Privacy Policy

Last updated: May 9, 2026

Operator: Terena Group LLC, a New York limited liability company Mailing Address: 418 Broadway, Ste N, Albany, NY 12207, United States Email: support@gaze.photo

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1. Introduction

Gaze ("we," "our," or "us") is operated by Terena Group LLC and provides the Gaze platform at gaze.photo. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our digital photobooth platform, including our website, capture experiences, kiosk mode, live display walls, galleries, publisher portal, and related services (collectively, the "Service").

This policy applies to event organizers who create and manage events through Gaze, and to event guests who interact with capture experiences, view galleries, or receive photos through the Service.

We believe in transparency. This policy is written in plain language so you can understand exactly what data we collect and why. If anything is unclear, please contact us at support@gaze.photo.

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2. Information We Collect

We collect information in three ways: information you provide directly, information collected automatically when you use the Service, and information from third-party authentication providers.

2.1 Information You Provide

2.2 Information Collected Automatically

2.3 Cookies & Local Storage

We use a minimal set of cookies and browser storage:

Essential cookies are strictly necessary for the Service to function and do not require consent. Analytics cookies (Microsoft Clarity and the synchronized Bing UET pixel) are set only on marketing pages and organizer / publisher dashboards and are not loaded on guest-facing pages or auth-flow pages. Where required by applicable law (including the GDPR ePrivacy Directive), we will obtain your consent before setting analytics cookies. We honor the Global Privacy Control (GPC) browser signal as an opt-out for analytics cookies; visitors with GPC enabled will not be tracked. You may also opt out of analytics cookies at any time through your browser settings. Microsoft may set additional operational cookies per the Microsoft Privacy Statement.

We do not use advertising or marketing cookies.

2.4 Information We Do NOT Collect

• We do not collect precise geolocation data.
• We do not use facial recognition, facial analysis, or biometric identification on captured photos or videos. Photos and videos are stored and delivered as standard media files only. We do not extract, store, or process biometric identifiers or biometric information as defined under any applicable biometric privacy law.
• We do not knowingly collect personal information from children under 13 years of age. See Section 8 (Children's Privacy) for details.

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3. How We Use & Share Your Data

3.1 How We Use Your Data

We process your personal information for the following purposes:

• Providing the Service — storing, processing, and delivering photos to event guests; managing events and galleries; running kiosk and live wall experiences; operating the publisher portal at vanity URLs of the form gaze.photo/u/{handle}; serving the Help Center and surfacing relevant articles
• Account management — authenticating users, managing profiles, plan tier and entitlements, the publisher-portal vanity handle, and the Stripe Customer Portal session (which lets you manage payment methods, download invoices, change subscription, and cancel)
• Billing — processing subscription payments, managing one-off event-credit purchases, applying plan entitlements (event count, storage, capture-mode availability), and applying prorations when you change plans mid-cycle
• Analytics — generating event performance insights for organizers (session counts, capture breakdowns) and product analytics for ourselves (heatmaps, error rates) on the surfaces described in Sections 2.2 and 2.3
• Security — rate limiting, fraud prevention, abuse detection, audit logs (e.g. retained Stripe webhook events for billing reconciliation), and protecting the integrity of the platform
• Communication — sending transactional emails (account verification, password resets, photo delivery, security alerts) and, only if you opted in at signup or in your account settings, occasional product updates

Legal bases for processing (for EU/EEA/UK users under GDPR):

• Contract performance — processing necessary to provide the Service you signed up for
• Legitimate interest — security, fraud prevention, and platform improvement
• Consent — for analytics cookies where required by law

3.2 Third-Party Service Providers

We share data with the following service providers, strictly for the purposes described. We do not sell, rent, or trade your personal information.

3.3 Sub-Processors

For event organizers acting as data controllers under GDPR: the service providers listed above are our sub-processors. A complete list of sub-processors with entity names, processing locations, and purposes is maintained at gaze.photo/subprocessors. We will notify organizers by email at least 30 days before adding a new sub-processor, and organizers may object to a new sub-processor during that period.

3.4 Other Disclosures

We may also disclose your information:

• To comply with legal obligations — in response to a subpoena, court order, or other lawful government request
• To protect rights and safety — to enforce our Terms of Use, protect our rights, or protect the safety of our users or the public
• In a business transfer — if Gaze is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction; we will notify you via email or prominent notice on the Service before your information becomes subject to a different privacy policy

3.5 Public Surfaces (Publisher Portal)

If you publish a vanity-handle profile under gaze.photo/u/{handle}, the following profile-level information is public by design and is indexable by search engines and link-preview generators (open-graph cards, social media unfurls, messaging apps):

• Your vanity handle, display name, profile avatar, and bio
• The list of events you have published on your profile page

Per-event landing pages are not publicly indexed. Pages of the form gaze.photo/u/{handle}/{event-name} (and the corresponding gallery, capture, kiosk, live-wall, and download sub-pages) carry a noindex, nofollow, noarchive, nosnippet, noimageindex directive and are also excluded from robots.txt. The pages remain reachable to anyone who has the direct link (a QR code, an emailed invitation, a social share), but search engines will not crawl, archive, or surface their contents (event name, description, cover image, or the photos themselves) in search results, link previews, or image search.

