This Privacy Policy is the notice given by FABPix ("we", "us") under the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the Information Technology Act, 2000 and the rules made under it. It explains what personal data we collect when you use the FABPix app, websites and host dashboard (the "Service"), the purposes for which it is processed, how we protect it, and the rights you have. It should be read with our Terms & Conditions.

For the personal data we handle to run the Service, FABPix is the Data Fiduciary (the entity that determines the purpose and means of processing) and you are the Data Principal (the individual to whom the personal data relates). Our infrastructure providers act as Data Processors who process personal data on our behalf under contract. By providing personal data and using the Service you give your consent to the processing described in this notice; you may withdraw that consent as set out below.

Contents
  1. What we collect
  2. How we use it
  3. Consent & lawful basis
  4. People who appear in photos
  5. Who we share with
  6. Storage & security
  7. Retention & deletion
  8. Your rights as a Data Principal
  9. Grievance redressal
  10. Children
  11. Cookies
  12. International transfers
  13. Changes & contact

1. What we collect

We do not perform facial recognition or build biometric profiles from your photos.

2. How we use it

We do not sell your personal data or your Content, and we do not use your Content for advertising.

Under the DPDP Act we process your personal data on the basis of your consent, which you give when you create an account, join an event and upload Content. Your consent is free, specific, informed, unconditional and unambiguous, and is limited to the purposes described in section 2 above (purpose limitation). We collect only the personal data that is necessary for those purposes (data minimisation).

We may also process personal data for certain legitimate uses permitted by the DPDP Act, such as complying with a legal obligation, responding to a legal claim, and keeping the Service secure and preventing fraud and abuse.

You may withdraw your consent at any time - for example by deleting your Content, deleting your event, or asking us to close your account. Withdrawing consent will not affect processing already carried out, and may mean we can no longer provide parts of the Service. Withdrawing consent is as easy as giving it.

4. People who appear in photos & videos

Event albums contain photographs and videos of real people, who are also Data Principals. The Event Host is the organiser who created the event and decides who is invited and what is captured; the host and their guests are responsible for photographing and uploading only people who are happy to be photographed and shared within that event, and for obtaining any consent required by law. FABPix processes this Content solely to operate the shared album for that event. We do not perform facial recognition, build biometric profiles, or use anyone's image to identify or track them. If you appear in an event's Content and want it removed, see section 8 and the notice below on contacting the Event Host.

5. Who we share with

We do not share your personal data with third parties for their own marketing.

6. Storage & security

We maintain reasonable security safeguards as required by the DPDP Act and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. Content and data are stored with our infrastructure providers using access controls and encryption in transit. Access to Content is restricted to the members of the relevant event (and our systems that operate the Service). If a personal data breach occurs, we will notify the Data Protection Board of India and affected Data Principals as required by law. No online service can be guaranteed perfectly secure, so please keep your own copies of important media.

7. Retention & deletion

8. Your rights as a Data Principal

Under the DPDP Act, as a Data Principal you have the right to:

You can edit your profile in the app, delete your Content and events, and contact us to delete your account. To exercise any of these rights, email [email protected] or contact our Grievance Officer below. We may need to verify your identity, and we will respond within the timelines set out in section 9. You also have the right to complain to the Data Protection Board of India if you are not satisfied with our response. You are responsible for the accuracy and truthfulness of the information you give us.

Appearing in an event's photos or videos? The Event Host is the organiser who created that event and is responsible for the photos and videos collected during it. If you would like an image of you removed, please contact the Event Host of that event directly - they control and manage their event's album. You may also raise the matter with our Grievance Officer below.

9. Grievance redressal

As required by the DPDP Act and the Information Technology Act, 2000 and the rules made under it, FABPix has appointed a Grievance Officer to address questions and complaints about how we handle your personal data and to receive requests to exercise your rights.

Grievance Officer

10. Children

The Service is not directed at children under 18 years of age. A person under 18 may use the Service only with the verifiable consent of a parent or legal guardian given in a manner permitted by the DPDP Act. We will not knowingly process a child's personal data in a way that is likely to cause any detrimental effect on the child, and we do not undertake tracking, behavioural monitoring, or targeted advertising directed at children. If you believe a child has provided us personal data without appropriate parental consent, contact us and we will delete it.

11. Cookies & local storage

Our websites and dashboard use only essential cookies and local storage needed to keep you signed in and to remember your session and preferences. We do not use third-party advertising or tracking cookies.

12. International transfers

Our providers (Google, Cloudflare) operate global infrastructure, so your data may be processed on servers located outside India. Where this happens, we rely on those providers' safeguards for such transfers, and we will not transfer personal data to any country that is restricted by the Central Government under the DPDP Act.

13. Changes & contact

We may update this Privacy Policy from time to time; the current version is always on this page and material changes will be notified in the app or on the website. For any privacy question or request, contact [email protected].