1. Introduction and Scope
This Privacy Policy applies to the Roll mobile application and website operated by Roll ("the Company", "we", "Data Controller"). It explains how personal data shared by, or obtained from, users, film hosts and guests ("Data Subject") is processed.
In Roll, photos are taken by the guests attending an event. A single user can therefore be both the owner of their own data and the producer of content containing other people's images. This document covers both situations.
2. What Data We Process
The following categories of personal data are processed under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK") and the EU General Data Protection Regulation ("GDPR"):
- Identity and Contact: Display name, email address, phone number (depending on your sign-in method).
- User and Transaction Data: User ID, the films you join, the number of shots you take, dates and times of service use, error logs, purchase and billing information.
- Transaction Security: Session data, device identifiers, IP address.
- Face Recognition Data (special category — biometric): Mathematical identifiers derived from facial features captured during the face scan, and the positions of faces within photos. Raw scan images are not retained.
- User Content: Film details (name, cover image, date), the photos taken and their metadata (who took them, when).
- Notification Data: Notification permission and device push token.
- Usage Analytics: First-party product-usage events collected on our own systems — the screens you view and key actions you take (such as joining a film, taking a photo or making a purchase), together with your device platform and app version. This is used to understand and improve the service; it is first-party only and is not shared with third-party advertising networks. You may ask us to stop processing it by contacting us at hello@uroll.app.
Location data is not processed. Location metadata is stripped from photos as they are uploaded from your device.
3. Purposes of Processing
- Service Delivery: Creating your account, joining films, enforcing the per-person shot quota, sharing photos at the reveal moment.
- Face Matching: Automatically delivering the photos you appear in. This depends solely on your explicit consent; if you withhold it you still see the whole film.
- Security and Abuse Prevention: Account security, assessment of content reports.
- Service Improvement: Error detection, performance measurement, and first-party usage analytics (which features are used and how) to improve the product. You may ask us to stop processing your usage analytics by contacting us at hello@uroll.app.
- Legal Obligations: Requests from competent authorities, dispute handling, regulatory compliance.
4. Legal Basis (KVKK art. 5–6 | GDPR art. 6, art. 9)
Identity, usage and content data are processed on the basis of the conclusion and performance of a contract, legal obligation, and legitimate interest.
Face recognition data is special-category personal data and is processed only with your explicit consent. Withholding or withdrawing that consent does not prevent you from using the rest of the service.
5. Sharing With Third Parties
- Technology Infrastructure: Amazon Web Services (Amazon S3 and Amazon Rekognition, Frankfurt / eu-central-1 region) for photo storage and face matching; Supabase for authentication and database.
- Payments: In-app purchases are handled through the Apple App Store and Google Play; Roll never sees or stores card data.
- Messaging/Notifications: The relevant service providers for sign-in verification and push delivery.
- Public Authorities: In line with court orders and lawful requests.
Your photos and face data are never sold or rented to third parties for advertising or profiling.
6. Visibility Within a Film
When you join a film, the photos you take become visible to the other participants of that film from the reveal moment onwards. If the film host turns off "Everyone sees all photos", only the shots you took and the photos delivered to you are visible to you.
You may request deletion of a photo containing your image; the request is passed to the user who took it and to the film host, and is assessed by us.
7. Retention Periods
- Face identifiers: Kept only while your face match is switched on. There is no fixed retention period: you can delete your face data at any time from Settings → Face Match, and it is also deleted when you delete your account. Deletion is actioned immediately and removes every match record.
- Photos: 90 days after a film closes, then deleted automatically. Copies you downloaded to your device remain yours.
- Explicit consent records: At least 1 year, due to the burden of proof.
- Account data: For as long as the account is active; deleted when you delete your account, subject to statutory retention obligations.
- Log and traffic data: 1 year, as required by legislation.
8. Security Measures
Data is encrypted in transit. Photos are held in storage that is closed to the public and served only through time-limited, signed links. Application clients cannot access face identifiers; that data is processed server-side only.
9. Specific Provisions on Face Recognition
- Face scanning is collected only through the three-pose enrolment flow that you start yourself; raw scan frames are not retained after processing.
- Matching delivers only at 90% similarity or above; results below that threshold are discarded without ever being shown to you.
- Film hosts and other users cannot access your face data; they only see the outcome of a match (that a photo was delivered to you).
- When you delete your face data, your identifiers and all match records are irreversibly deleted. Photos already delivered to you remain yours.
10. International Transfers
Photos and face identifiers are processed on Amazon Web Services infrastructure in the Frankfurt (Germany) region in order to provide the service. This transfer relies on your explicit consent.
11. Your Rights (KVKK art. 11 | GDPR art. 12–22)
- Requesting information and access to your data
- Rectification and updating
- Erasure / right to be forgotten, and restriction of processing
- Objection
- Data portability
- Withdrawal of explicit consent at any time
12. How to Exercise Your Rights
Email hello@uroll.app to exercise your rights. Requests are concluded within 30 days at the latest.
13. Children
Roll is not directed at people under 13. The face recognition feature is disabled for users under 18.
14. Changes
This Policy may be updated from time to time. You will be informed in the app of material changes, and your consent will be collected again where required.
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Data Controller: FindPhoto LLC (operating Roll) Address: Barbaros Mah. Şebboy Sk. No: 4/1, Apt. 2, Ataşehir, İstanbul, Türkiye Phone: +90 (850) 346 54 38 Email: hello@uroll.app