1. What we compute and why
1.1. After restoring a photo we check whether the face in the restoration matches the face in your original. Software computes a temporary numerical representation of facial features (an embedding) for the original and for the restoration and compares them. In some jurisdictions such a representation may be treated as a "scan of face geometry", a biometric identifier or biometric data.
1.2. The sole purpose is quality control of our own work: making sure we have not distorted the face. There is no other purpose.
2. What we never do
- we do not work out who is depicted and do not confirm anyone's identity (no identification, no authentication);
- we do not compare against any database of faces, do not build one and do not enrol the data in any database;
- we do not store it, write it to disk or include it in backups;
- we do not sell, lease, trade, disclose to third parties or otherwise profit from it;
- we do not use it to train models — ours or any provider's;
- we do not use it for anything other than the purpose in 1.2.
3. Retention schedule and destruction guidelines
3.1. Retention period: zero. The numerical representation exists only in working memory while the comparison runs (seconds) and is permanently destroyed immediately afterwards, within the same processing session. The purpose is satisfied the moment the comparison completes; that is the moment of destruction.
3.2. This is far shorter than the statutory limits: three years from the last interaction (Illinois), one year after the purpose expires (Texas), 24 months from the last interaction or 45 days after the data is no longer needed (Colorado). We keep this data for no time at all.
3.3. Destruction means removal from working memory with no copy made. Because the data is never written to storage media, no media-wiping procedure is needed. The numerical representation is not passed to any provider or third party. This Notice concerns only the numerical representation; the photographs themselves are kept for the periods in section 9 of the Privacy Policy.
4. Consent
4.1. We do not run the Similarity Check without your prior written consent. At checkout you tick a separate checkbox with this wording:
"I confirm the warranties about the photos: I have the right to use them; living depicted persons (and parents/guardians of children) have consented; for deceased persons I am a family member and know of no objection from those entitled to consent. I consent to the temporary automated face Similarity Check described in the Privacy Policy and understand its data is not retained."
4.2. The tick, recorded with date, time, IP address and document version, is your electronic signature and written release within the meaning of BIPA, your consent under the Texas, Washington and Colorado statutes, your unambiguous consent under Article 7 of the Ukrainian law and — where this data counts as biometric — your explicit consent under Article 9(2)(a) GDPR / UK GDPR.
4.3. Other living people in the photos. You confirm that you have informed them and obtained their consent; for children, that you are their parent or guardian or have that person's consent. Show them this Notice before ordering.
4.4. The deceased. Biometric-data laws concern living people. We nevertheless apply the same destruction rules to every face.
4.5. Non-automated alternative. You may decline or withdraw consent by writing to hello@vidlunnya.com before production starts. A person will then check the likeness by eye — no numerical representation is computed and there is no extra charge. Declining is never a reason to refuse you the service.
5. Orders from the US and Canada
5.1. For Orders from the US and Canada the Studio may not run the automated check at all and carry out manual review only. In that case your consent under 4.1 is not used and no numerical representation is computed. This Notice holds true either way.
6. Security and incidents
6.1. The computation runs in a protected environment (TLS, role-based access, action log), protected at least as well as our other confidential data. Because the numerical representation is not stored, there is no body of such data that could leak or be stolen. Any incident affecting your data is reported to the regulator and to you under section 15 of the Privacy Policy.
7. Questions and complaints
7.1. Write to hello@vidlunnya.com. US residents may contact their state Attorney General; residents of Ukraine, the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua). Changes to this Notice follow section 17 of the Privacy Policy.