Last updated: October 18, 2026
This Privacy Notice for PicVaultPro, a product of Open Key Technologies LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@picvaultpro.com.
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? If you opt in to AI-assisted features, we process biometric data (facial geometry embeddings) derived from your photos. This data is encrypted at rest using AES-256-GCM and is permanently deleted when you opt out, delete your account, or after 3 years of inactivity. This biometric data is the only sensitive personal information we process.
Do we collect any information from third parties? We receive limited information from third parties: your name and email address if you sign in with Google or Apple (Apple may give us a private relay address instead of your real email if you choose to hide it), and subscription status updates from Apple, Google Play and Stripe if you subscribe. We do not buy personal information from data brokers.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Information. If you opt in to AI-assisted features, we process biometric data (facial geometry embeddings), as described in the section on AI-assisted features below. We do not otherwise process sensitive personal information.
Contacts (optional). If you choose Import from Contacts on a person's card, PicVaultPro reads only the contact you pick, on your device, to fill that person's email and phone. On iOS you pick the contact in the system contact picker, which needs no permission. On Android the app asks for contacts permission when you tap Import. Only the fields you save are uploaded; your address book is never uploaded or stored.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice here: https://stripe.com/privacy. Purchases made in our iOS app are processed by Apple through In-App Purchase; Apple handles all payment information and we never receive your card details. Purchases made in our Android app are processed by Google through Google Play Billing; Google handles all payment information and we never receive your card details. To link an Android purchase to your account, the app passes your PicVaultPro account ID to Google Play, and our server confirms the purchase with Google and receives subscription status updates from Google. Stripe is used only for subscriptions purchased through our website.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.
Our AI Products
Our AI Products are designed for the following functions:
How We Process Your Data Using AI
All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.
Third-Party AI Providers
AI inference runs on PicVaultPro-controlled infrastructure operated by our hosting subprocessor Fly.io, Inc. (United States). Your photos are transmitted to this infrastructure for in-memory analysis only — they are not retained there after processing. PicVaultPro does not use any general-purpose third-party AI providers (such as Google Vision, Amazon Rekognition, OpenAI, or similar services) to process your photos, and your biometric data is never sold, shared with data brokers, or used for advertising. Your photos are never used to train AI for anyone else. Face matching learns only from your own photos and the ones shared with you.
Biometric Data Collection and Retention
If you opt in to AI-assisted features, we collect and store the following biometric data:
These are not images or photographs of faces. They are numerical vectors that cannot be reverse-engineered into images.
Security: All biometric embeddings are encrypted at rest using AES-256-GCM with a dedicated key held by PicVaultPro, not with your vault key. Unlike the contents of your photos and videos, embeddings are therefore technically readable by us. Row-level security additionally ensures that no other user can access them.
Retention schedule:
No third-party disclosure: Your biometric data is never sold, leased, traded, or otherwise disclosed to any third party for any purpose. All AI processing occurs on PicVaultPro-controlled infrastructure operated by our hosting subprocessor (Fly.io, Inc., United States); your photos are sent there only for in-memory analysis and are not retained after processing.
Your rights: You may revoke your biometric data consent at any time by disabling AI features in your Privacy Settings. Upon revocation, all biometric data is permanently and irreversibly destroyed.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
Encryption: Your photos and videos are encrypted with AES-256-GCM on your device, before they are uploaded. The key that protects them is derived from your encryption password, which we never receive. We do not keep an administrative or escrow copy of your encryption key, and we cannot decrypt your photos and videos — not for ourselves, and not in response to a legal demand.
Account recovery: When you set up encryption, your device generates a recovery phrase and shows it to you once. Your device uses that phrase to store a second, separately-wrapped copy of your key. The phrase itself is never transmitted to us; we store a one-way hash of part of it, used only to confirm you have entered the correct phrase. Recovery therefore depends on the phrase you kept. If you lose both your encryption password and your recovery phrase, we cannot restore access to your photos and videos, and they cannot be recovered by anyone.
What is not encrypted: PicVaultPro is not a strictly zero-knowledge system. While the contents of your photos and videos are encrypted, some information is necessarily handled in readable form so that the product can function, and this information is visible to us and can be produced under valid legal process: your file names; the capture time and the location (including coordinates, city, state and country) read from your photos' metadata; file type and size; and the vault, album, tag and people names that you create. If you use AI face grouping, image data is processed by our AI service in order to detect and match faces. Account information such as your email address, phone number and billing records is likewise readable.
Legal process: If we receive a valid and binding legal demand, we can produce the readable information described above, together with account and activity records. We cannot produce the decrypted contents of your photos and videos, because we do not hold the means to decrypt them. We may be compelled to hand over the encrypted files themselves, which are of no use without your key.
Safety and legal reporting: If we receive a credible abuse report or obtain actual knowledge of prohibited content, we may preserve relevant account records (including metadata and legal-hold records), investigate under documented controls, and report to applicable authorities where required by law.
In Short: We prohibit child sexual abuse material (CSAM), act on reports, and report apparent CSAM to NCMEC and law enforcement as required by federal law. We do not currently run automated scanning on uploads; we plan to add it.
Detection today: We do not currently run automated scanning on your uploads. Photo and video contents are encrypted on your device before upload, so we cannot view them. We rely on reports from users and others, and on content we become aware of. We plan to add automated detection of known CSAM that runs on your device before encryption. We will update this section before it starts.