Captured photos, videos, GIFs, and boomerangs themselves are stored in private cloud storage and are served only via short-lived signed URLs, so they are not directly indexable by search engines under any circumstance.

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4. Your Rights & Controls

4.1 Rights for All Users

Regardless of where you are located, you can:

• Access your personal data by viewing your account profile and event data
• Correct inaccurate information through your account settings
• Delete your account and associated data through account settings or by contacting us
• Export your event media and data using the data export feature in your account settings

4.2 Additional Rights for EU/EEA/UK Users (GDPR)

If you are located in the European Union, European Economic Area, or the United Kingdom, you also have the right to:

• Rectification — request correction of inaccurate personal data
• Erasure ("Right to be Forgotten") — request deletion of your personal data
• Data portability — receive your data in a structured, commonly used, machine-readable format
• Restrict processing — request that we limit how we use your data
• Object to processing — object to processing based on legitimate interest, including the right to object to Microsoft Clarity analytics
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing
• Lodge a complaint — file a complaint with your local data protection supervisory authority (for UK users, this is the Information Commissioner's Office at ico.org.uk)

We will respond to GDPR requests within 30 days.

4.3 Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, under the California Consumer Privacy Act and California Privacy Rights Act you have the right to:

• Right to Know — request what personal information we have collected, used, and disclosed about you in the past 12 months
• Right to Delete — request deletion of your personal information
• Right to Correct — request correction of inaccurate personal information
• Right to Opt-Out of Sale or Sharing — we do not sell or share your personal information for cross-context behavioral advertising, so no opt-out is necessary
• Right to Limit Use of Sensitive Personal Information — photos captured through the Service may constitute sensitive personal information; we process this data only as necessary to provide the Service
• Right to Non-Discrimination — we will not discriminate against you for exercising your privacy rights

We will respond to CCPA/CPRA requests within 45 days.

4.4 Additional Rights Under Other US State Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Oregon, Texas, Montana, or other states with comprehensive privacy laws, you may have similar rights to access, correct, delete, and port your personal data, and to opt out of certain processing activities. We honor the Global Privacy Control (GPC) signal as a valid opt-out request where required by applicable law. To exercise your rights, contact us using the methods described in Section 4.6.

4.5 Rights for Canadian Users (PIPEDA)

If you are located in Canada, under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, you have the right to:

• Access — request access to the personal information we hold about you
• Correction — request correction of inaccurate or incomplete personal information
• Withdrawal of consent — withdraw your consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions
• Challenge compliance — file a complaint with the Office of the Privacy Commissioner of Canada if you believe we have not handled your personal information in accordance with PIPEDA

We collect, use, and disclose your personal information only for the purposes identified in this Privacy Policy and with your knowledge and consent, except where otherwise permitted or required by law. We will respond to PIPEDA access and correction requests within 30 days.

To exercise your rights, contact us using the methods described in Section 4.6.

4.6 How to Exercise Your Rights

To exercise any of the rights above:

1. Account holders (organizers): Delete your account or update your information through your account settings, or email support@gaze.photo with the subject line "Privacy Rights Request"
2. Event guests: Because event organizers act as data controllers for guest data captured at their events, guests should direct privacy requests (access, deletion, correction) to the event organizer who hosted the event. If the organizer does not respond within 14 days, or you are unable to reach them, you may contact us at support@gaze.photo with the subject line "Guest Privacy Rights Request" and we will make reasonable efforts to assist.
3. Marketing email opt-out: Every product-update email we send includes a one-click unsubscribe link (also available in your account settings under Communication preferences). Unsubscribing from marketing email does not affect transactional emails (account verification, password resets, photo delivery, security alerts).
4. By mail: You may also send written requests to Terena Group LLC, 418 Broadway, Ste N, Albany, NY 12207, United States. Email is faster and we recommend it where available.

For account holders, we will verify your identity by confirming your account email address. For guest requests routed through us, we will verify your identity by confirming the contact information you provided at the event. For requests made on behalf of another person, we may require authorized agent documentation. We will not charge a fee for processing reasonable requests.

