Biometric Data Notice
Last updated: October 14, 2026
This notice explains how collects, uses, shares, keeps and destroys your photos and the face data derived from them. It is our public retention and destruction schedule, and it is part of our Privacy Policy.
In short
- We use your photos and face data only to make your headshots.
- We never use them to identify anyone, never sell them, and never use them to train shared or general AI models.
- Your selfies are deleted 7 days after delivery, or 24 hours after upload if you don’t buy. Your headshots are deleted 30 days after delivery. The full schedule covers every other case.
- You can delete everything at once, at any time, from your gallery or by emailing .
What we collect
- Your selfies: the 6 to 10 photos you upload, and any photos you send to replace them.
- Face measurements from the photo checks: where your face is in each selfie, how far your head is turned (worked out from the positions of your eyes and nose), and a short fingerprint of the whole picture that lets us spot the same photo uploaded twice. We store them with the selfie and remove them within an hour after the selfie is deleted. We keep only the result of each check (passed, or which rule it failed).
- Face embeddings: a set of numbers that describes the face in a photo. We use them to measure how closely each generated headshot resembles your selfies. They are computed on our own server for each comparison and discarded as soon as that comparison is done. They are never kept in memory afterwards, and never written to disk or to a database.
- Your headshots: the images we generate from your selfies, including any edits you order. They show your likeness.
Some state laws, including those of Illinois, Texas, Washington and Colorado, treat photos of a face or data derived from them as biometric identifiers, biometric information or biometric data. We treat all of the above that way, whichever state you live in.
The only purpose we use it for
We use your photos, face data and headshots to provide the service you ordered:
- to check that your photos are usable (one face, clearly visible, facing the camera, sharp, large enough, not a duplicate);
- to screen your selfies and your headshots for nudity and sexual content;
- to generate your headshots and check that they look like you;
- to apply the edits you order;
- to show your headshots in your private gallery and let you download them.
We never:
- use them to identify or authenticate you or anyone else, or compare your face against other people or any database;
- sell, lease or trade them, or otherwise profit from them beyond providing the headshots you paid for;
- use them, or let our processors use them, to train shared or general AI models;
- use them in our advertising or as examples of our work.
Your consent
Before you upload anything, we ask you to tick four boxes:
- You are 18 or older, and every photo you upload is of you.
- You agree to our Terms of Service and Privacy Policy.
- You consent to us processing your photos and the face data derived from them to make your headshots, as this notice describes.
- You agree that your photos are shared with fal.ai, OpenAI and Google, only to generate your headshots.
Ticking the boxes and continuing is your written release and electronic signature. We store the version and wording of the text you agreed to, the time, your IP address and the state of each box. Without all four we cannot make your headshots.
Who receives your photos
- fal.ai runs the image models for us. We send your selfies inside each request rather than uploading them as files, and with fal’s storage turned off, so fal keeps no copy. The images it returns expire from its servers 1 hour after they are made, and we copy them to our own server straight away.
- OpenAI and Google provide the image models that generate your headshots. We reach them through fal.ai.
- Our hosting provider supplies the server where your files are stored, under contract.
- Authorities, only when a valid warrant, subpoena or law requires it.
We share your photos and face data with no one else. Our payment, email and advertising providers never receive them.
Retention and destruction schedule
| Data | When we destroy it |
|---|---|
| Selfies, if you don’t order | 24 hours after upload |
| Selfies, once your headshots are delivered | 7 days after delivery |
| Selfies, if your order fails or is refunded | 7 days after the refund, or 7 days after payment if there was no refund |
| Selfies, if a paid order is never delivered | 30 days after payment |
| A selfie you remove or replace | At once |
| Face measurements from the photo checks | Within 1 hour after the selfie they came from is destroyed |
| Face embeddings | Never stored. Discarded as soon as each comparison is done |
| Headshots and edits | 30 days after delivery, or 30 days after payment if they were never delivered |
| Unfinished images from an interrupted generation | Within 1 hour |
| Images at fal.ai | Your selfies are never stored there. Generated images expire 1 hour after they are made |
| Everything above | At once, when you press “Delete all my photos now” in your gallery, ask us by email or withdraw your consent |
Deletion runs automatically every hour. Every deletion is logged with what was deleted and when; the log never contains the photos themselves.
In every case we destroy this data once its purpose is met, and never later than 3 years after your last interaction with us, the outer limit set by Illinois law. The schedule above is far shorter.
What we keep after your photos are gone
These records contain no photos and no face data:
- Your consent record (the text you agreed to, the time, your IP address and the box states): 5 years after your selfies are destroyed, so we can show that you agreed for as long as a claim could be brought.
- Order and payment records: 7 years after payment or the last refund, for tax and accounting.
- The deletion log: 7 years.
Withdrawing your consent
You can withdraw your consent at any time with the “Delete all my photos now” button in your gallery, or by emailing from the address you used to order. Withdrawing deletes your selfies and every headshot at once, so download the ones you want to keep first.
If your headshots haven’t been delivered yet, we stop the order and refund it in full. After delivery, refunds follow our Refund Policy.
How we protect it
Your files travel over encrypted connections and are stored on our server, not on public links. Your gallery opens only with its private, unguessable link. Only the people who run the service can reach the server, and the keys for our processors never leave it.
State-specific information
Illinois
Under the Biometric Information Privacy Act, we tell you in writing what we collect, why and for how long, and we get your written release before we collect anything. This page is our publicly available retention schedule. We do not sell, lease, trade or otherwise profit from your biometric data, we disclose it only with your consent or when the law requires it, and we destroy it when its purpose is met or within 3 years of your last interaction, whichever comes first.
Texas
Under the Capture or Use of Biometric Identifier Act, we inform you and get your consent before any capture. We do not sell, lease or disclose your biometric identifiers except to complete the service you asked for or as the law requires, and we destroy them well within the legal limit of one year after their purpose ends.
Washington
Washington’s My Health My Data Act treats images of a face as consumer health data. Our separate Consumer Health Data Privacy Policy covers it.
Colorado and other states
Colorado requires a public policy for biometric data and deletion at the earliest of the purpose being met, 24 months after your last interaction, or 45 days after the data is no longer needed. Our schedule meets all three. Several other states, including Connecticut, Virginia and Oregon, treat biometric data as sensitive and require opt-in consent; the boxes you tick before uploading are that consent. Your other privacy rights are in our Privacy Policy.
Changes to this notice
If we change how we use, share or keep your photos or face data, we will update this page and its date first. We will never use data we already hold for a new purpose without asking you again.