Privacy Policy

Effective date: [DATE] · Last updated: [DATE]

1. The short version

• Pholo is for sharing photo albums with people you choose. We collect what we need to run it: your account details, the photos and words you add, and the technical information needed to keep it working and secure.
• If a photo has location data, we keep it. The album Owner and the person who added the photo see the exact spot. Other signed-in members of the album see only an area about 1 km (0.6 mi) across.
• We do not sell your personal information, share it for targeted advertising, use advertising or analytics trackers, or use facial recognition.
• You can delete photos, albums and comments, and ask us to delete your account.

2. Who we are

[COMPANY LEGAL NAME] ("Pholo," "we," "us") runs pholo.com, the Pholo apps and the album links we create (the "Service"). We are responsible for the personal information described here. Contact us at [PRIVACY EMAIL] or [ADDRESS].

This policy covers account holders and Guests (people who use an album link without an account). It does not cover other companies' services, even when they load inside Pholo (see Section 6).

3. What we collect

You give us:

• Account details: your name, email address and password. Your password passes through our servers to our authentication provider, which stores it only in protected (hashed) form. We do not store or log it.
• Profile: the name you choose and, if you add one, a profile photo. People who share an album with you see your name, its initials and your photo on album cards: the owners of albums you joined, and the people who joined yours. We turn the photo upright, crop it to a 512-pixel square and save a new copy, which removes its camera details and location. You can change or remove it on your Profile at any time; we then delete the old file.
• Phone number: optional. Only you can see it. We do not send messages to it today; if we later use it for something like text invitations, we will tell you first. You can remove it in Settings at any time.
• Email changes: when you change the email you sign in with, our authentication provider sends confirmation links (to the new address, and to your old one), and the change applies only once confirmed.
• Guest details: an optional display name, if you give one.
• Your content: photos you add, and album titles, descriptions, places and map pins, comments, likes, messages you write when asking people for photos, and reports you send.
• Messages to us: what you send when you contact us.

We get from your photos:

• The photo itself. We make resized copies (up to 2560 pixels) and thumbnails, and store those. We delete your original file once processing finishes, normally within minutes.
• Photo metadata: the date and time it was taken, its size and dimensions, and its GPS location if the photo has one. The stored copies we show do not contain embedded metadata.
• A fingerprint (hash) of the original file, so we can spot the same photo being added to an album twice.
• Place tags: the town, county, state, country or park around the photo's approximate location (see Section 5).

Photos you take with the Pholo camera. If you post camera photos without choosing an album, they go to My photos, a private album only you can see. It is never listed or shared. If you add a photo to more than one album, each album gets its own copy: the copies share the stored image, and each has its own likes and comments. Deleting a photo from one album does not remove its other copies. We delete the image file once no album uses it.

We collect automatically:

• Technical information: your IP address, browser or device type, and the pages and features you request. We use IP addresses to limit abuse, such as repeated sign-in attempts, and store them only in scrambled (hashed) form, deleted within 1 day. Our hosting provider also keeps short-term server logs.
• Activity records: a log of key events, such as creating an album, opening a link, starting an upload, downloading or reporting a photo. These records use a scrambled identifier, not your name or email.
• Cookies and similar storage: see Section 9.

Your device location (only if you allow it): if you use "Nearest" to sort albums or center the map, your location is used on your device and is not sent to us or stored. If you take photos with the Pholo camera, we ask once to use your location. When a photo you take has no GPS location of its own, we store your device's location at the time you posted it as the photo's location. It is shown under the same rules as GPS (Section 5).

From other people: people you share with may add photos of you, or mention you in comments.

4. How we use it

We do not use your photos or personal information to train artificial intelligence models, and we do not make automated decisions about you that have legal or similarly significant effects.

5. Photo and album location

5.1 Who sees what:

5.2 How approximate locations work. We divide the map into fixed squares about 1 km across. Other members see the center of the square a photo falls in, not the photo's spot. Place tags come from the center of that square, so they never reveal more than the square does.

5.3 Who we send locations to. To make place tags, we send our map provider (MapTiler) only the center of the square. We never send it the exact photo location.

5.4 How to control it. You can:

• remove location from a photo before adding it. On iPhone, tap "Options" in the photo picker and turn off "Location";
• delete a photo, which removes its location from the Service (see Section 10);
• leave an album's pin empty, or set it to a general place rather than an exact address.

