Biometric data policy

This policy covers “biometric identifiers”, “biometric information” and “biometric data” as defined by applicable law, including the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code §503.001), the Colorado Privacy Act (C.R.S. §6-1-1314) and the Washington My Health My Data Act (RCW 19.373), that AboutUsAgency Inc. or its service providers may collect when you use automatic cropping, AI headshots or Studioless Restore (photo restoration, memorial and pet portraits) (“Biometric Data”), such as facial-landmark geometry or face embeddings. Photographs themselves are covered by our privacy policy and follow the same deletion schedule.

We use Biometric Data only to:

• crop, center and size your photo to the published rules for your document;
• check photo quality (for example head size, tilt, eyes, lighting and background);
• generate the AI headshots you order;
• for Studioless Restore: find the faces in the photo you send, restore them, and compare each restored face with the same face in the original to check that it still looks like the same person (a quality check of our own output, never identification of who the person is).

We never use it to identify, track or profile anyone, or to verify anyone’s identity, for advertising, or to train AI models, and we don’t compare faces between people or between orders.

We collect Biometric Data only after you, or your parent or legal guardian, have read a written notice and given written consent by electronic signature (a checkbox), separately for passport photos and for AI headshots. Face detection does not load until you agree. You can decline and crop your photo by hand instead. We record which notice version you accepted (currently 2026-09-29.3) and when.

Studioless Restore has its own written notice and consent on the restore start page (currently version 2026-10-09.5), given by the adult who sends the photo. They confirm that each living person shown is them or gave permission (for a child, a parent or guardian), and that for someone shown who has died they are family or have the family’s agreement. A Restore order can’t be sent without it, and we record the version and the time.

We permanently destroy Biometric Data at the earliest of: when the purpose for collecting it has been met; the schedule above; 45 days after we determine it is no longer needed; or your verified request or withdrawal of consent. In no case do we keep it longer than one year after the purpose ends, 24 months after your last interaction with us, or three years after your last interaction with us, whichever comes first.

Destruction means deletion from our storage by an automated job that runs every hour, and instructing our service providers to delete. We review what we store at least once a year to confirm that deletion works.

We disclose Biometric Data only to the service providers listed on our subprocessors page, under written terms that limit use to our instructions and forbid sale and model training; or when the law, a warrant or a subpoena requires it. We never sell, lease, trade or otherwise profit from Biometric Data.

We protect Biometric Data with at least the care we use for our other confidential information and the reasonable standard of care in our industry: encryption in transit and at rest, private storage, least-privilege access, and keeping camera and image data out of analytics, logs and error reports.

If a security incident may affect Biometric Data, we contain it, investigate, notify affected people and regulators as the law requires, instruct our service providers to take corrective action, and document what we fixed.

You can ask what Biometric Data we hold, ask us to delete it, or withdraw your consent at any time: email support@getstudioless.com or use the support form. We complete deletion within 15 days. A copy OpenAI keeps of a Studioless Restore photo for abuse monitoring is deleted on OpenAI’s own schedule (up to 30 days, longer where the law requires it or an image is flagged); we can’t delete it sooner.

AboutUsAgency Inc., support@getstudioless.com. When this policy changes we post the new version here with a new date.