Privacy Policy

1. What we collect

• The photograph you upload, and the files derived from it (the watermarked preview and the finished photo — and, for a document whose online portal requires JPEG 2000, a .jp2 copy of that finished photo).
• Measurements taken from the photograph in order to lay it out: the position of the top of the head and the chin, the outline of the person, and the average colour and variation of the background.
• Minimal job metadata: which specification you chose, the interface language the page was shown in, timestamps, the results of the automated checks, and a random job identifier.
• If you buy: the sale identifier and the email address Gumroad reports for the purchase, so we can honour the download and handle refunds. We never receive your card details.
• Ordinary server logs (IP address, request time, user agent) kept for security and debugging.
• Anonymous usage counters — when a photo is checked, when a purchase button is clicked, and when a photo is bought, refunded or downloaded, we append one line to a log on our own server recording the document type, the interface language the page was shown in, the outcome of the check (which rules passed, warned or failed), how long processing took, three numbers describing the background behind you (its average brightness, how uneven it is, and how strongly it is tinted) together with which of them fell outside the required range and by how much, and — when the framing check fails — three measurements expressed as percentages: how far outside your picture the required crop fell, which edge it fell outside, and how large the head is compared with the official target. These lines contain no photograph, no IP address, no browser or device information, no email address and no job identifier, so they cannot be traced back to you or to a particular upload. We use them only to see where the service fails people — for example which rule blocks the most photos. They are deleted after 90 days.
• Aggregate traffic statistics — our network provider (section 3) compiles totals from its ordinary request logs: how many requests the site served, how much data it sent, how many unique visitors it saw, and which countries the requests came from. We see those totals only, with no per-visitor detail. Producing them adds no script and no cookie to these pages, and nothing in them is linked to your photograph, your upload or your purchase. They are held by that provider under its own retention policy, not on our server.
• Kept in your browser, not sent to us: two localStorage values — the last document type you chose and the identifier of your last job — so the site can offer to continue where you left off. Clearing your browser storage removes both.
• One first-party cookie, only if you switch language: it stores the language code you picked (nothing else) for up to a year, so the site opens in your language next time. We set no other cookies and load no third-party scripts.

We do not ask for your name, address, date of birth, passport number, or any other identity document detail, and you should not send them to us.

2. Face detection — what actually happens

To place your head correctly within the frame, we run automated face detection on your photograph. This locates facial feature points, including the bottom of the chin, so that the head can be sized to the millimetre range the issuing authority requires. Depending on where you live, this processing may be treated as the creation of biometric data.

These feature points are used only to compute where to crop, are never used to identify or recognise you, are never compared against any other photograph or database, are never used to train any model, and are deleted together with your photograph on the schedule in section 5. We ask for your explicit agreement before the first photograph you upload in a given browser, and the same notice is shown next to the upload control every time. If you do not want this processing, do not upload a photograph. We do not sell, lease, trade, or otherwise profit from biometric data — the only thing we charge for is the finished photo file.

3. Who else sees your photograph

• Cutout.Pro — when enabled, your photograph is sent to this image processing provider to separate the person from the background. It is sent for processing only, may be processed on servers outside your country, and is handled under that provider’s own privacy policy. When this provider is not enabled, background separation runs on our own server and your photograph is not sent to it at all.
• Gumroad, Inc. — handles payment. Gumroad receives your payment details directly; we do not. Gumroad tells us that a sale occurred, its identifier, and the purchase email. Your photograph is never sent to Gumroad. The buy button takes you to Gumroad’s own checkout page: that page is theirs, not ours, and what happens on it is covered by Gumroad’s privacy policy rather than this one. It runs Gumroad’s own analytics; we have configured no analytics or advertising pixel of our own there.
• Cloudflare, Inc. — our content delivery network, and the tunnel through which this site reaches the internet. Every request passes through it, so it sees what any web server sees: IP address, requested URL, browser and country. From those ordinary request logs it also compiles the aggregate traffic statistics described in section 1. Your photograph passes through Cloudflare in transit, as the body of your upload; it is never sent to Cloudflare for analysis and it is stored only on our server.
• Our hosting — the server stores your photograph and the files derived from it for the retention period in section 5, and nowhere else.

We do not sell your data and we do not share it for advertising.

4. What we do not do

• We do not require or create an account.
• We do not use your photograph to train models, ours or anyone else’s.
• We do not build a profile of you or link your uploads together.
• We do not run advertising trackers, and we load no third-party scripts at all — no analytics script, no tag manager, no font or widget fetched from anyone else’s domain.
• We do not measure you with a script in your browser, and we do not follow you across other sites. The only usage statistics we hold are the anonymous counters in section 1, written to and read from our own server; the aggregate traffic totals in section 1 are compiled and held by our network provider, not by us. Neither is linked to your photograph, your upload or your purchase.

5. How long we keep it

• If you do not buy: your photograph and everything derived from it are deleted automatically within 6 hours of upload.
• If you buy: they are kept for 72 hours so you can download again, then deleted automatically.
• To stop a payment being reused, we permanently keep a minimal claim record: a hashed sale identifier, the job identifier, and a timestamp. It contains no email address and no photo data. Our copy of your purchase email is stored with the job and deleted with it; the full sale record (including your email and receipt) is held by Gumroad in our merchant account for as long as accounting and tax rules require.
• The anonymous usage counters in section 1 are deleted after 90 days.

Deletion is performed by an automatic sweep; it is not conditional on you asking.

6. Your rights

Where the GDPR or UK GDPR applies, our legal bases are: your consent, for processing the photograph you upload (including face detection); performance of a contract, for delivering a file you purchased; and our legitimate interest in keeping the service secure, for server logs. You can withdraw consent at any time by not proceeding — the photograph is deleted on the schedule above regardless.

Depending on where you live, you may have the right to access, correct, delete, or restrict processing of your personal data, to object to processing, to data portability, and to complain to a supervisory authority. Because we hold your photograph only briefly and under a random identifier, the practical way to exercise deletion is simply not to complete a purchase — the file is removed on the schedule above. For anything else, contact admin@zyxir.com.

7. Children

Passport photographs are frequently taken of children. If you upload a photograph of a child, you confirm you are their parent or legal guardian. Children should not use this service themselves.

8. Contact

PhotoExact is operated by ZYXIR PTE. LTD. Privacy questions: admin@zyxir.com.