Privacy Policy

1. Introduction

At Protevio AI ("Protevio", "We", "Us"), we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your data when you use our facial recognition search platform.

By using our services, you consent to the data practices described in this policy. Please read this document carefully alongside our Terms of Service.

2. Biometric Data Processing ⚠  CRITICAL

2.1 What Biometric Data We Collect

When you upload a photo to search, we create mathematical representations called "facial embeddings" or "facial templates." These are:

• NOT stored permanently — We process them and delete within specified timeframes
• Unique numerical representations — Mathematical vectors representing facial geometry
• Cannot be reverse-engineered — Cannot reconstruct original photo from embeddings
• Used only for matching — To compare against our indexed faces

2.2 How We Process Biometric Data

1. Upload: You provide a photo
2. Embedding Creation: Our AI generates a facial template (~512-dimensional vector)
3. Comparison: Template is compared against indexed faces in our database
4. Results: Matching faces are returned to you
5. Deletion: Your template is deleted per retention schedule (see Section 8)

2.3 Legal Basis & Your Biometric Data Rights

We process biometric data under distinct legal frameworks depending on the data source:

• User-Uploaded Photos (Search Queries): Processed based on explicit Informed Consent. Used solely for the duration of the search/matching process and strictly deleted per our retention schedule.
• Publicly Indexed Data (OSINT Index): The facial embeddings in our search index are generated exclusively from publicly accessible images on the open web. This processing relies on our Legitimate Interest to provide fraud prevention, identity verification, and OSINT services, operating under the legal basis that the data has been manifestly made public by the data subject (e.g., GDPR Article 9(2)(e) and Article 6(1)(f)).

For all biometric data, we enforce strict rights:

• No Sale: We never sell or profit from raw biometric data.
• Security: Encrypted in transit (TLS 1.3) and at rest (AES-256).
• Opt-Out: Any individual can request immediate removal of their data from our index via our Opt-Out Form.

2.4 Compliance with Biometric Laws

We adhere to global biometric and privacy standards:

• GDPR (EU): Processing special category data under Article 9(2)(e) (manifestly public data) and Article 9(2)(a) (explicit consent for user uploads).
• Illinois BIPA & Texas CUBI: Strict adherence to retention maximums, security requirements, and prohibitions on data sales.
• Washington HB 1493: Compliance with consumer biometric protection standards.

3. What Personal Data We Collect

3.1 Information You Provide

• Account Information: Email address, password, name
• Identity Verification: For certain services: full name, address, anonymized ID scan
• Photos: Images you upload for facial recognition searches
• Payment Data: Name, billing address, payment method (processed by third-party)
• Communications: Support tickets, feedback, survey responses
• Opt-Out Requests: Photo, anonymized ID, email, phone number

3.2 Automatically Collected Data

• Usage Data: Search queries, features used, time spent
• Device Data: Browser type, OS, device model, screen resolution
• Location Data: IP address, approximate geographic location
• Log Data: URLs accessed, timestamps, referrer URLs, errors
• Performance Data: Page load times, API response times

3.3 Data in Protevio's Search Index

Our search engine indexes publicly available images from the open web:

• Facial embeddings of faces found in publicly accessible images
• Source URLs where images were found
• Image metadata (when available): alt text, surrounding context
• NOT indexed: Social media, private accounts, paywalled content
• Identity unknown: We don't know who individuals in indexed photos are

4. How We Use Your Data

Purpose	Legal Basis	Data Used
Create and maintain OSINT search index	Legitimate interest & Manifestly public data (Art. 9(2)(e))	Public images, source URLs, embeddings
Provide search services	Contract performance	Photos, embeddings, account data
Process payments	Contract performance	Payment data, billing info
Customer support	Contract performance	Email, support tickets
Improve services	Legitimate interest	Usage data, feedback
Prevent fraud/abuse	Legitimate interest	Usage patterns, device data
Legal compliance	Legal obligation	As required by law
Marketing (opt-in)	Consent	Email, preferences

5. AI Technology & Limitations

5.1 Technology Overview

• Model Architecture: Deep convolutional neural networks (ResNet-based)
• Training Data: Millions of diverse facial images
• Accuracy Rate: Approximately 95% under optimal conditions
• Processing Speed: <800ms average per search

5.2 Known Limitations

• False Positives: ~5% of results may be incorrect matches
• Photo Quality: Low resolution, blur, or extreme angles reduce accuracy
• Lighting: Poor lighting or extreme shadows affect matching
• Age Changes: Significant aging may reduce match accuracy
• Occlusion: Sunglasses, masks, hats reduce facial area available
• Demographics: We work to minimize bias, but accuracy may vary

5.3 Acceptable Use and Limitations

Protevio is designed as an advanced Open-Source Intelligence (OSINT) and investigative support tool.

