Creator terms

Version: ct-2026-09-v1

These terms apply when you host events on FindMyPhoto for creators. Section 5 is the data processing agreement for your events.

1. Parties, beta status and acceptance

These terms are an agreement between you, the creator (the photographer, organiser, venue, club, school or other organisation that creates events on creator.findmyphoto.app), and S-Industry, trade name of Sem van Embden, Rotterdam, the Netherlands, Chamber of Commerce (KvK) number 94484124 ("FindMyPhoto", "we").
You use the creator features for your business, profession or organisation, and you are at least 18. If you accept for an organisation, you confirm that you may bind it.
FindMyPhoto for creators is an invite-only private beta (section 3).
You accept these terms when you redeem your invite and tick the acceptance box during onboarding. We record the version above and the date. Our Terms of Service and Privacy Policy still apply to your FindMyPhoto account; for the creator features, these terms take precedence.

2. The service

You create events (name, date, a retention period of 1, 3 or 12 months, and settings), upload photos from your computer or import them from a supported album link, and share the event's link, its code of 6 to 8 characters and its QR code. The retention period counts from the day you set up the event, or from the event date if you set the event up in advance, so that photos never go offline before the event has taken place; the event date can lie up to a year in the past. You can extend the retention period by up to 12 months at a time, to an end date at most 12 months after the day you extend it, and never beyond 24 months after the day it started counting (the set-up day, or the event date for an event set up in advance); we then tell every guest still in the event the new end date.
Guests find their photos with a selfie, on the web or in the app, as described in the Events Privacy Addendum. By default the General tab is on, so every guest who joins sees all the event's photos (and anyone who has the link or code can join), and originals are downloadable. You can switch the General tab off, and choose whether guests can download originals, only copies watermarked with your logo, or nothing (view only).
Open gallery. For each event you can also switch on "Anyone with the link can see all photos". It is off by default, can only be on while the General tab is on, and works on the website only. Anyone with the event link or QR code can then browse all photos of the General tab, and download them as your download setting allows, without a selfie, an email address or an account; the selfie search stays available next to it. The open gallery works while the event is open or closed, never for an archived, deleted or expired event. When you switch it off, new visitors are refused at once, and access already given ends within an hour. We show the photos on your instruction, as your processor (section 5.2); the decision to open the gallery, and the legal basis for it, are yours (section 4).
We email your guests about your event from photos@findmyphoto.app, naming you as the host and, if you set one, with your reply-to address. You get an email when an event goes live, when an import has finished, and 30, 7 and 1 days before an event's photos are deleted.
Your @handle. During onboarding you choose a public handle of 3 to 30 characters: lowercase letters, digits and hyphens, starting and ending with a letter or digit. It is unique: once it is yours, nobody else can use it. Guests see it next to your display name, as "Hosted by {display name} (@handle)", on the event page, in the consent text and in emails, so that they can tell who hosts the event. These handles are reserved and cannot be chosen: findmyphoto, fmp, admin, support, help, official, team, staff, security, legal, privacy, api, www, cdn, mail, news, event, events, creator, creators, app, login, account, g, e, c and test. Your handle and display name must not impersonate another person, brand or organisation or mislead guests; we may refuse or change a handle that does, after telling you. During the beta, handle changes go through support. When you delete your creator account, your handle is released, and another creator can then choose it; there is no waiting period.
Beta limits: 3 open events at a time; per event 2,000 photos, 500 guests and 20 GB; 50 MB per photo; and at most 24 rounds per event per day in which new photos are searched for keep-me-posted guests.
Face matching is not perfect. It can miss photos of a guest and, rarely, show a guest a photo of someone who looks like them; the threshold is strict to keep that rare. Do not rely on it to identify people or for security.

3. Beta terms

Free. The creator features cost nothing during the beta. We tell you at least 30 days before we introduce prices, and events that are running at that moment keep their terms until their retention period ends.
Things may change. Features, limits and the supported album services may change during the beta. Where we can, we tell you in advance about a change that limits what you can do with a running event.
No service levels. There is no guaranteed availability, response time or support hours. We fix problems as fast as we reasonably can.
Feedback. Ideas and bug reports are welcome. We may use your feedback freely, without any obligation to you.
End of the beta. We may end the beta, or your place in it, with 30 days' notice, so that you can download your photos and consent exports first.

