photolab by emlovz — Privacy Policy

1. About this policy

This Privacy Policy explains how emlovz LLC, doing business as emlovz ("we," "us," or "our"), collects, uses, discloses, and retains personal information when you visit photolab.emlovz.com, create an account, purchase a photo test, submit photographs, receive results, or contact us (collectively, "photolab" or the "Service").

Our mailing address is One Sansome Street, Suite 1400, San Francisco, CA 94104. For privacy questions or requests, email info@emlovz.com, write to that address, or call (415) 306-3900.

This policy covers photolab. Other emlovz services may have separate privacy notices. External websites and providers may also process information under their own policies. This policy does not waive your privacy rights or make every processing activity dependent on your acceptance of website terms.

The essential point: human raters will see photographs you submit for testing. Your photographs can identify you even when your name and contact information are not displayed.

This policy describes photolab’s information practices. It is not a request for blanket consent. An activity that requires separate permission will be presented separately, and a policy update alone does not supply that permission.

2. Information we collect and its sources

We collect information you provide, information generated through your use of photolab, and information received from providers involved in delivering the Service. If an authorized coach or photographer submits photos for you, we receive those photos and related order information from that person.

Photographs may reveal other people, approximate age, racial or ethnic appearance, religious clothing, health-related details, location clues, or other sensitive information. We do not need those details for their own sake. Avoid sensitive documents, precise location information, and unnecessary personal details. Embedded photo metadata, including available location metadata, is removed before a photo is made available to raters. Do not rely on metadata removal to hide an address, person, or other detail visible in the image itself.

Our Terms prohibit identifiable photographs of anyone under 18 and require appropriate permissions for other adults appearing in a submission.

Payment details: Payments are processed through Stripe. Stripe receives payment information necessary to process the transaction and may process it for additional purposes explained in its own Privacy Policy. We receive transaction information needed to manage your purchase.

You pay in Stripe's secure payment form on our checkout page, so your card number and security code go directly to Stripe and never reach photolab. We keep Stripe's reference numbers for your payment, the amount and currency, and the email address used at checkout. We do not store card numbers or their last four digits; refunds are made through Stripe using the payment reference.

3. How we use personal information

We use personal information to:

• Create and administer accounts and authenticate access.
• Accept eligible photos, configure tests, recruit raters, and display photos for evaluation.
• Calculate scores, rank photos, produce reports, and make reports available to you.
• Send order confirmations, result notifications, and important service notices.
• Process purchases, refunds, accounting records, and payment disputes.
• Respond to support requests and privacy requests.
• Protect accounts, investigate misuse, moderate prohibited content, and assess rating quality.
• Maintain and troubleshoot the Service and evaluate performance.
• Send optional promotional communications when permitted by law and consistent with your choices.
• Meet legal obligations and establish, exercise, or defend legal claims.

Scores describe subjective photo impressions. They are not background checks or verified findings about your character, health, safety, or relationship readiness. Calculating a score does not make it an objective fact about you. We do not use photolab scores to make employment, housing, credit, insurance, or similar eligibility decisions.

We may use aggregated or genuinely deidentified rating statistics to improve photolab. When information has been deidentified, we maintain it in that form and do not attempt to reidentify it except where permitted by law to verify the effectiveness of deidentification. Merely removing a name from an identifiable photograph does not make the photograph anonymous.

We do not use photo scores to identify you through facial recognition or to decide your eligibility for employment, housing, credit, insurance, or similarly significant services. We do not seek to infer a diagnosis, sexual orientation, religion, or other sensitive characteristic from your appearance. The impressions described in your purchased test remain subjective photo feedback.

4. Human raters and photo access

Human raters will see the photographs you submit for testing and the rating questions needed for the test. We do not provide raters with your account name, email address, payment details, or other account contact information. A photograph can nevertheless identify you or reveal information about you and other people shown.

We may use third-party recruiting platforms to find eligible raters and coordinate participation. These platforms handle participant accounts and related information under their own privacy policies. We may receive participant identifiers, demographic eligibility information, completion records, and quality-control information to administer tests and assess rating quality. Raters view photos on photolab itself: we do not send your photos to the recruiting platform, which receives only a link to the test.

Rater responses are associated with your test so we can calculate scores, rank your photos, and deliver your report. This customer policy does not replace any separate privacy information required for people participating as raters.

Your uploaded photos are not intended for a public gallery or public search. Access is intended for raters evaluating your photos and authorized personnel and providers supporting the Service. Photo use is limited to the purposes described in this policy and our Terms.