6. Who we share it with

People you share with. Albums are private until you share them. When you share an album link, anyone with the link can see what it allows (Terms Section 4). This includes photos, capture dates, display names, comments, likes, and the album's place and pin, and they can download the photos. Your chosen name, its initials and your profile photo are shown to the people who share an album with you: the owners of albums you joined, and the people who joined your albums. Guests using a link do not see profile photos.

Service providers who process information for us under contract, only to provide their service to us:

Legal and safety reasons. We may disclose information when we believe in good faith it is needed to comply with law or legal process, protect someone's safety, investigate fraud or abuse, or enforce our Terms. We report apparent child sexual abuse material to NCMEC, as federal law requires.

Business changes. If we are involved in a merger, acquisition, financing or sale of assets, information may be transferred as part of it, under this policy or one at least as protective.

With your direction or consent, in any other case.

We do not sell personal information. We do not share it for cross-context behavioral (targeted) advertising, as those terms are defined in California law.

7. How long we keep it

We may keep information longer if the law requires it, to resolve disputes, or to enforce our Terms.

8. Your choices and rights

8.1 Everyone can:

• see, edit or delete albums, photos and comments you control in the Service;
• download photos one at a time;
• ask us for a copy of your personal information, to correct it, or to delete it, by emailing [PRIVACY EMAIL];
• delete your account [in Settings / by emailing PRIVACY EMAIL].

If a photo of you is in someone else's album, ask the album Owner to remove it, or contact us.

8.2 State privacy rights. Depending on where you live, including California, Colorado, Connecticut, Oregon, Texas, Utah, Virginia and other states with privacy laws, you may have the right to:

• know what personal information we have about you and get a copy in a portable format;
• correct inaccurate information;
• delete your information;
• opt out of the sale of personal information, targeted advertising and certain profiling (we do none of these);
• limit the use of sensitive personal information, such as precise location, or, where the law requires, have it used only with your consent;
• not be treated differently for using these rights.

8.3 How to make a request. Email [PRIVACY EMAIL] [or use the form at LINK]. We will verify your identity by confirming control of the email address on the account, and will reply within the time the law requires (usually 45 days). You may use an authorized agent; we may ask for proof of their authority.

8.4 Appeals. If we deny your request, you can appeal by replying to our decision or emailing [PRIVACY EMAIL] with "Appeal" in the subject. We will respond within the time the law requires. If you are not satisfied, you can contact your state attorney general.

8.5 Global Privacy Control. We do not sell or share personal information for targeted advertising. If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of those activities.

8.6 California notice. In the past 12 months we collected these categories of personal information, for the purposes in Section 4, from the sources in Section 3, and disclosed them to the recipients in Section 6:

We use sensitive personal information only to provide the Service you ask for, to keep it secure, and as the law otherwise permits. We do not use it to infer characteristics about you.

9. Cookies and local storage

We use only what the Service needs to work. We use no advertising, analytics or tracking cookies, pixels or session-recording tools.

In the iPhone app, your sign-in is stored in the iOS Keychain, and display preferences on your device.

10. Deleting photos and albums

When you delete a photo or album, it disappears from the Service right away. The image files are removed from storage promptly, and related records, including location, are removed within the periods in Section 7. Copies already downloaded by people you shared with are outside our control.

11. Children

The Service is not directed to children under 13. We do not knowingly collect personal information from children under 13, and accounts require users to be 18 or older. If you believe a child under 13 has given us personal information, contact [PRIVACY EMAIL] and we will delete it.

Adults often share photos of their own children. Album Owners are responsible for who they share those photos with. A parent or guardian can ask us to remove a photo of their child at [PRIVACY EMAIL].

12. Security

We protect information with measures such as encryption in transit (HTTPS), short-lived links for photo files, sharing links stored only in scrambled form, limits on repeated attempts, and access controls. Our providers encrypt stored data. No system is perfectly secure. If a breach affects your information, we will notify you as the law requires.

13. Where information is processed

We are based in the United States, and our providers process information in the United States [and other countries]. The Service is intended for people in the United States.

14. Changes to this policy

We will post any changes here and update the date at the top. If a change is material, we will tell you by email or in the Service before it takes effect. Where the law requires, we will ask for your consent.

15. Contact us

[COMPANY LEGAL NAME] · [ADDRESS] · [PRIVACY EMAIL]