Face Data Notice
Effective 26 September 2026, version 2026-09-26
SpotMe is operated by HPK AI Labs, Ahmedabad, India.
This notice explains, in plain language, how SpotMe (operated by HPK AI Labs) uses face recognition, what face data we create, how long we keep it and how you can delete it. It forms part of our Privacy Policy, which has the full details.
1. What is face data?
When SpotMe finds a face in a photo, it computes a face template: a list of 512 numbers that describes the features of that face. A face template cannot be viewed as a picture. Two templates that are close to each other probably belong to the same person, and that is how SpotMe groups and matches faces.
Face templates are biometric data. Under Indian law (the SPDI Rules) they are sensitive personal data, and under the GDPR they are a special category of personal data when used to identify a person. We treat them with extra care.
2. What face data SpotMe creates
From event photos, after the photographer runs face detection:
- one or more face templates for each usable face;
- people groups: faces that look like the same person, grouped together; and
- a small cropped face image for each people group, shown as that group's thumbnail to the photographer and the couple.
To avoid matching very young children, SpotMe automatically estimates whether a face appears to belong to a child under about 5 years old. If so, that face is excluded from matching. This estimate is not stored.
From a guest's selfie:
- basic automated checks that the selfie contains a clear, real face (for example, face size, detection confidence and sharpness);
- one face template, which is compared with the event's people groups to find your photos; and
- the list of people groups your template matched.
Your selfie image is never stored. It is processed in memory to create the face template and is then discarded.
3. Why we use it
Face data is used only to:
- group the faces in an event's photos, so the photographer and the couple can browse photos by person; and
- match a guest's selfie with the faces in that same event, so the guest sees the photos they appear in.
4. What we never do
- We never use face data, photos or selfies to train, test or improve any AI or machine-learning model.
- We never match faces across different events, or across different photographers' accounts.
- We never use face data to identify strangers, for surveillance or for security or access control.
- We never sell, rent or share face data for advertising or any other purpose.
- We never estimate or record anyone's gender, ethnicity, emotions or other personal characteristics. The only estimate we make is the temporary "very young child" check in Section 2, which is used to exclude faces and is not stored.
5. Who can access it
- Face templates are used only by our automated systems. Nobody views them.
- People group thumbnails are shown to the photographer who created the event and to the couple (Master Link).
- Guests see only the photos matched to their own face and the couple's shared highlights. They cannot see people groups or other guests' matches.
- Face data is stored and processed on Amazon Web Services servers in Mumbai, India.
6. How long we keep it
| Face data | When it is deleted |
|---|---|
| Selfie image | Never stored: discarded immediately after processing. |
| Face templates, people groups and face thumbnails from event photos | When the event is archived, or when the photos or the event are deleted. If the photographer restores an archived event, this face data is generated again. |
| Guest selfie face template and matches | When the photographer permanently deletes the event or their account, or earlier if the photographer deletes it at your request. It is kept when an event is archived, so that your gallery works again if the photographer restores the event. |
| Backups | Deleted data is removed from our rolling backups within 7 days. |
7. Your choices
- Consent: guests agree to face matching by continuing past the notice on the login screen and then taking a selfie. If you do not want face matching, do not take a selfie. Ask the couple or the photographer for your photos instead.
- Retake: you can retake your selfie at any time. Your new face template replaces the old one.
- Delete: guests cannot delete their face data themselves. The photographer who created the event owns its photos and data, so ask the photographer to delete your face template, name, mobile number and matches, or the photos of you. If you cannot reach them, or they do not act within 15 days, email spotme@hpklabs.ai.
- Not a SpotMe user? If you appear in an event's photos and want your face data or photos removed, contact the photographer who took them. If you cannot reach them, email spotme@hpklabs.ai with the event link or the photographer's name, and we will follow it up with the photographer. See our Data Deletion Instructions.
8. Children
SpotMe is not for anyone under 18. A parent or lawful guardian may take a selfie of their child to find that child's photos, and by doing so gives consent on the child's behalf. See Section 14 of our Privacy Policy.
9. Accuracy
Face matching is statistical and can make mistakes: it may miss some photos of you, or occasionally show you a photo of someone who looks similar. If that happens, retake your selfie or contact the photographer or us.
10. Contact
Questions about face data: Umang Gajjar, Grievance Officer, HPK AI Labs, spotme@hpklabs.ai.