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Security & Trust

BUILT TO BE READ
BY YOUR LEGAL TEAM.

Event photos and face data are sensitive personal data. This page describes, plainly, how TIME&SPACE handles them: what we collect, where it lives, when it is deleted, and what paperwork we can put on the record for you.

Consent before any face search

Face search is opt-in and never runs without a consent record for that event. Every way into a face search, on the web and in the mobile app, asks for it with a dedicated, unticked consent box that the guest has to tick. Every consent is logged with its time; web consents also record the version of the wording shown. Declining changes nothing about the event.

EU data residency

Photos, selfies and face data are stored and processed in the European Union: database and storage in Ireland (AWS eu-west-1), face-recognition service in the Netherlands.

Deletion on a schedule

Guest selfies are deleted within 30 days. The face index of event photos expires after one year at most, earlier if the event or photo is deleted. A deleted event’s photos are permanently deleted 30 days later. The schedule is published in our privacy policy and terms.

Paperwork for your legal team

A data processing agreement with GDPR Art. 28 terms and our sub-processor register are available on request, along with the wording of our guest consent screen.

Biometric data

HOW FACE SEARCH HANDLES PERSONAL DATA.

  • •Consent is collected in-product, before camera access, and checked against the event being searched. Every entry point uses an explicit unticked checkbox: the event page’s “Find my photos” button, the registration link, roster invitations, the organiser-wide search and the mobile app. A consent recorded under the older notice wording is kept as history but can no longer start a search. Web consent records are versioned by the wording shown and logged (timestamp, hashed IP, withdrawal state). At events with children under 16, a parent or legal guardian consents for their child, and the photos go only to the parent's verified email.
  • •Consent is never a condition of attending an event. Guests who decline can browse public galleries like anyone else.
  • •Face embeddings are used only to match a consenting guest's selfie against the photos of the event being searched. They are never used to train models and never shared or sold.
  • •No account is needed for deletion. Guests can delete their selfie and face data from their results page, which takes effect immediately, or by requesting it from the event page, confirmed by email.
  • •Photos an organiser marks private are excluded from face search itself, not only hidden from results.
  • •A performer or speaker added to an event roster is only matched after they accept the invitation and give their own consent; a photo uploaded by the organiser is never used for matching on its own.
  • •Retention is fixed and published: selfies within 30 days; guest search templates within 30 days; the photo face index no later than 1 year from upload.

Application security

THE CONTROLS AROUND THE DATA.

  • •All traffic is encrypted in transit (TLS). Photo storage is private by default; photos are served through signed, time-limited URLs only.
  • •Role-based access for event teams (owner, team member, photographer, VIP) with per-event scoping. Administrative access is limited to named individual accounts, and administrator actions taken through the admin interface (user accounts, password resets, events, data-protection requests, payouts, imports and data ingests) are logged with who, what and when; audit coverage of the CRM is still being extended.
  • •A web application firewall and per-endpoint rate limiting protect guest-facing routes, including the scan and search endpoints.
  • •Secrets are kept in platform secret stores and referenced by name. Error monitoring runs in an EU region, with access tokens and email addresses removed from reported URLs.
  • •Rate-limit counters store a keyed hash of the IP address, never the address itself.
  • •Payments are processed by Stripe; card data never touches TIME&SPACE systems.

Sub-processors

WHO ELSE TOUCHES THE DATA, AND WHERE.

These providers process personal data to deliver the service. Biometric data (photos, selfies, face embeddings) is stored and processed in the EU. Consent-gated analytics (Google Analytics, Meta, Microsoft Clarity) are not part of delivering an organiser’s event. Google Analytics and the Meta pixel load in a denied state and send nothing until a visitor grants cookie consent; Microsoft Clarity loads only on public marketing and public profile pages after analytics consent, never on guest pages or inside the dashboard.

ProviderPurposeLocation
SupabaseDatabase, photo storage, authenticationEU (Ireland, AWS eu-west-1)
RailwayFace-recognition processingEU (Netherlands)
VercelWeb hosting and computeEU deployment region; global edge
CloudflareDNS, CDN, firewallGlobal edge
StripePaymentsEU / US
ResendTransactional emailSent from the EU (Ireland); account data, metadata and logs in the US (SCCs)
SentryError monitoringEU region
UpstashRate limiting (hashed IP keys)EU (Ireland, eu-west-1)
ExpoPush notifications (consumer app)US (Data Privacy Framework)
Google / AppleOptional sign-in; organiser-initiated Drive importEU / US
DropboxOrganiser-initiated photo importUS (SCCs / DPF)
AnthropicClassifying public event listings; drafting replies to messages sent to our Instagram account. Never photos or face dataUS (SCCs)
Google (Firebase)Archive of photos from the retired first-generation TIME&SPACE appGoogle Cloud (location being confirmed)
Google WorkspaceCompany email and calendarEU/US

Compliance posture

WHAT WE CLAIM, AND WHAT WE DON'T.

TIME&SPACE processes biometric data under GDPR Art. 9 on the basis of each guest’s explicit consent, and treats its face-matching system as high-risk AI under the EU AI Act (Annex III), with a documented risk-management, transparency and human-oversight programme. Our lead supervisory authority is the CNPD (Portugal).

We describe capabilities, not guarantees: you are the controller of your event photos, roster and team data, and we are your processor under our data processing agreement. For guest photo search (consent, selfies, face data, guest emails) TIME&SPACE is an independent controller. We do not currently hold SOC 2 or ISO 27001 certification; our controls are documented and available for review instead.

Full details: Privacy Policy and Terms of Service.

NEED THE DPA, OR FOUND
SOMETHING WE SHOULD KNOW?

Request our data processing agreement and sub-processor register, ask a security question, or report a vulnerability. We read everything.

legal@timeandspace.earth