No online service can guarantee that a viewer will never recognize, copy, or misuse an image. Submit only photos you are comfortable having human raters evaluate, and contact info@emlovz.com promptly if you suspect unauthorized use.

Rater access is limited to the assigned evaluation. Raters must not download, screenshot, retain, redistribute, publish, identify or contact the subject, or use a photo for an unrelated purpose. We require applicable rater and provider restrictions and limit authorized access to the task. After an evaluation ends, the rater has no continuing permission to access or use the photo.

5. Other disclosures

We disclose information as reasonably necessary to:

Service providers. Providers supporting website hosting, file storage, authentication, payment processing, rater recruitment, moderation, email delivery, support, security, and any disclosed analytics functions. They receive information relevant to their role, subject to applicable contractual and legal requirements. Some providers, such as payment processors, also process information for independent purposes under their own policies. Our current providers include a website hosting and file storage provider, a database provider, Stripe (payments), a rater recruitment platform, an email delivery provider, an image moderation service (the automated nudity check of uploaded photos described in Section 6), analytics providers, including Google Analytics, subject to the practices and choices described in Section 7, a customer relationship management (CRM) provider, and Google, if you choose to sign in with Google. We also use Google Ads for advertising and conversion measurement. Google may receive information about website visits, advertising interactions, and completed purchases through cookies, conversion tags, or similar technologies, subject to applicable privacy requirements and the settings we implement.

Customer relationship management (CRM) provider. When you buy a test, your name, email address, and purchase details (package, amount, and date) are added to our customer records. Adding you to our CRM does not sign you up for marketing emails; any marketing follows your choices described in Section 8.

Authorized personnel. Personnel and contractors who need access to deliver tests, handle support, maintain systems, or address legal and security matters. Being part of the emlovz coaching team does not by itself mean someone needs access to every customer's photos.

People you authorize. A coach, photographer, or other recipient if you ask us to share information or authorize access. If you share your report yourself, that recipient's use is outside our direct control.

Legal and safety recipients. Authorities, advisers, or other parties when reasonably necessary to comply with law or lawful process, protect rights and safety, investigate fraud or unlawful activity, or resolve disputes. We do not treat every third-party allegation as automatic permission to disclose your identity.

Business transfers. Parties involved in a proposed or completed merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality protections, applicable law, and continued protection of your information. We will provide notice or obtain consent where required.

We do not disclose uploaded customer photographs or individual test results to advertising platforms for advertising, audience building, retargeting, or conversion measurement. Current cookie and advertising practices are described in Section 7. If we propose a materially different disclosure, we will provide the notice, choices, and separate permission required by law before it begins.

6. Photographs, AI, and biometric processing

Human raters provide the photo feedback. Software organizes their responses and calculates results. Automated tools may support functions such as moderation or quality checks only as described here.

Submitting a photo or accepting the Terms does not authorize use of identifiable customer photographs or individual reports in advertising, public examples, testimonials, or any AI or machine-learning model training, fine-tuning, or evaluation. Those uses require a separate, specific authorization and any further permission required by law. Running an existing moderation model solely to check a submitted photo is a different activity, described below.

Nudity check. We use an image moderation service to check uploaded photos for prohibited sexual content before testing. We use its online immediate-response mode: the service receives the photo for the check, processes the image data in memory without persisting it to disk, and may temporarily retain request metadata such as timing and request size. Its provider states that submitted content is not used to train or improve the service. We keep the moderation result needed to accept or reject the submission. A flagged photo is not accepted; you may submit a replacement or contact info@emlovz.com if you believe the flag is mistaken. Authorized personnel may review photos where needed for moderation, support, or an error investigation.

photolab does not create face templates, faceprints, facial embeddings, or other biometric identifiers and does not perform facial recognition or identity matching. The moderation check is not used for those purposes. We do not instruct our providers to create biometric identifiers or use submitted photos to identify a person.

A photograph and information derived from it may be regulated differently depending on what processing occurs and the applicable law. This policy is not a blanket authorization for biometric identification.

7. Cookies, analytics, advertising, and privacy choices

Current practice. photolab uses cookies and similar technologies needed for sign-in, account security, preferences, and operation. We use Google Analytics to understand how visitors interact with our website and Google Ads to advertise our services and measure advertising performance.

