Privacy Policy

Last Updated: May 6, 2026

This Privacy Policy explains how Evoto Instant and the applicable Evoto contracting entity collect, use, disclose, store, and otherwise process personal information in connection with Evoto Instant and related websites, applications, galleries, cloud storage, project tools, photo delivery flows, purchase and download flows, and related services (collectively, the “Services”).

Evoto Instant is a cloud-based, AI-assisted real-time photo gallery and workflow service designed primarily for photographers and similar professional or business users. Depending on the feature used, the Services may support photo hosting, cloud storage, project administration, participant communications, optional purchase and download workflows, AI-assisted processing, optional face-based project tools, and related service features.

For purposes of these Services, the applicable Evoto contracting entity is generally:

(i) Truesight Technology Inc. if you are located in the United States, Canada, or Mexico; or

(ii) TRUESIGHT PTE. LTD. if you are located outside those regions. In this Privacy Policy, “Evoto Instant,” “Evoto,” “Truesight,” “we,” “us,” and “our” refer to the applicable contracting entity unless the context indicates otherwise.

This Privacy Policy should be read together with the applicable Terms of Use, photographer-facing terms, End User privacy notices, feature-specific notices, and any applicable data processing or transfer terms. Where a feature-specific notice or consent flow applies, that feature-specific notice will supplement this Privacy Policy for that feature.

1. Who This Privacy Policy Applies To

This Privacy Policy applies to different categories of individuals depending on how the Services are used, including:

• photographers, studios, agencies, organizations, project administrators, and other account holders who subscribe to or use the Services (“Customers”);

• end users, participants, invitees, gallery visitors, purchasers, download recipients, and other individuals who access a project, gallery, link, or delivery flow made available by a Customer (“End Users”); and

• individuals who use optional features such as Find Me or Interact, or who otherwise interact with us directly through support, account, payment, or service-related communications.

2. Our Roles: When We Act as Controller and When We Process Data on a Customer’s Behalf

Depending on the processing activity, Evoto Instant may act either as an independent controller (or equivalent concept under applicable law) or as a processor, service provider, contractor, or similar intermediary acting on a Customer’s behalf.

We generally act as a controller for our own business and operational purposes, such as account registration, subscription management, billing support, credits administration, cloud storage administration, security, fraud prevention, customer support, legal compliance, audit, service analytics used to operate and improve the Services, and management of third-party integrations or Connected Accounts.

We generally process personal information on behalf of Customers when we provide hosting, storage, photo delivery, gallery administration, project administration, project-level workflows, participant-list functionality, optional face-based project tools, and related customer-facing service functionality.

As between the Customer and the individuals whose personal information the Customer uploads or makes available through the Services, the Customer is generally responsible for determining whether it acts as a controller, business, or other primary responsible party under applicable law, and for providing required notices and obtaining required permissions, consents, authorizations, or other lawful bases where required.

3. Personal Information We Collect

The categories of personal information we collect depend on how you use the Services and which features are used.

A. Account and subscription information. We may collect information such as your name, business or studio name, email address, login or account credentials, account settings, subscription plan information, storage plan information, credits records, billing address, tax-related information, transaction records, payment status, invoice data, and customer support history.

B. Project and gallery data. We may process photos, image files, edits, metadata, project settings, comments, delivery settings, gallery access settings, delivery history, order-related data, download history, and other content or project-related materials uploaded to or generated through the Services.

C. Participant List data. If a Customer uploads a participant list or similar contact list, we may process limited contact information such as a participant’s or invitee’s name or nickname and email address for the purpose of distributing or facilitating access to photos, galleries, or other project data.

D. End User interaction data. We may collect technical and usage information relating to access to the Services, such as IP address, browser type, operating system, device identifiers, network information, language and regional settings, access timestamps, pages viewed, clicks, session information, error logs, and other service interaction data.

E. Payment and transaction metadata. Depending on the workflow, we may process transaction-related information such as order identifiers, payment status, refund status, service-fee status, download fulfillment status, fraud checks, and related records. Complete payment card details are generally processed by the applicable payment provider and are not stored by Evoto Instant.