✅ Authorized Uses include:

• Investigative support for authorized law enforcement and government agencies.
• Institutional integrity auditing and compliance checks.
• Fraud prevention and identity verification (KYC/AML) by authorized businesses.
• Professional open-source intelligence research.
• Copyright protection and DMCA enforcement.

🚫 Limitations of the AI (Disclaimer of Liability):

Protevio's results are strictly informational and represent mathematical probabilities, not absolute certainties. Our AI-generated matches must NOT be used as the sole basis for:

• Automated legal, judicial, or criminal judgments without independent human investigation.
• Final employment termination or hiring decisions without corroborating evidence and human review.
• Automated denial of essential services, credit, or insurance.

Operators and clients must independently verify all matches through human review and corroborating legal evidence before taking any significant action.

5.4 Bias Mitigation

We actively work to reduce algorithmic bias by:

• Training on diverse, representative global datasets.
• Conducting regular audits for demographic performance disparities.
• Providing full transparency to our professional clients regarding confidence scores, potential limitations, and accuracy rates.

6. Photo Upload Policy

6.1 Photo Processing

By uploading photos, you agree that:

• Photos are used solely to provide search services
• We create facial embeddings from your photos
• Photos are encrypted in transit (TLS 1.3) and at rest (AES-256)
• We never use your photos for advertising or marketing
• We never sell your photos to third parties

6.2 Photo Ownership & License

• You Own Your Photos: Uploading doesn't transfer ownership
• License Granted: You grant us a limited license to process photos for services
• License Duration: Ends when you delete photos or close account
• License Scope: Only for facial recognition matching, no other use

6.3 Third-Party Sharing

We share photos ONLY with:

• Cloud Infrastructure: AWS/GCP for secure storage (encrypted)
• AI Processing: Our neural network models (isolated environment)
• Never Shared With: Advertisers, data brokers, or other users

7. Data Sharing with Third Parties

7.1 Service Providers

We share data with trusted partners who help us operate:

• Payment Processors: Stripe, PayPal (name, payment details)
• Cloud Hosting: AWS, Google Cloud (encrypted data)
• Email Service: SendGrid (email address for transactional emails)
• Analytics: Google Analytics (anonymized usage data)
• Customer Support: Zendesk (support tickets)

7.2 Legal Obligations

We may disclose data when:

• Required by law, court order, or legal process
• To respond to valid law enforcement requests
• To protect our rights, property, or safety
• To prevent fraud, abuse, or illegal activity

7.3 Business Transfers

If Protevio is acquired or merged, your data may be transferred. We'll notify you and ensure continued protection.

7.4 With Your Consent

We may share data for other purposes with your explicit consent.

8. Data Retention Periods

Secure Deletion: When retention periods expire, data is securely deleted using industry-standard methods (overwriting, cryptographic erasure).

Identity Verification for DMCA Services

What We Collect

When you use our automated DMCA takedown service, we require a one-time identity verification. During this process, we temporarily collect:

• Selfie photograph: A clear photo of your face for identity confirmation
• Government-issued ID (redacted): A photo of your government ID with your name visible and other sensitive details (ID number, date of birth, address) redacted or covered
• Legal name and contact email: Used for generating DMCA notices on your behalf

How We Process This Data

• Your selfie and ID document are stored temporarily in our database for admin review only.
• Review is conducted by authorized Protevio administrators to verify that the selfie matches the ID document.
• No automated facial comparison is performed during the verification process.

Immediate Data Deletion

What We Retain After Verification

After your identity documents are deleted, we retain only:

• Your verification status (verified/not verified)
• The date of verification
• Your legal name (as provided by you, for use in DMCA notices)
• Your contact email (as provided by you, for DMCA correspondence)
• The username of the admin who reviewed your request

This minimal data retention follows the GDPR principle of data minimization (Article 5(1)(c)) — we keep only what is strictly necessary for the service to function.

DMCA Takedown Records

When you use the automated DMCA takedown service, we store:

• The URL of the infringing content
• The domain and abuse contact email
• The generated DMCA notice text
• Delivery status and timestamps (sent, reminded, resolved)
• A unique reference number for each notice

This data is stored in your account and is accessible only to you and Protevio administrators. You may request complete deletion of your takedown history at any time.