4. Acceptable use and your warranties

You confirm, and you remain responsible for it, that:

Rights to the photos. You own the photos or have every right and permission needed (copyright, and where needed the consent of the people in them) to upload or import them, to have them processed as these terms describe, including the face index, and to share them with guests in the way your event settings allow.
Lawful basis. You have a lawful basis under the GDPR for taking and sharing the photos and for having the faces in them indexed for the selfie search, and you meet your other obligations as controller, including a data protection impact assessment where one is required.
Attendees are told in advance. Before and during the event you tell attendees that photos are taken and delivered through FindMyPhoto, that the faces in them are indexed so that guests can find their own photos with a selfie, how long the photos stay online, and how to object or ask for removal. Use our privacy outline or equivalent text in your privacy policy, ticket terms or invitation, and put up a notice at the venue.
Children. You do not host events that are mainly for, or mainly attended by, children under 16, unless you have the consent of their parents or guardians for the photos and the face index, and you act promptly on requests from parents and guardians.
No sensitive events. You do not use FindMyPhoto for events where being present reveals someone's health, religion or beliefs, political opinions, trade union membership, sex life or sexual orientation, or ethnic origin, or in places where people reasonably expect not to be photographed, such as care settings, changing rooms or support groups.
Open gallery. If you open the gallery of an event, you have a lawful basis to show all its photos to anyone who has the link, and you tell attendees before and at the event that anyone with the link will be able to see the photos (our privacy outline has an optional paragraph for this). You keep the open gallery off where it is not appropriate: for events that are mainly for or about children under 16, when attendees would not expect people outside the event to see the photos, and wherever being seen there could harm someone. When a parent or guardian asks you to hide a photo of their child, you hide it as soon as they ask; when anyone else in the photos asks, you hide the photos concerned or switch the open gallery off, without undue delay.
No re-identification. You use the face index, the matches, the guest list and the consent register only to let each guest find their own photos and to run your event. You do not try to identify, track or profile anyone, to find out who a pseudonymous guest is, or to combine this data with other data, and you never sign up with a selfie of anyone but yourself.
Accurate identity. Your display name, @handle, email address and reply-to address are accurate and do not mislead guests about who hosts the event. Your own privacy notice names you as the controller, with your contact details.
Lawful content. You do not upload unlawful or infringing content, sexual or intimate images, or photos that expose people in a harmful or humiliating way.
Requests. You answer requests from guests and from people in your photos that we pass on to you within the legal deadline (one month), and you act quickly on removal requests, hiding the photo while you assess the request. You instruct us to hide a photo from guests if you have not responded within 7 days to a removal request about it that we passed on to you.
Imports. You import only albums that you own or are authorised to import.
Your account. You keep your login details safe, do not share your account, and tell us straight away about any unauthorised use.
No abuse. You do not overload, probe, reverse-engineer or work around the limits or protections of the service, and you do not resell access to it.

Confirmation for each event. When you create an event, you confirm with a checkbox that you have the right to upload and share its photos, that attendees are informed with the privacy outline or equivalent text, and that the event is not mainly for children under 16. We record your confirmation with the event, together with the version of these terms.

Claims by others. You are responsible for claims by third parties, including people in your photos, that result from a breach of these warranties, and you compensate us for our reasonable costs of such claims, as far as the law allows.

We may hide photos, switch off an event's open gallery, or suspend an event or your creator access, if these rules are broken (section 9).

5. Data processing agreement (Article 28 GDPR)

This section is the data processing agreement between you, as controller, and FindMyPhoto, as processor, for the personal data of your events. Where it conflicts with the rest of these terms, this section prevails for that data.