Mandatory reporting: PicVaultPro is legally required under 18 U.S.C. § 2258A to report apparent CSAM to the NCMEC CyberTipline. Reports may include the flagged content, your account information (email, IP address), upload timestamps, and other metadata required by law. NCMEC may forward reports to law enforcement.
Account actions: Accounts found to contain CSAM are immediately and permanently terminated. Associated data is preserved for law enforcement as required by law.
Consent: By using PicVaultPro, you agree not to upload CSAM and acknowledge that we report apparent CSAM as described in this section.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@picvaultpro.com.
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
No mobile information will be sold or shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at support@picvaultpro.com.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
The categories of personal information we have collected in the past twelve (12) months include:
You have rights under certain US state data protection laws. These rights include:
pv_ad_consent=denied, which turns the Meta Pixel off on every marketing page in this browser for six months), use the request link below, email support@picvaultpro.com, or block cookies in your browser.To exercise these rights, you can contact us by submitting a data subject access request, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@picvaultpro.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
In Short: We use the following third-party service providers to operate our Services. Each processes personal data only as necessary for the stated purpose.
| Provider | Purpose | Data processed | Location |
|---|---|---|---|
| Supabase, Inc. | Database, authentication, file storage | Account data, media files, encrypted embeddings | United States |
| Vercel, Inc. | Web hosting and CDN | IP address, request metadata | United States |
| Stripe, Inc. | Payment processing | Payment information, billing address | United States |
| Fly.io, Inc. | AI inference server hosting | Image data (processed in-memory, not stored) | United States |
| Cloudflare, Inc. | Bot protection (Turnstile) | IP address, browser fingerprint | United States |
| Twilio, Inc. | SMS delivery for two-factor authentication | Phone number | United States |
| Resend, Inc. | Transactional email delivery | Email address | United States |
| Meta Platforms, Inc. | Advertising measurement (Meta Pixel), public marketing website only | Cookies, device/browser information, page views, sign-up button clicks (no account or vault data) | United States |
| Google LLC | OAuth social sign-in | Email, name (from Google profile) | United States |
| Apple Inc. | Sign in with Apple | Email (or private relay address) and name, as you choose to share them | United States |
| Google LLC | Google Play Billing (Android app purchases) | Purchase and subscription details, PicVaultPro account ID, purchase token | United States |
| Google LLC | Firebase Cloud Messaging (Android push notifications) | Device push token, notification title and text | United States |
| Apple Inc. | In-App Purchase (iOS app purchases) and Apple Push Notification service (iOS push notifications) | Purchase and subscription details; device push token, notification title and text | United States |
| GitHub, Inc. | Bug-report tracking (“Report a bug” in the web app) | Your account email, the report title and description you write, and the page you were on | United States |
| Functional Software, Inc. (Sentry) | Error reporting for the website and web app | Error messages, stack traces, request and browser/device details (passwords, cookies and authorization headers removed from server reports), performance traces, masked session replays | United States |
We enter into data processing agreements with subprocessors where the provider offers one. OpenStreetMap Nominatim is a public service run by the OpenStreetMap Foundation, not a subprocessor under contract with us: we send it photo GPS coordinates, and on the web your browser also sends it your IP address and browser information during upload, under the Foundation's own privacy policy. We will update this list when we add or change subprocessors, and will notify affected users where the change materially affects how their data is handled.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at support@picvaultpro.com or contact us by post at:
Open Key Technologies LLC (PicVaultPro)Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
To request to review, update, or delete your personal information, please fill out and submit a data subject access request.
In Short: Our Android and iOS apps handle your data the same way this notice describes for the web, including the limits on our encryption set out in section 7. This section does not grant or claim anything beyond what is stated elsewhere in this notice.
Data collected by the mobile apps. The apps collect the same categories described in section 1: your account details (email address, phone number for two-factor authentication, display name), the photos and videos you choose to upload, and app diagnostics such as error reports and performance events. The apps request access to your photo library so you can select media to upload, and they access only what you select. The iOS app can also use the camera to capture photos to upload; the Android app does not currently use the camera.
Encryption, and its limits. Photo and video contents are encrypted before upload and stored encrypted. As section 7 explains, PicVaultPro is not a strictly zero-knowledge system. Some information is necessarily handled in readable form so the product can work: file names, capture time and location taken from photo metadata, and the tags, people names, and album names you create. If you use AI face grouping, image data is processed by our AI service in order to detect and match faces. Please read section 7 in full — it, not this summary, governs.
Data sharing. We do not sell your personal information, and we never share your photos, vault contents, or account data with advertisers. The one exception to advertising-related sharing is the Meta Pixel on our public marketing website, which measures the performance of our ads and never runs inside the app or your vault (see section 3). The Android app uses Google Play Billing for purchases and Firebase Cloud Messaging for notifications; the iOS app uses Apple In-App Purchase and Apple Push Notification service. Neither app uses Sentry. Place names for photo locations are looked up with OpenStreetMap Nominatim as described in section 3. The service providers we use to operate the app are listed in section 13.
Deleting your account and data. You can delete your account and its contents from inside the app, or on the web, at any time — you do not need to contact us. Full instructions, including exactly what is removed, are published at picvaultpro.com/delete-account, which is reachable without signing in.
Google Play Data safety. The Data safety section on our Google Play listing describes the same collection, sharing, and deletion practices set out in this notice. Where the two are ever read differently, this Privacy Policy is the authoritative statement of what we do.
This Privacy Policy was created using Termly's Privacy Policy Generator
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.