Legal Basis (GDPR)

We process identity verification data under the following legal bases:

• Consent (Article 6(1)(a)): You explicitly consent to providing your selfie and ID for verification purposes
• Legitimate interest (Article 6(1)(f)): Preventing abuse of the DMCA system and ensuring only legitimate takedown requests are processed
• Legal obligation (Article 6(1)(c)): DMCA notices require identification of the complainant under 17 U.S.C. § 512(c)

Your Rights Regarding DMCA Data

• Access: Request a copy of all DMCA-related data associated with your account
• Deletion: Request deletion of your takedown history and verification status
• Rectification: Update your legal name or contact email used for DMCA notices
• Withdrawal of consent: Revoke your DMCA verification at any time (this will disable the automated takedown feature)

To exercise these rights, contact us at [DMCA ].

9. Your Privacy Rights

9.1 GDPR Rights (EU Residents)

• Right to Access: Obtain copies of your personal data
• Right to Rectification: Correct inaccurate data
• Right to Erasure: Request deletion ("right to be forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive data in machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Revoke consent at any time
• Right to Complain: Lodge complaint with supervisory authority

9.2 CCPA Rights (California Residents)

• Right to Know: What personal data we collect
• Right to Access: Obtain copy of your data
• Right to Delete: Request deletion of your data
• Right to Opt-Out: Opt out of sale (we don't sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices

9.3 Other U.S. State Rights

Residents of Virginia, Colorado, Connecticut, Utah, and other states with privacy laws have similar rights. Contact us to exercise them.

10. Right to be Forgotten (GDPR Article 17)

10.1 What Gets Deleted

• Account information (email, name, password)
• All uploaded photos
• Facial embeddings/templates
• Search history
• Usage data and logs
• Payment information (except legal retention requirements)

10.2 Deletion Timeline

1. Request Submission: Via Deletion Form or DMCA
2. Identity Verification: We verify your identity (1-2 business days)
3. Deletion Execution: Data deleted from active systems (7 days)
4. Backup Removal: Purged from backups (within 30 days)
5. Confirmation: Email confirmation when complete

10.3 Exceptions to Deletion

We may retain data if:

• Required by law (e.g., tax records, court orders)
• Needed to complete transactions you initiated
• Necessary to detect/prevent fraud or security incidents
• Part of ongoing legal proceedings
• Required to exercise/defend legal rights

11. Security Measures

11.1 Technical Safeguards

• Encryption in Transit: TLS 1.3 for all connections
• Encryption at Rest: AES-256 for stored data
• Database Security: Encrypted databases with access controls
• Network Security: Firewalls, intrusion detection, DDoS protection
• Secure Authentication: Bcrypt password hashing, 2FA available
• API Security: Rate limiting, API key rotation, OAuth 2.0

11.2 Organizational Safeguards

• Access Controls: Role-based access, principle of least privilege
• Employee Training: Regular security and privacy training
• Background Checks: For employees with data access
• Confidentiality Agreements: All staff sign NDAs
• Incident Response Plan: Documented procedures for breaches

11.3 Monitoring & Testing

• 24/7 security monitoring and logging
• Regular penetration testing (quarterly)
• Vulnerability scanning (continuous)
• Annual third-party security audits
• Bug bounty program for responsible disclosure

12. Data Breach Notification

12.1 Our Response Plan

In the event of a data breach affecting your personal data:

1. Detection & Containment (0-24h): Identify and stop the breach
2. Assessment (24-48h): Determine scope and affected data
3. Regulatory Notification (within 72h): Notify authorities as required by GDPR
4. User Notification (within 72h): Email all affected users
5. Remediation: Fix vulnerabilities, enhance security
6. Post-Incident Review: Analyze and improve processes

12.2 What We'll Tell You

Our notification will include:

• Nature of the breach
• Types of data affected
• Approximate number of affected users
• Likely consequences
• Measures we've taken to address it
• Recommended actions for you to take
• Contact information for questions

12.3 Your Action Steps

If notified of a breach:

• Change your Protevio password immediately
• Change passwords on other sites if you reused passwords
• Enable two-factor authentication
• Monitor your accounts for suspicious activity
• Consider credit monitoring if payment data was affected

13. International Data Transfers

Protevio operates globally. Your data may be transferred to and processed in countries outside your residence, including:

13.1 Transfer Mechanisms

• EU Standard Contractual Clauses (SCCs): For EU data transfers
• UK International Data Transfer Agreement (IDTA): For UK data
• Privacy Shield (where applicable): For US transfers
• Adequacy Decisions: EU-approved countries (e.g., UK, Switzerland)

