Biometric Information & Facial Recognition Privacy Notice

Wil the Photographer, LLC
Effective Date: September 5, 2026
Last Updated: September 17, 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 or live selfie frames are captured or submitted for facial photo search. 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 use the live-camera facial-search feature.

WHAT FACIAL INFORMATION MAY BE PROCESSED

Depending on the feature being used, we may process or maintain:

A selfie image or multiple live-camera still frames that you voluntarily provide for facial photo search.
Temporary normalized or resized copies of submitted or captured images created solely to perform the requested verification or search.
Temporary live-camera challenge information, which may include randomized head-turn instructions, capture timing, active-light color sequences, and verification results.
Facial detection and pose information, including head-angle measurements and related face attributes used to evaluate the live-camera challenge.
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 use the one-time facial-search feature, the Site may first require a live-camera check and capture several still frames from your device camera. After the live-camera check is completed, the Site prepares the necessary reference image data for processing and sends the necessary image data to Amazon Web Services (“AWS”), including Amazon Rekognition, to compare your face against facial feature information associated with eligible searchable photographs.

The selfie and live-camera frames must depict you. One-time facial search may not be used to search for another person.

LIVE SELFIE / ANTI-SPOOFING CHECK

To reduce misuse of facial photo search through a printed photograph, a photo displayed on another screen, or an ordinary prerecorded video, the Site may require a native live-camera challenge before performing a one-time facial search. The challenge may capture multiple still frames while asking you to follow randomized head-turn instructions and may briefly change the color or brightness displayed on your device screen as an active-light challenge.

The Site may evaluate whether the expected head movement occurred, whether the same face remained present during the challenge, and whether the captured face shows the expected change in reflected screen light. Necessary challenge frames may be processed by our server and by Amazon Rekognition for face detection, facial pose analysis, temporary face indexing or comparison, and facial matching. The Site may also perform server-side image and color measurements for the active-light portion of the challenge.

The current native live-selfie check is operated by the Site and uses Amazon Rekognition for supporting facial analysis and matching. It is not designed to use Amazon Rekognition Face Liveness as the active camera interface. The anti-spoofing check is a security measure intended to reduce misuse; it does not guarantee that every attempted spoof, replay, altered video, or synthetic image will be detected.

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 AND LIVE-CHALLENGE RETENTION

For a normal one-time facial photo search, Wil Photo Store is designed not to retain the submitted selfie, live-camera challenge frames, or temporary normalized copies as permanent customer photo files after the applicable verification and search request has been processed.

Temporary Amazon Rekognition face identifiers created solely to evaluate the live-camera challenge are designed to be deleted after challenge processing. A reference frame or related one-time verification record may be held temporarily only as necessary to complete the current facial-search request and is designed to expire automatically. These temporary challenge records do not by themselves create a saved “Photos of Me” face profile.

We do not use a selfie or live-camera challenge frame submitted only for facial photo search as a public photograph, advertisement, promotional image, or product merely because it was submitted or captured for the search feature.

OPTIONAL SAVED FACE PROFILE / “PHOTOS OF ME”

If you are signed in, are at least 18 years old, and separately affirmatively 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.

Consent to perform a one-time facial photo search does not by itself authorize creation of a saved face profile or enrollment in new-photo alerts. Saving a face profile or enabling a feature that retains a face identifier for future matching requires a separate affirmative choice when that option is presented. The saved-profile option is not intended to be automatically selected merely because you consented to a one-time facial search.

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 user who submitted their own image for 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.
Perform live-camera anti-spoofing checks intended to reduce use of static photographs, screen-displayed images, or ordinary prerecorded video in place of the person using the feature.
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.

For the native live-selfie challenge, Amazon Rekognition may also be used to detect a face, measure facial pose or head angle, temporarily index challenge frames, and compare temporary face identifiers to help confirm that the same face completed the requested movement sequence. Temporary face identifiers created solely for the live-camera challenge are designed to be deleted after that challenge is processed. The Site separately evaluates the active-light color response using server-side image analysis.

The current native live-selfie flow is not designed to invoke Amazon Rekognition Face Liveness as the active camera experience. 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 and live-camera challenge files: Submitted selfie images, captured challenge frames, and temporary normalized copies are designed not to be retained as permanent customer photo files after the applicable verification and search request is processed.
Temporary live-camera verification records and face identifiers: Temporary challenge/session data, active-light verification results, and any Amazon Rekognition face identifiers created solely for the live-camera challenge are retained only as needed to complete the current verification and search flow. Temporary challenge face identifiers are designed to be deleted after challenge processing, and one-time server verification records are designed to expire automatically.
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. Where the one-time search uses the live-camera challenge, the applicable consent may also cover capture and processing of multiple live selfie frames, randomized head-movement prompts, active-light challenge data, and temporary facial analysis necessary to perform the requested search.

Consent to a one-time facial search and consent to create or maintain a saved face profile are separate choices where those features are offered.

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, saved face profiles, and related biometric photo-search features are available only to persons who are at least 18 years old.

Because facial photo search is limited to self-search, a parent, guardian, or other person may not submit a child’s image, create a face-search profile on behalf of a child, or use the feature to search for a person under 18.

We may disable or restrict biometric features when we cannot reasonably establish the age, identity, consent, or authorization required to process facial information.

AUTHORIZED USE ONLY

Facial photo search is a self-search feature only. The selfie or other image you submit must depict you. You may not submit another person’s image or use the feature to identify, track, locate, investigate, impersonate, discriminate against, or search for another person, even if you believe you have that person’s permission.

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