5.1 Subject, duration, nature and purpose. We host your event photos and deliver them to your guests and, if you open the gallery, to anyone with the event link: we make display versions, index the faces in the photos, run the selfie search that guests consent to, send guests emails and notifications, keep the consent register and produce exports. This lasts, for each event, until its data is deleted (section 5.10). The personal data: event photos (images of attendees, staff and anyone else in them, which can include children); face vectors of every face in the photos (biometric data, a special category of personal data); and guests' email addresses, selfies, choices, match results and consent records, with technical data about their use. The people concerned: everyone who appears in your event photos, and the guests who join your event.
5.2 Instructions. We process your event data only on your documented instructions. These are: these terms; your settings and actions in the creator portal (for example uploads, imports, hiding and deleting photos, the retention period and extensions, the General tab, the open gallery, downloads and exports); the instruction in section 4 about unanswered removal requests; delivering each guest's photos to the FindMyPhoto account or app the guest uses, by linking their participation to that account when they sign in with the same verified email address, open an event link in the app, or sign in for the first time on a phone where they joined as a guest; and written instructions to support that fit these terms. If the law requires us to process the data otherwise, we tell you first, unless the law forbids that. If we believe an instruction breaks the GDPR, we tell you and may decline to follow it.
5.3 Confidentiality. Everyone on our side who can access your event data is bound by confidentiality, and has access only as far as needed for support, security and running the service.
5.4 Security. We apply the measures in section 10 of the Events Privacy Addendum and keep them at least at that level, taking into account the state of the art and the risks of processing biometric data.
5.5 Subprocessors. You give us general authorisation to use the subprocessors listed in section 7 of the Events Privacy Addendum (the rows marked Subprocessor). We tell you at least 30 days before we add or replace one, by email to your account address. You may object on reasonable data protection grounds within that period; if we cannot address your objection, you may end these terms and delete your events. Each subprocessor is bound by data protection obligations equivalent to these, and we remain responsible to you for them.
5.6 Location and transfers. We store and process your event data in the EU (Stockholm and Ireland). Where a subprocessor can access it from outside the EU, the transfer is covered by an adequacy decision (such as the EU-US Data Privacy Framework) or by standard contractual clauses.
5.7 Requests from the people concerned. Guests can leave an event, delete their selfie and matches, change their choice and unsubscribe themselves; in the creator portal you can remove a guest and export the consent register. We pass requests about your event that reach us on to you within 2 business days, do not answer them on the merits unless you ask us to, and help you answer within the legal deadline.
5.8 Your other obligations. On request we give you the information you need for your records, for a data protection impact assessment and for any prior consultation of a supervisory authority: a description of the processing, the security measures and the subprocessors.
5.9 Personal data breaches. We notify you without undue delay, and at the latest within 48 hours after we become aware of a breach affecting your event data, so that you can meet your own 72-hour deadline. We tell you what we know about the nature of the breach, the data and people concerned, the likely consequences and the measures taken, and we keep you updated.
5.10 Deletion at the end. At the end of each event's retention period and when you delete an event, we delete the event data as described in section 6 of the Events Privacy Addendum: within 7 days, with database backups rolling off within 35 days. When these terms end, the same deletion happens within 7 days after the download period of section 9 has passed. Until then you can download your photos and the consent register. You instruct us to keep the consent records as proof of consent, for you and for us, until 5 years after the event's data is deleted: their email hashes are overwritten and only the random participant reference stays, which nothing in our systems links to the guest once their participation is erased.
5.11 Information and audits. We make available the information needed to show that we meet this section. You may audit our compliance once a year, with 30 days' notice and at your own cost, first through a written questionnaire and our documentation; an on-site audit is possible only if the documents are not enough or a supervisory authority requires it. For Amazon Web Services we rely on its independent audit reports.
5.12 No other use. We do not use your event data for our own purposes, except to keep the service secure, to prevent abuse, to keep anonymous totals (such as the number of photos processed), to keep the consent records as proof (section 5.10), and to show a guest's photos in the FindMyPhoto account or app they use (section 5.2). We never use it to train AI models, for advertising, or to contact guests about anything other than your event.

