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Privacy Policy

Version 1.1 — Effective 29 October 2026

This Privacy Policy explains how Tradax Sdn Bhd (Company No. 202301011247 / 1504135-A) ("we", "us", "our") collects, uses, and protects your personal data when you use the Photo Finder platform ("Service").

This policy is drafted in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA).

1. Data We Collect

Category Data Purpose
Account Information Email address, display name, Google OAuth ID; for event owners also phone number, company and bank details (bank, account number, account holder name) Authentication, account management, communication, owner payouts
Facial Data Numerical embedding vectors derived from uploaded photos Photo matching (face recognition search)
Transaction Data Credit purchases, face unlocks, payment references Billing, transaction history, fraud prevention
Usage Data Search history, download history, consent records (IP, user-agent) Service improvement, legal compliance
Technical Data IP address, browser type, device information Security, abuse prevention

2. How Facial Data Is Processed

3. Legal Basis for Processing

Under the PDPA 2010, we process your personal data based on:

4. Data Sharing

We do not sell your personal data. We share data only with:

5. Data Retention

Data Type Retention Period
Account information Until account deletion or 2 years of inactivity
Facial embeddings (your uploads) Until account deletion
Event photos and their facial embeddings Until the event is removed. An event with no paid sale for 90 days incurs a storage fee; if it isn't paid, the event's photos and embeddings are deleted after a 7-day notice to the organiser
Transaction records 7 years (Malaysian tax law requirement)
Uploaded selfie images Automatically deleted within 24 hours of upload
Search results (with the search's facial embedding and face thumbnail) 7 days
Consent records Duration of account + 2 years
Encrypted backups (including account and facial data) 30 days

6. Your Rights Under PDPA

Under the Personal Data Protection Act 2010, you have the right to:

To exercise these rights, contact us at [email protected].

7. Cookies & Similar Technologies

8. Data Security

9. Event-Specific Privacy Terms

Individual events may have additional privacy terms set by the event organiser. These will be displayed in the consent prompt when you first access an event. Event organisers are responsible for their own compliance with applicable data protection laws regarding event photos.

10. Children's Privacy

The Service is not intended for use by persons under the age of 18. We do not knowingly collect personal data from minors.

11. International Data Transfers

Your account data, transaction records and facial embeddings are stored and processed on our servers in Malaysia. Original event photos are stored with Backblaze in the United States and preview images with Cloudflare; some data may also be processed by Google and Cloudflare, with servers in other jurisdictions. These providers maintain appropriate data protection standards.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through an updated consent prompt on the platform. The "Effective" date at the top indicates the latest revision.

13. Contact & Complaints

For privacy inquiries or complaints:

Tradax Sdn Bhd
Email: [email protected]