measures designed to protect facial information from unauthorized access, acquisition, use, alteration, or disclosure.
These measures may include encrypted website connections, restricted administrative access, account authentication controls, AWS access controls, security monitoring, rate limiting, temporary-file cleanup, and the use of service-provider security controls.
No electronic system can be guaranteed to be completely secure.
RETENTION AND DESTRUCTION SCHEDULE
Wil the Photographer, LLC maintains the following intended retention and destruction schedule for facial information. We may delete information sooner when the purpose for which it was collected has been satisfied, when a valid deletion request applies, when an associated photograph or account is deleted, or when required by law.
- One-time selfie-search files: The uploaded selfie and temporary normalized copies are designed to be deleted after the applicable search request is processed.
- Temporary live-search face vectors: Retained only for the live-search period shown to the user, which is configured for no more than 24 hours, and then scheduled for deletion.
- Saved account face profiles: Retained while the user keeps the optional saved face-profile feature, subject to earlier deletion upon the user’s request, account deletion, satisfaction of the original purpose, or a shorter period required by applicable law. We intend to review saved biometric profiles so that they are not retained longer than reasonably necessary for the requested service.
- Face vectors associated with event photographs: Retained only while reasonably necessary to provide facial photo search for the associated searchable photograph. A face vector is designed to be deleted when the associated photograph is removed from the facial-search index. We intend to apply a maximum facial-index retention period of three years from the applicable event date or indexing date, unless a shorter period is required by law or a legal exception permits or requires longer retention.
- Consent and compliance records: Records documenting consent, withdrawal, deletion requests, and compliance actions may be retained for a reasonable period necessary to demonstrate compliance, resolve disputes, protect legal rights, or satisfy legal obligations. These records do not require retention of the underlying selfie image.
For persons and processing subject to the Illinois Biometric Information Privacy Act or another law imposing a shorter destruction requirement, we intend to permanently destroy covered biometric identifiers and biometric information when the initial purpose for collecting or obtaining the information has been satisfied or within the maximum period required by the applicable law, whichever occurs first, absent a lawful exception.
CONSENT AND WRITTEN RELEASE
Where applicable law requires consent, written authorization, or a written release before facial or biometric information is collected, captured, enrolled, stored, or used, we will seek the applicable authorization through an affirmative electronic or written process.
A facial-search checkbox, electronic acknowledgment, event-specific release, or other consent mechanism may provide additional disclosures concerning the specific purpose and retention period applicable to that feature.
This public Biometric Notice itself is a disclosure and retention policy. It does not replace a separate written or electronic release where applicable law requires one.
WITHDRAWAL OF CONSENT AND DELETION REQUESTS
Where processing is based on your consent, you may withdraw that consent for future processing as permitted by applicable law.
If you have a saved face profile, use the available account deletion control when possible. You may also contact us to request deletion of facial information associated with you.
To submit a biometric-information request, email wilthephotographer@gmail.com and include sufficient information for us to understand and verify the request. We may request additional information reasonably necessary to verify that the request concerns you or that you are legally authorized to act for another person.
A deletion request may be subject to legal exceptions. Deleting a face vector does not necessarily require deletion of the underlying event photograph when we have a separate lawful basis to retain the photograph. Where appropriate, we may remove the photograph from facial search while retaining the photograph for other lawful photography, archival, licensing, transaction, or legal purposes.
ILLINOIS NOTICE
Where the Illinois Biometric Information Privacy Act (“BIPA”) applies, our policy is to provide the notices and obtain the written release required by applicable law before collecting or obtaining covered biometric identifiers or biometric information; not sell, lease, trade, or otherwise profit from covered biometric identifiers or biometric information as prohibited by law; protect such information using the required standard of care; and follow a publicly available retention and destruction schedule.
Where we cannot satisfy an applicable prerequisite for facial indexing or search, we may exclude or disable the applicable biometric processing.
TEXAS NOTICE
Where Texas biometric law applies, our policy is to provide required notice and obtain consent before capturing a biometric identifier for a commercial purpose, protect the identifier using reasonable care, limit disclosure as required by law, and destroy the identifier within the period required by applicable Texas law after the purpose for collecting it expires.
WASHINGTON NOTICE
Where Washington biometric law applies, our policy is to provide the notice, consent, or other mechanism required before enrolling a covered biometric identifier for a commercial purpose, protect enrolled identifiers using reasonable care, limit disclosure and use to permitted purposes, and retain covered identifiers no longer than reasonably necessary for the purpose for which they were enrolled or another legally permitted reason.
CALIFORNIA AND OTHER STATE PRIVACY RIGHTS
Depending on applicable law, biometric information used to identify or match a person may be treated as sensitive personal information. Residents of certain states may have rights to access, correct, delete, obtain information about, limit certain uses of, or withdraw consent for personal or sensitive information.
For more information regarding general privacy rights, please review our Privacy Policy.
MINORS
Facial photo search is not intended for use by a child under 13. Do not submit a child’s selfie or create a saved face profile for a child unless you are the child’s parent or legally authorized guardian and have provided any consent or authorization required by applicable law.
Additional age-related restrictions may apply in certain jurisdictions. We may disable or restrict biometric features when we cannot reasonably establish the authorization required to process a minor’s facial information.
AUTHORIZED USE ONLY
You may use facial photo search only for a lawful and authorized purpose. You may not use the feature to stalk, harass, track, impersonate, discriminate against, or invade the privacy of another person.
If you submit an image containing another person, you represent that you have the authority required by applicable law to submit that image and request the applicable search.
CHANGES TO THIS BIOMETRIC NOTICE
We may update this Biometric Notice to reflect changes in our facial-search features, service providers, retention practices, security practices, or legal requirements.
When this Biometric Notice is materially updated, we will revise the “Last Updated” date above and may provide additional notice or obtain new consent where required by applicable law.
CONTACT INFORMATION
If you have questions about facial recognition, biometric information, this Biometric Notice, or a request concerning facial information, contact:
Wil the Photographer, LLC
10050 Palma Linda Way #319
Orlando, FL 32836
Email:
wilthephotographer@gmail.com
Phone:
(407) 569-7788
