Privacy Policies

UNIVERSAL PRIVACY POLICY & BIOMETRIC DATA NOTICE

Business Name: Frampton Production / Frampton Photography ("FP")

Primary Platforms: Studio Ninja (Client Management) & Pic-Time (Gallery Delivery)

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1. OVERVIEW & SCOPE

Frampton Production / Frampton Photography ("FP") respects your privacy and is committed to protecting the personal data of our clients, event attendees, and gallery visitors. This Privacy Policy outlines how we collect, use, store, and protect your information across all photography services—including Event, Dance, Headshot, Corporate, Couple, Portrait, Sports, and Wedding bookings.

2. INFORMATION WE COLLECT

We collect information necessary to provide our professional photography services, process bookings, and deliver media:

- Client Contact & Booking Data: Names, email addresses, phone numbers, billing addresses, and event details collected via Studio Ninja booking forms or contract executions.

- Gallery Access Data: Email addresses, IP addresses, and gallery interaction history logged when you view, favorite, or download images via Pic-Time.

- Visual & Audio Media: Digital photographs, RAW data, and video footage captured during contracted sessions or events.

- Payment Information: Transaction details required to process invoices and gallery store orders (processed securely through third-party payment gateways; FP does not store full credit card details).

3. HOW WE USE YOUR INFORMATION

We use the collected information for the following specific purposes:

- Fulfilling photography services, managing schedules, and processing contracts via Studio Ninja.

- Delivering online image galleries and print store services via Pic-Time.

- Responding to inquiries, sending invoices, and providing ongoing customer support.

- Marketing and promotional display (such as website portfolios, social media showcases, and industry entries) in accordance with our Master Terms of Service, unless an opt-out has been requested in writing prior to booking or download.

4. PIC-TIME AI PHOTO SEARCH, FACE GROUPING & BIOMETRIC DATA

Our gallery delivery platform, Pic-Time, offers optional AI Photo Search and Face Grouping features to help clients and guests easily find photos (e.g., finding photos of themselves, selfie searching, or filtering images).

(a) Biometric Data & Mathematical Embeddings:

When AI Photo Search or Face Grouping features are activated within a gallery, automated systems detect facial regions and generate 512-dimensional numerical feature vectors ("Face Data" / face embeddings). This Face Data is an abstract mathematical representation used solely for sorting and grouping images within that specific gallery.

(b) Strict Limitations on Use:

- No Identity Verification: Face Data is strictly used for in-gallery search and organizing. It is never used for identity verification, fraud detection, security, tracking individuals across unrelated galleries, or building user profiles.

- No Name Association: Names are never attached to face embeddings, and users/guests cannot "name a face."

- Internal Models & No Third-Party Sales: All AI models are developed internally by Pic-Time. Face Data is never sold, leased, traded, or shared with third parties for their own commercial use.

If a guest uses the "Selfie Search" feature by uploading a temporary photo, the resulting Face Data is processed for that specific session only and is immediately deleted once the guest exits the gallery.

(d) Consent, Opt-Out & Data Retention:

- Controller & Processor Roles: FP acts as the Data Controller for gallery media, and Pic-Time acts as the Data Processor.

- Notice & Opt-Out: The AI Photo Search feature operates on an opt-in/opt-out basis. In jurisdictions requiring explicit consent for biometric data collection, features will only be offered upon clear notice or opt-in. Users may opt out of facial recognition data collection at any time by disabling the feature within the gallery or submitting a request to FP.

- Permanent Destruction Schedule: Face Data and associated biometric embeddings are permanently destroyed when the gallery expires (12 months from delivery), when the feature is disabled, or upon receipt of a valid deletion request—whichever occurs first.

5. PUBLIC GALLERIES & THIRD-PARTY ACCESS

For events, dances, sports, or general public shoots, online galleries delivered via Pic-Time may be accessible by third parties or members of the general public.

- Information Logged: Accessing or downloading media from a public gallery logs your session activity and email address.

- Acceptance of Terms: Anyone accessing, viewing, or downloading media from a public gallery automatically agrees to our Terms of Service and this Privacy Policy.

- Privacy & Deletion Requests: If you appear in a public gallery and wish to request image removal, face grouping correction, or gallery privacy controls, please contact FP directly.

6. DATA SHARING & THIRD-PARTY SERVICES

FP does not sell, rent, or trade your personal information. We only share data with trusted service providers essential to running our business operations:

- Studio Ninja: Customer relationship management, contract signing, and booking audit logging.

- Pic-Time: Online gallery hosting, digital delivery, AI image search, and automated print lab fulfillment.

- Professional Print Labs: Fulfilling physical print and album orders placed through your gallery.

- Legal Compliance: Disclosing information if required by applicable law, court order, or governmental regulation.

7. DATA SECURITY

We implement standard administrative, technical, and digital security measures (including industry-standard encryption) to safeguard your personal information, contracts, photos, and any associated Face Data against unauthorized access, loss, or misuse.

8. YOUR PRIVACY RIGHTS & CONTACT INFORMATION

Depending on your jurisdiction, you have the right to request access to the personal data we hold about you, request corrections to inaccurate information, opt out of AI/biometric data processing, or request the deletion of your personal contact data and gallery face embeddings.

For any privacy-related questions, image removal requests, or biometric data opt-out requests, please contact:

Frampton Production / Frampton Photography

Email: info@framptonproduction.com

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TERMS OF ACCEPTANCE:

By booking a session through Studio Ninja, signing a contract, accessing a Pic-Time online gallery, or downloading any digital media, you consent to the collection, use, and processing of your information and biometric data as outlined in this Privacy Policy.