F. Communications and support information. We may collect the contents of communications you send to us, including support tickets, emails, feedback, and related correspondence.

G. Connected Account and third-party integration data. If you choose to connect a third-party platform, login service, payment channel, communication service, or other supported integration to your account, we may receive information made available by that third party, such as account identifiers, profile information, tokens, permissions, transaction status, or content needed to provide the integration.

H. Optional face-based feature data. If you choose to use certain optional features, we may process additional data as described below under “Optional Face-Based Features,” including Find Me reference images and project-internal Interact-related data.

4. Optional Face-Based Features

Certain features of Evoto Instant may involve face-based, facial matching, face grouping, or similar image analysis functionality. These features are optional unless expressly stated otherwise in feature-specific terms.

A. Find Me. If an End User voluntarily chooses to use the Find Me feature, the End User may be asked to upload a reference image of themself so the system can search for likely matches within the relevant project. The reference image is used to provide the requested Find Me functionality for that project. After processing is completed, Evoto Instant will not retain the original reference image for the Find Me search process; however, a thumbnail version may be saved to the photographer’s account to help the photographer quickly identify the corresponding user and provide related project services, such as photo selection, retouching, delivery, and other project-related support. We do not use the reference image for identity verification, and do not use it to train Evoto Instant’s or Evoto’s generalized or foundational artificial intelligence or machine learning models. Where required by applicable law, Find Me is subject to a separate notice and consent flow.

B. Interact. Interact is an optional project-level tool for photographers and authorized project administrators. When enabled, Interact may analyze photos within a project in order to detect faces appearing in those photos, organize project-internal face-related results, and generate a clickable face index or similar project-internal navigation functionality to help locate, group, filter, select, or batch process photos within that same project. Interact is not an identity verification service, is not used to build cross-project identity profiles, is not reused across different projects, and is not used to train Evoto Instant’s or Evoto’s generalized or foundational artificial intelligence or machine learning models. Interact-related data remains associated with the relevant project and is deleted in accordance with the applicable project deletion and retention rules described below.

C. Responsibility for permissions and notices. Customers remain responsible for determining and satisfying any notice, transparency, consent, permission, parental authorization, or other legal requirement applicable to their use of optional face-based features in connection with project photos, including where minors appear in those photos. Feature-specific notices or activation terms may apply in addition to this Privacy Policy.

5. How We Use Personal Information

We may use personal information for the following purposes, depending on the relationship, feature, and processing context:

• to create, manage, and maintain accounts, subscriptions, storage plans, credits, project settings, and related account records;

• to provide, deliver, activate, host, update, maintain, secure, support, and improve the Services;

• to process, store, organize, display, transmit, export, share, and administer project photos, project data, gallery data, and related cloud-based features;

• to process orders, payments, subscriptions, invoices, taxes, refunds where applicable, payment support requests, and related customer relationship and transaction administration;

• to verify identity where reasonably necessary, protect account security, detect and prevent fraud, abuse, unauthorized access, illegal content, and other security incidents;

• to respond to inquiries, requests, comments, complaints, appeals, support matters, and privacy rights requests;

• to analyze Service usage, diagnose issues, debug errors or crashes, improve stability, and improve product design, performance, and user experience;

• to support cloud sync, project storage, content processing, collaboration, sharing, export, cross-device access, and other cloud-based or workflow-related features;

• to communicate with you about your account, subscription, transactions, support requests, technical notices, service updates, surveys, newsletters, offers, event notices, product updates, marketing information, or message alerts, where you have provided consent or where otherwise permitted by applicable law;

• to enforce contracts, terms, and policies, resolve disputes, protect our lawful rights, property, users, partners, and public safety, and establish, exercise, or defend legal claims; and

• to comply with applicable laws, regulatory requirements, court orders, law enforcement requests, or other legal processes.

For clarity, we do not use photos uploaded to or processed through Evoto Instant, Find Me reference images, or Interact-related face data to train Evoto Instant’s or Evoto’s generalized or foundational artificial intelligence or machine learning models.

