Legal
Biometric & Likeness Rights Policy
Last updated: April 23, 2026 · This policy explains how snapshots.cloud handles facial and biometric data, likeness rights, and your consent rights under applicable law.
1. Why This Policy Exists
snapshots.cloud is an AI-powered media platform that processes photographs — many of which contain human faces. Our restoration, enhancement, and Cinema animation features involve AI analysis of facial geometry and features. This places us squarely within the scope of biometric data laws in several U.S. states and international regulations.
This policy explains exactly what biometric and facial data we process, why, how long we keep it, your rights under applicable law, and how we handle photos containing the faces of people other than yourself.
2. What Is Biometric Data?
For purposes of this policy, "biometric data" means any data derived from facial geometry, facial feature mapping, or other physical characteristics that can be used to identify an individual. This includes, but is not limited to:
- Facial geometry maps or feature embeddings generated during AI photo restoration
- Face position, proportion, and landmark data used during AI video animation
- Any intermediate representation of a face generated during AI processing
We do not collect fingerprints, voiceprints, retina scans, iris scans, or DNA data.
3. What We Collect and Why
When you upload a photo containing a human face and request AI processing, our pipeline (and/or third-party AI providers acting on our behalf) may generate temporary facial data for the following purposes only:
- Photo restoration and enhancement — facial feature analysis to reconstruct detail, reduce noise, and improve image quality.
- AI video animation (Cinema) — facial geometry analysis to generate animated video clips from still photos.
- Color correction and upscaling — face-aware processing to maintain natural skin tones and proportions.
We do not use facial data to identify individuals, build recognition databases, serve advertising, train AI models on your personal photos, or share facial data with any third party except as required to deliver the processing you requested.
4. Retention and Destruction Schedule
We retain biometric and facial data only as long as necessary to deliver your project:
- Temporary processing data — facial embeddings and geometry maps generated during AI pipeline processing are transient. They exist only for the duration of active processing and are not persisted to long-term storage by us.
- Original uploaded photos — retained for 90 days after project completion, then permanently deleted from our storage.
- Processed output (restored/animated) — retained for 180 days and available in your account for download. Deleted thereafter unless you request earlier deletion.
- Third-party AI providers — subject to their own data retention policies. We select providers who commit to not retaining submitted data beyond the scope of the API call. See Section 7 for details.
You may request immediate deletion of your uploaded photos and any associated biometric data at any time by emailing privacy@snapshots.cloud. We will complete deletion within 30 days.
5. Your Consent
By creating an account and submitting photos for AI processing, you provide explicit, informed consent to the facial and biometric data processing described in this policy, for the specific purposes stated herein.
You may withdraw consent at any time by ceasing to use the AI processing features and requesting deletion of your data. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.
6. Photos Containing Other People's Faces
Many users upload historical family photographs that contain the faces of relatives, friends, or other individuals who may not be the account holder. By uploading such photos, you represent and warrant that:
- You have the legal right to submit the photo for AI processing.
- You have obtained any consent required by applicable law from identifiable individuals in the photo, or that such consent is not required (e.g., the individual is deceased, or you have a familial relationship that grants you authority over the photo).
- You will not use the resulting processed media to harass, defame, impersonate, or harm any individual depicted.
- You will not use the resulting processed media for commercial purposes involving another person's likeness without their explicit written consent.
We cannot verify consent on your behalf. You assume full responsibility for ensuring that your use of photos containing third-party faces complies with applicable law.
7. Likeness Rights and AI-Generated Output
When our AI pipeline animates or transforms a photo, it creates a new depiction — a video or enhanced image — that may constitute a use of a person's likeness under applicable right-of-publicity laws.
What we do with output: AI-generated output is delivered solely to you, the account holder. We do not publicly display, share, license, or distribute AI-generated depictions of individuals without your explicit action (e.g., you choosing to share a film via a public share link).
What you may do with output: You may use AI-generated output for personal, non-commercial purposes. Commercial use of output depicting identifiable individuals requires you to independently secure any required likeness rights or consents. snapshots.cloud makes no representation that output is cleared for commercial use.
Prohibited uses of output: You may not use AI-generated output to impersonate, defame, sexualize, or harass any individual, or to create synthetic media intended to deceive (deepfakes for fraudulent purposes). Violations will result in account termination.
8. State-Specific Disclosures
Illinois — Biometric Information Privacy Act (BIPA)
If you are an Illinois resident, you have specific rights under 740 ILCS 14/1 et seq. (BIPA):
- You have the right to know what biometric data we collect and our retention/destruction policy (see Sections 3 and 4 above).
- Your submission of photos for AI processing constitutes written consent to the collection and use of biometric identifiers and information as described in this policy.
- We do not sell, lease, trade, or profit from your biometric data.
- We do not disclose biometric data to third parties except to AI processing providers under written contracts that prohibit independent use of the data.
- You may request deletion of your biometric data at any time. See Section 4.
Texas — Capture or Use of Biometric Identifier (CUBI), Tex. Bus. & Com. Code § 503.001
If you are a Texas resident: we capture biometric identifiers solely for the commercial purpose of delivering AI photo and video processing services. We do not sell biometric identifiers. We will destroy biometric data within a reasonable time after the purpose for which it was collected has been fulfilled, consistent with our retention schedule in Section 4.
Washington — My Health MY Data Act (MHMD)
If you are a Washington resident: facial geometry data may constitute consumer health data under the MHMD Act. We collect this data solely to deliver the services you request, do not sell it, and provide deletion rights as described in Section 4.
California — CCPA / CPRA
Biometric data is a category of sensitive personal information under the California Consumer Privacy Act. California residents have the right to limit the use of sensitive personal information to what is necessary to provide the requested service. Our use of facial data is already limited to service delivery as described herein. You also have the right to request deletion. See Section 4 and our Privacy Policy for full CCPA rights.
European Union — GDPR Article 9
Biometric data processed for the purpose of uniquely identifying a natural person is a special category of personal data under GDPR. Our legal basis for processing is your explicit consent (Article 9(2)(a)), provided when you upload photos for AI processing. EU residents have the right to withdraw consent, request erasure, and lodge a complaint with their supervisory authority.
9. Third-Party AI Providers
To deliver our AI pipeline, we transmit your uploaded photos to third-party AI processing APIs. Current providers involved in facial processing include:
- Anthropic (Claude) — image analysis for project tagging and scene understanding. Anthropic's API does not retain submitted images.
- fal.ai — video generation (Kling AI). Submitted images are used to generate video clips and are subject to fal.ai's data handling terms.
- Shotstack — video rendering and composition. Processed media assets are submitted for rendering and deleted after render completion.
We select providers who contractually commit to not using submitted data for their own model training or commercial purposes. We cannot make absolute guarantees about third-party data practices and encourage you to review their respective privacy policies.
10. Changes to This Policy
We will notify you by email of any material changes to this policy. Given the sensitivity of biometric data, we will provide at least 30 days' notice before any material changes take effect, and will seek fresh consent where required by law.
11. Contact & Deletion Requests
For biometric data deletion requests, consent withdrawal, or questions about this policy:
privacy@snapshots.cloud
We respond to all biometric data requests within 30 days.