Privacy Policy

Effective date: June 25, 2026

1. Overview

MemoSnap ("we", "our", "the Service") is committed to protecting your personal information in accordance with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173). This policy explains what we collect, why we collect it, and how it is used and protected.

2. Information We Collect

When you use MemoSnap as an event guest, we collect:

• Name — the name you enter before uploading photos
• Selfie photo — an optional photo of your face, used to identify your uploads in the gallery
• IP address — your internet connection's address, recorded at the time of consent and each upload
• Device and browser information — your device model, operating system, browser type (User-Agent string), screen resolution, timezone, language, CPU cores, device memory, and touch capability
• Device fingerprint — a unique identifier derived from how your device renders graphics (canvas fingerprint), used to identify your device in the event of a content violation
• Photos you upload — images captured and submitted through the camera interface
• Consent timestamp — the date and time you agreed to these terms

When you book or inquire as an event organizer, we also collect your name, phone number, and email address.

3. Legal Basis for Collection

We collect personal data on the basis of your explicit consent, given when you check the agreement box on the camera page. We collect device and network data on the basis of our legitimate interest in maintaining the safety and integrity of the platform.

4. Selfie and Biometric Data

Your selfie is classified as biometric data under RA 10173. It is collected solely to help you and the event organizer identify your photos in the gallery. It is stored securely, linked only to your anonymous session ID, and is not shared with third parties, used for facial recognition beyond the stated purpose, or transferred outside of Cloudflare's infrastructure.

5. How We Use Your Information

• To tag and organize your photos within the event gallery
• To identify you in the event of a content violation or legal inquiry
• To respond to law enforcement requests where legally required
• To contact you regarding your booking or event (organizers only)

6. Data Sharing

We do not sell, rent, or share your personal data with third parties for marketing purposes. We may disclose your information to:

• The event organizer — who can view the guest gallery and associated names
• Law enforcement or government authorities — if required by law or in response to a valid legal process
• Cloudflare, Inc. — our infrastructure provider, under their data processing agreement

7. Data Retention

• Guest photos are retained for a minimum of 6 months from the event date. Where server capacity allows, galleries may remain accessible for up to 12 months at no additional charge, after which all photos are permanently deleted
• Selfie photos are retained for the same period as the event gallery
• Consent records (name, IP, device info, timestamp) are retained for 3 years for legal accountability purposes
• Organizer contact details are retained for the duration of the business relationship

8. Data Security

All data is stored on Cloudflare's infrastructure (R2 object storage and KV store), protected by Cloudflare's enterprise-grade security. Access to raw data is restricted to authorized administrators only. Data is transmitted over HTTPS.

9. Your Rights Under RA 10173

As a data subject under Philippine law, you have the right to:

• Be informed — know what data we collect and why
• Access — request a copy of your personal data we hold
• Correction — request correction of inaccurate data
• Erasure — request deletion of your data, subject to legal retention requirements
• Object — object to processing of your data in certain circumstances
• Lodge a complaint — file a complaint with the National Privacy Commission (NPC)

To exercise any of these rights, contact us at hello@memosnap.cc.

10. Cookies and Local Storage

MemoSnap uses browser local storage (not cookies) to remember your name and session ID on your device for the duration of your use of the event gallery. No tracking across other websites occurs.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page reflects the most recent revision. Continued use of the Service constitutes acceptance of the updated policy. Changes do not apply retroactively to data already collected under prior versions of this policy.

12. Data Protection Officer

In compliance with RA 10173, MemoSnap has designated a Data Protection Officer responsible for ensuring the lawful and secure processing of personal data. For privacy-related concerns or to exercise your rights, contact:

Data Protection Officer — MemoSnap
Email: hello@memosnap.cc