6. Legal Bases for Processing

Where required by applicable law, we rely on one or more legal bases to process personal information, depending on the context.

When we act as a controller, we may process personal information where necessary to perform a contract with you, to take steps at your request before entering into a contract, to comply with legal obligations, to pursue our legitimate interests where those interests are not overridden by applicable rights and interests, or on the basis of your consent where required by law.

When we process personal information on behalf of a Customer, the Customer is generally responsible for identifying and documenting the appropriate legal basis for the relevant processing, including where explicit consent or other special authorization is required for particular project content or optional face-based features.

7. Payments, Purchases, and Future Service Fees

Customers may purchase subscriptions, cloud storage, credits, or related services directly from Evoto Instant. In those cases, we and our payment providers may process the information needed to administer the applicable subscription, billing, payment, refund, fraud review, and tax or invoicing obligations.

In some project, gallery, purchase, or download workflows, a Customer may choose to charge End Users for access to or downloads of photographic works. Unless expressly stated otherwise in the applicable checkout flow, supplemental terms, or written agreement, those transactions are generally formed between the Customer and the End User, and the applicable third-party payment provider may process the payment. Evoto Instant may nevertheless process limited transaction metadata, payment status information, fulfillment data, fraud or security data, and related service records needed to facilitate or support the relevant workflow.

Where permitted by applicable law and disclosed in advance, Evoto Instant may in the future charge platform, technology, transaction-support, digital-delivery, or other service-related fees for certain features or services. If introduced, any such fees will be described in the applicable pricing page, checkout flow, product interface, or supplemental terms and will apply prospectively only.

8. How We Share Personal Information

We may disclose personal information to the following categories of recipients, depending on the Services used and applicable law:

• our affiliates, related entities, and internal support teams where reasonably necessary to provide, administer, support, secure, maintain, or improve the Services;

• service providers, processors, and subprocessors that help us provide the Services, such as cloud hosting and infrastructure providers, storage providers, payment providers, communications and email providers, customer support and ticketing providers, security and anti-fraud providers, analytics providers, development and operations support providers, and professional advisers;

• connected-account providers or other third-party integration providers where you choose to enable or use the relevant integration;

• payment providers and financial service providers that process subscription charges, refunds, settlements, or transaction support;

• legal, regulatory, governmental, judicial, or law-enforcement authorities where required by applicable law or reasonably necessary to protect rights, safety, or the integrity of the Services;

• professional advisers, auditors, insurers, or transaction counterparties in connection with legal compliance, corporate transactions, or the establishment, exercise, or defense of legal claims; and

• other recipients where you direct us to do so or where we otherwise have your consent.

We require service providers that process personal information on our behalf to process such information in accordance with our written instructions and to implement appropriate confidentiality, security, and data protection measures. Where appropriate, we enter into data processing agreements or other compliance documentation with such providers to limit their use of personal information for their own independent purposes.

To enhance transparency, we may further disclose, through our list of third-party service providers and subprocessorsCookie Policy, in-product notices, or other supplemental notices, the names or categories of certain third-party recipients, service providers, and subprocessors, the processing purposes, and the types of personal information involved.

We do not sell uploaded customer photos, Find Me reference images, or Interact-related face data, and we do not use them for generalized or foundational AI model training.

9. International Transfers and Hosting Location

Your use of the Services may involve the processing, hosting, storage, or transfer of personal information and project data in the United States, including on Amazon Web Services infrastructure located in Oregon, and in other jurisdictions where Evoto Instant or its service providers operate.

Where required by applicable law, we implement appropriate transfer safeguards for cross-border data transfers, which may include the EU Standard Contractual Clauses, the UK International Data Transfer Addendum, Swiss supplementary clauses or adaptations, or other legally recognized transfer tools. Additional information about applicable transfer safeguards may be set out in the DPA, Privacy Policy supplements, or other applicable transfer documentation.

10. Retention and Deletion

We retain personal information for different periods depending on the type of data, the purpose for which it is processed, our legal obligations, and the applicable service rules.