6. Guest consent, the register and exports

We ask every guest for explicit consent on your behalf, before their selfie is used, with the published and versioned consent text (currently ec-2026-09-v1, in English and Dutch). You cannot change that text; a change is published as a new version.
For every consent, change of choice and withdrawal we record: a pseudonymous reference and a keyed hash of the guest's email address, the time (UTC), the version and the sha256 fingerprint of the published consent text in the guest's language, the language, the choice (once or keep me posted), the action, the channel (app or website) and the app or website version. We do not record IP addresses or browser details.
You can export the register of each event as a CSV file from its Guests tab. It is pseudonymous: it holds a reference, not the guest's email address.
No full guest list. You see your guests' email addresses only partly hidden, and the export holds a pseudonymous reference instead of the address. Showing you the full addresses (the participant list) would need a consent text that tells guests so before they sign up; the current one (ec-2026-09-v1) does not, so the participant list cannot be switched on.
When a guest withdraws or leaves, the search stops at once and their selfie, matches and email address are deleted; the register keeps the entry as proof, with the email hash overwritten (section 5.10).
Guest consent covers the selfie search only. Everything else, including taking and sharing the photos and having them indexed, rests on your own legal basis (section 4).

7. Intellectual property and licence

You keep all rights to your photos, your logo and your event content. You give us a non-exclusive, royalty-free licence to store, copy and convert them (including the smaller versions, the watermarked copies and the face index), and to show and deliver them to your guests, to you and, if you open the gallery, to anyone with the event link, as your event settings allow, for as long as the event's data is kept and only to provide the service. We may show your display name, @handle and logo on your event pages and in emails about your events.
You decide whether guests may download photos. Any licence for guests to use downloaded photos is between you and your guests.
FindMyPhoto, its software and its brand stay ours. You get the right to use the service under these terms, nothing more.

8. Availability and liability

During the beta the service is provided "as is". We do our best to keep it running, but we do not promise that it is always available, that every photo of every guest is found, or that it fits a particular purpose.
Keep your own copies. FindMyPhoto is not a backup, and photos are deleted automatically at the end of the retention period.
As far as the law allows, our total liability to you for all claims connected with the beta, including under section 5, is limited to EUR 100; after the beta, to the fees you paid in the 12 months before the claim. We are not liable for indirect or consequential loss, such as lost profit, lost photos or missed matches.
These limits do not apply to damage caused by our intent or deliberate recklessness, or where the law does not allow a limitation. Nothing in these terms limits the rights of guests and other people under Article 82 GDPR; between the two of us, each bears the part of such damage that its own conduct caused.
We are not responsible for failures caused by events beyond our reasonable control, including outages of third-party services we depend on.

9. Suspension, termination and deletion

You can close, archive or delete any of your events at any time. Deleting an event deletes its photos, face index, guest data and matches (section 5.10).
You can end these terms at any time by deleting your creator account: in the app under Settings → Delete Account, or on the account page of the website. This deletes all your events, your creator profile, your handle and your invites, and then your FindMyPhoto account.
We may hide photos, switch off an event's open gallery, or suspend an event or your creator access, straight away if we receive a credible report of unlawful content, if we are legally required to act, if you break section 4, or to stop a security risk. We tell you why, unless the law forbids it, and you can respond.
We may end these terms with 30 days' notice, or straight away if you seriously break them.
When these terms end, your events close. Unless they ended because of a serious breach, or you ended them by deleting your account, you then have 30 days to download your photos and consent exports; after that the data is deleted as described in section 5.10.
Sections 5 (until the data is deleted), 7, 8 and 10 continue to apply after the end.

10. Changes, law and courts

We may change these terms. We tell you about important changes by email at least 30 days before they apply; changes that the law requires can apply sooner. If you do not agree, you can end these terms before the change applies.
These terms are governed by Dutch law. The United Nations Convention on Contracts for the International Sale of Goods does not apply. Disputes go to the competent court in Rotterdam.
These terms are written in English; if we provide a translation, the English text prevails.

11. Contact

FindMyPhoto: S-Industry, trade name of Sem van Embden, Goudse Rijweg 497, 3031 CG Rotterdam, Netherlands; Chamber of Commerce (KvK) number 94484124; support@findmyphoto.app. For the data processing agreement and for breach reports, use the same address with "DPA" in the subject line.
Notices to you go to the email address of your creator account.