Biometric Data Policy

Part 1. Biometric Data Policy

Kiniage is a software product owned and operated by Metro Point Technology LLC, 4021 NE 8th Pl, Cape Coral, FL 33909. This policy explains the Name the faces feature (technically "face grouping", the name used in the consent members sign before turning it on) and the biometric data it creates. It is part of our Privacy Policy and Terms of Service.

What Name the faces does

When a user turns Name the faces (face grouping) on, our software finds each face in the photos that user uploads and turns it into a face template: a set of numbers describing the face's geometry. Templates that match are grouped, so the user can name a person once instead of tagging every photo. Kiniage does not know who anyone is until a user names a group. Laws in some places call a face template a biometric identifier or biometric information ("biometric data").

Off by default, and not available everywhere

Name the faces (face grouping) is OFF for every account until the account holder reads this policy and signs the separate consent. It is not offered to residents of Illinois, Texas or Washington; there, people are tagged by hand and no face templates are created. We determine residence from the state the user tells us and from their connection's location, and if either points to Illinois, Texas or Washington the feature stays unavailable.

Why we use it

Only to group and label faces within the user's own family archive, for that user and the family members they share with. We do not use biometric data for identification outside the family archive, for advertising, for training any AI model, or for any other purpose.

Automatic tagging, if a user turns it on, uses the same face data, only to suggest and tag people that user has already named; nothing new is collected.

No sale, no sharing

We do not sell, lease, trade or otherwise profit from biometric data. We do not disclose it to anyone outside Metro Point Technology unless the person it describes (or their legal representative) consents, or the law, a valid warrant or subpoena requires it. Face templates are created on a server that Kiniage rents and runs itself, and are stored in Kiniage's database, which our database provider (Supabase) hosts for us under contract. Both are in the United States. Face templates are never sent to an AI provider or any outside face-recognition service.

How long we keep it and when we destroy it

We permanently destroy a user's face templates at the earliest of: (a) when the user switches Name the faces (face grouping) off; (b) when the user deletes their account; (c) when the photo a template came from is deleted (for that template); (d) 12 months after the user's last sign-in; or (e) when a person asks us to remove their face under the next section. Destruction happens within 30 days of the triggering event, including backups. We never keep biometric data longer than the law allows, and in no case longer than 3 years after the user's last interaction with Kiniage.

Anyone can ask to be removed

Anyone who appears in a Kiniage photo, whether or not they have an account, can ask us to delete the face templates of them and to stop their face from being named or grouped with a named person in that family again. Email Support@kiniage.com with the subject line "Kiniage face removal". We act within 30 days and keep only what is needed to honor the request.

How we protect it

We store, transmit and protect biometric data using a reasonable standard of care, and in a way that is the same as or more protective than how we protect other confidential and sensitive information: encrypted in transit and at rest, with access limited to the systems that run Name the faces (face grouping).

Changes

If we change this policy materially, Name the faces (face grouping) stays paused for each user until they read the new version and consent again.

When a user dies

If Passing on a shoebox is turned on and a user dies and their account becomes a memorial, we delete the face templates created from that user's own photos. Faces of that person in other users' photos are covered by those users' consent. A Keeper or the person's executor may ask us to delete face data about the person from all family photos, and we will.