4.7 Event Organizer Responsibilities

If you are an event organizer using Gaze, you are responsible for:

• Informing your event guests that photos are being captured and how they will be used
• Obtaining any necessary consent from guests before capturing their photos, including verifiable parental or guardian consent for children under 13
• Posting visible signage at events where photos may be displayed on live walls or shared publicly
• Configuring appropriate data retention and gallery privacy settings for your events
• Complying with all applicable biometric privacy laws when operating events in jurisdictions with such laws

Gaze acts as a data processor on behalf of event organizers (who act as data controllers) with respect to guest data captured at events. Event organizers who require a Data Processing Agreement (DPA) can access one at gaze.photo/dpa.

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5. Security & Updates

5.1 How We Protect Your Data

We implement industry-standard security measures to protect your personal information:

• Encryption in transit — all data transmitted between your device and our servers is encrypted using TLS (HTTPS)
• Secure file storage — media files are stored in private cloud storage buckets and can only be accessed via time-limited signed URLs (1-hour expiry) for all assets, with proactive refresh 5 minutes before expiry on the client
• Event-owner-scoped storage access — in addition to signed URLs, our captures storage bucket enforces a row-level policy that limits read and delete operations on any event's files to the user who owns that event (storage path: events/{eventId}/...)
• Image metadata stripping — we strip embedded EXIF and IPTC metadata (including GPS coordinates, camera model, device serial, and timestamp data) from JPEG and PNG uploads — both event captures and brand assets — before the file is written to storage
• Upload integrity — capture file writes use collision-protected mode (no overwrite of an existing object on the same path); video poster images are constrained to a JPEG/PNG MIME allowlist and verified by magic-byte inspection
• Authentication security — session tokens are cryptographically signed using HMAC-SHA256; kiosk exit PINs are hashed using PBKDF2-SHA256 with 100,000 iterations; account passwords are managed by Supabase Auth (bcrypt)
• Rate limiting — API endpoints are protected against abuse with per-IP rate limiting
• Access controls — database tables are protected with row-level security policies; sensitive fields (gallery passwords, kiosk PINs) are stripped before client-side storage
• Kiosk session isolation — kiosk sessions are isolated between guests; each session is cleared upon completion to prevent access by subsequent users
• Diagnostic source maps — we upload application JavaScript source maps to Sentry (our error-monitoring sub-processor) solely to make production stack traces resolvable; source maps contain no end-user data

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

5.2 Security Incident Response

In the event of a data breach that compromises your personal information, we will:

• Notify affected event organizers (as data controllers) without undue delay and within 72 hours of becoming aware of the breach, where feasible
• Notify relevant supervisory authorities as required by applicable law (including GDPR and applicable US state breach notification laws)
• Notify affected individuals as required by applicable law
• Provide details of the nature of the breach, the data involved, and the measures taken to address it

5.3 Data Retention

5.4 Data After Termination

When you delete your account, your data — including your profile, events, media, and settings — is deleted from active systems immediately. Database backups containing your data are cycled out within 7 days. Payment records processed by Stripe are retained by Stripe in accordance with applicable tax and financial regulations. We recommend exporting your data before deletion using the data export feature in your account settings or by contacting support@gaze.photo.

5.5 International Data Transfers

Your data is processed and stored in the United States via our infrastructure provider (Supabase). If you are accessing the Service from outside the United States, your data will be transferred to the US. For transfers from the EU/EEA, we rely on Standard Contractual Clauses (SCCs) as approved by the European Commission. For transfers from the United Kingdom, we rely on the International Data Transfer Addendum (IDTA) to the SCCs as approved by the Information Commissioner's Office. Where applicable, we also rely on the EU-US Data Privacy Framework.

5.6 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

• We will update the "Last updated" date at the top of this page
• For significant changes, we will notify you by email or through a prominent notice on the Service

Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

5.7 Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices:

• Operator: Terena Group LLC
• Mailing Address: 418 Broadway, Ste N, Albany, NY 12207, United States
• Email: support@gaze.photo

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6. Children's Privacy

The Service is not directed at children under 13 years of age. Gaze does not knowingly collect personal information from children under 13. However, we recognize that events may include minor attendees.

If we learn that personal information has been collected from a child under 13 without verifiable parental consent, we will take steps to delete that information promptly. Parents or guardians may contact us at support@gaze.photo to request deletion of a child's data.

Event organizers are solely responsible for obtaining verifiable parental or guardian consent before capturing photos of children under 13 at their events, in compliance with the Children's Online Privacy Protection Act (COPPA) and any other applicable child privacy laws. Gaze does not collect email addresses, phone numbers, or other contact information from event guests (including children) — photos are delivered via QR code, native share (which on iOS includes AirDrop), or direct download only.