A. Account, subscription, billing, support, and operational records may be retained for as long as reasonably necessary to administer the account and subscription relationship, provide support, comply with legal obligations, maintain appropriate financial and audit records, resolve disputes, prevent fraud, and enforce our agreements.

B. Project photos and project data. If a Customer deletes a project, the associated photos and related project data, including associated feature-specific project data linked to that project, will be deleted in the ordinary course, subject to limited backup, cache, logging, legal hold, security, fraud-prevention, and technical cleanup processes. If a subscription expires or is terminated, project photos, related user data, and related project-derived data may remain available for up to thirty (30) days solely to allow renewal, recovery, export, account reactivation, or service continuity. After that period, the relevant data will be permanently deleted or rendered non-recoverable in the ordinary course, unless a longer retention period is required by applicable law or is necessary for security, fraud prevention, or the establishment, exercise, or defense of legal claims.

C. Participant List data is retained as part of the relevant project or account records in accordance with the applicable project and account retention rules, unless deleted earlier through the Services or by instruction from the relevant Customer, subject to limited backup, legal, security, and technical retention needs.

D. Find Me reference images. After processing is completed, Evoto Instant will not retain the original reference image for the Find Me search process. A thumbnail version may be saved to the photographer’s account to help the photographer quickly identify the corresponding user and provide related project services, unless deleted earlier through available controls or upon request where applicable.

E. Interact-related data remains associated with the relevant project. If the project is deleted, the associated Interact-related data will be deleted together with the project data in the ordinary course. If the relevant subscription expires or ends, Interact-related data is subject to the same project retention rules described above and will not be preserved independently of the project.

F. Certain cached, logged, or backup copies may continue to exist for a limited period and may be deleted or overwritten on a rolling basis under our ordinary system rules.

11. Data Subject Rights and Choices

Depending on your location and applicable law, you may have rights to request access to, correction of, deletion of, restriction of, portability of, or objection to the processing of certain personal information, and to withdraw consent where processing is based on consent.

If you are a Customer, you may also be able to access, update, export, or delete certain information through your account settings or by contacting us at contactus@evoto.ai.

If you are an End User whose information is processed on behalf of a Customer, we may need to direct your request to the relevant Customer, because that Customer is generally the party best positioned to decide how your project-related information should be handled. We may still process certain requests directly where we act as a controller or where applicable law requires us to do so. If you would like to request deletion of a Find Me thumbnail, you may contact us at contactus@evoto.ai, and we may coordinate with the relevant Customer where appropriate.

If you wish to withdraw consent for a feature that relies on consent, such as a feature-specific face-based workflow where consent is required, you may do so using the relevant feature controls where available or by contacting the relevant Customer and/or us, as appropriate. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

12. Marketing Communications and Cookies

Where permitted by applicable law, we may send Customers service-related or, where applicable, marketing-related communications. You may opt out of non-essential marketing communications by using the unsubscribe mechanism included in the message or by contacting us.

Where required by law, non-essential cookies or similar technologies will be used only with the consent required by applicable law. You may manage cookie preferences through the tools made available in the relevant interface where applicable.

13. Minors

Evoto Instant is primarily designed for photographers, studios, and other professional or business users, not for direct consumer use by children as a general audience service. However, project photos uploaded by Customers may include images of minors, and certain project-related personal information may relate to minors depending on the event or project context.

Customers are responsible for determining whether minors’ information is included in project data and for obtaining any notices, consents, parental authorizations, or other lawful bases required under applicable law for the collection, upload, processing, sharing, or use of that information, including in connection with optional face-based features such as Find Me or Interact where applicable.

If you believe that personal information relating to a minor has been processed through the Services in a way that violates applicable law, please contact us at contactus@evoto.ai so that we can review the issue and take appropriate action as required by law.

14. Security

We use reasonable technical, organizational, and administrative measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Services, law, technology, business operations, or privacy practices. When we do so, we will update the “Last Updated” date above and, where required by applicable law, provide additional notice or obtain consent as required.

16. Contact Us

If you have questions, comments, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: contactus@evoto.ai