13.2 Safeguards

For all international transfers, we ensure:

• Recipient country provides adequate protection
• Appropriate contractual obligations
• Technical safeguards (encryption, access controls)
• Your rights remain enforceable
• Effective legal remedies available

13.3 Data Processing Locations

Your data may be processed in:

• Primary: EU (Ireland, Germany), UK
• Secondary: United States (AWS/GCP data centers)
• Backups: Geographically distributed (encrypted)

14. Children's Privacy

14.1 COPPA Compliance (U.S.)

Under the Children's Online Privacy Protection Act (COPPA):

• We do not knowingly collect data from children under 13
• If we discover such collection, we delete it immediately
• Parents can request deletion of child's data

14.2 GDPR Compliance (EU)

Under GDPR:

• Services require age 18+ (16+ with parental consent in some jurisdictions)
• We verify age during registration
• Parental consent required for users under 18 (where applicable)

14.3 Protection of Minors in Index

We take special care with minors' images:

• Detection Systems: AI-based age estimation to identify minors
• Exclusion Policy: Images of apparent minors excluded from index
• Reporting: Users can report apparent minor images for immediate review
• Manual Review: Human reviewers verify and remove flagged content
• Proactive Monitoring: Regular audits of indexed content

15. Cookies & Tracking Technologies

15.1 Types of Cookies We Use

15.2 Third-Party Cookies

• Google Analytics: Site usage analysis — Opt-out
• Google Ads: Advertising — Manage settings
• Facebook Pixel: Ad conversion tracking — Opt-out

15.3 Cookie Management

You can control cookies through:

• Our Cookie Banner: Accept/reject on first visit
• Cookie Settings: Granular control in account settings
• Browser Settings: Block all cookies (may break functionality)
• Do Not Track: We honor DNT browser signals

16. User Control Dashboard

16.1 Available Controls

• Download Your Data: Export all data in JSON format (GDPR Article 20)
• Delete Search History: Remove individual searches or clear all
• Delete Uploaded Photos: Remove photos from our servers
• Manage Alerts: Edit or delete saved search alerts
• Privacy Settings: Cookie preferences, analytics opt-out
• Communication Preferences: Email notifications, marketing emails
• Account Deletion: Initiate full account deletion

16.2 Data Export Format

Your data export includes:

• Account information (JSON)
• Search history with timestamps
• Uploaded photos (original files)
• Settings and preferences
• Communication history

17. Transparency & Third-Party Audits

17.1 Transparency Report

We publish quarterly transparency reports showing:

• Law Enforcement Requests: Number received, complied with, rejected
• GDPR Requests: Access, deletion, portability requests received/fulfilled
• Data Breaches: Any incidents (with details on impact and response)
• Opt-Out Requests: Number processed
• Account Suspensions: Reasons and frequency

View Latest Transparency Report →

17.2 Security Audits & Certifications

Our security and privacy practices are independently verified:

• ISO 27001: Information security management (planned 2026)
• SOC 2 Type II: Security, availability, confidentiality (planned 2026)
• Annual Penetration Testing: By third-party security firms
• GDPR Compliance Audit: By privacy specialists

17.3 Bug Bounty Program

We run a responsible disclosure program:

• Scope: Security vulnerabilities, privacy issues
• Rewards: Up to €5,000 for critical findings
• Report: Bounty
• Hall of Fame: Public recognition (with permission)

18. Contact Information

18.1 General Privacy Inquiries

Email: Information
Response Time: Within 48 hours

18.2 Data Protection Officer

Email: DPO Officer
Role: GDPR compliance, privacy concerns, data subject requests

18.3 Exercise Your Rights

• Access Request: Data Access Form
• Deletion Request: Deletion Form
• Opt-Out Request: Opt-Out Form
• Complaint: File Complaint

18.4 Supervisory Authorities

EU residents can file complaints with:

• Your Country's DPA: Find Your DPA
• Lead Supervisory Authority: Irish Data Protection Commission (for EU operations)

18.5 Mail Address

Protevio AI
[Strada Tattarescu Gheorghe]
[Bucharest, 030413]
[Romania]

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect:

• Changes in our services or features
• New legal requirements
• Improved privacy practices
• User feedback

19.1 Notification of Changes

• Material Changes: Email notification + 30-day notice
• Minor Updates: Notice on website
• Version History: Available on request

19.2 Your Acceptance

Continued use of services after changes constitutes acceptance. If you don't agree, please stop using our services and delete your account.