Google Ads and conversion tracking. We use Google Ads conversion tracking to measure the effectiveness of our advertisements, including when visitors complete actions such as purchasing a photo test. Google Ads may collect information through cookies, tracking tags, and similar technologies, including IP addresses, browser and device information, website interactions, advertising identifiers, and conversion events. This information helps us understand which advertisements lead to customer activity and improve our advertising campaigns.

We do not provide uploaded customer photographs, individual photo ratings, or test results to Google Ads for advertising or conversion measurement. Google Analytics remains disabled on pages displaying customer photographs or individual test results, and its advertising features are not enabled.

Advertising privacy choices. Google may process information collected through its advertising technologies in accordance with its privacy policies. Visitors can manage Google's advertising personalization settings at https://myadcenter.google.com/ and learn more about Google's privacy practices at https://policies.google.com/privacy.

We provide any consent mechanisms and opt-out options required by applicable privacy laws, including honoring Global Privacy Control signals where legally required. Depending on the advertising technology and configuration, certain disclosures to advertising providers may qualify as sharing for cross-context behavioral advertising under applicable law.

Cookies and browser settings. You may block or delete cookies through your browser settings, although disabling essential cookies may affect sign-in, payments, or other website functionality. Stripe's payment form uses its own technologies under Stripe's privacy policy.

We do not provide uploaded customer photographs or individual test reports to advertising platforms for advertising, audience building, retargeting, or conversion measurement. Any material changes to our advertising or tracking practices will be reflected in this Privacy Policy, together with applicable privacy choices and protections.

8. Communications and marketing choices

We send service emails about purchases, results, security, and support. These differ from optional marketing messages.

You can unsubscribe from marketing emails using the link in the message or by contacting info@emlovz.com. Unsubscribing from marketing does not stop necessary service messages. Marketing texts or calls, if offered, require any separately applicable consent and provide their own opt-out instructions. Acceptance of this Privacy Policy is not consent to marketing texts or calls.

We obtain separate permission before using an identifiable customer photo or testimonial for promotion. You may contact us to withdraw that permission prospectively, subject to the authorization you gave and applicable law.

Permission to use a photo or testimonial for promotion is optional and is not required to purchase or receive the photo test. Any separate authorization will explain its scope and how to withdraw permission prospectively.

9. Retention and deletion

We retain information only for the stated service, support, security, or legal purpose and only for as long as reasonably needed. The following periods govern active systems unless an earlier verified deletion request or a specific lawful preservation duty applies.

Request photo or account deletion at info@emlovz.com. We verify identity only as reasonably necessary and permitted. We remove eligible information from active systems, stop further authorized rater access to affected photos, and instruct relevant providers to delete or restrict information as required. We may retain limited information for legal compliance, security, payment records, or claims; it remains restricted to that purpose.

Active-system deletion and backup expiry may occur on different schedules. We cannot retrieve copies you independently shared or guarantee removal of unauthorized copies, but we investigate reported misuse and take available corrective measures. If deletion prevents an unfinished test, the cancellation and refund provisions in the Terms apply; deleting an upload does not itself waive a refund or forfeit unused paid value.

10. Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the information involved. Pages and uploads use HTTPS. Photos are stored with restricted access for the customer, assigned raters, and authorized personnel who need access for the disclosed purposes. photolab itself does not store IP addresses. Our hosting provider keeps request logs, which include IP addresses, browser details, and the pages requested, for security and troubleshooting, and they are deleted automatically within 30 days. Raters can open a test's photos only through its test link while the test is open; the link closes two hours after the test's last rating. We investigate reported misuse. Sign-in uses a one-time email link or Google rather than a photolab password. Card payments are handled by Stripe's payment form on our checkout page.

No system is completely secure. Keep account access information confidential and report suspected unauthorized access to info@emlovz.com. We provide notifications about security incidents where required by applicable law.

11. Your privacy requests and rights

You can contact info@emlovz.com to request access to your information, correction of inaccurate account details, deletion, or assistance with privacy preferences. Depending on your location and the laws that apply to our processing, you may have rights to:

• Know the categories and specific information collected, its sources, purposes, and recipients.
• Obtain access to information and, where required, a portable copy.
• Correct inaccurate information and request deletion, subject to lawful exceptions.
• Opt out of sale, sharing, targeted advertising, or certain profiling where applicable.
• Restrict or object to particular processing or withdraw consent where processing depends on consent.
• Limit certain uses of sensitive personal information where applicable.
• Appeal a denied request where applicable and complain to a competent privacy regulator.

We do not unlawfully discriminate against you for exercising privacy rights. If deleting necessary information prevents us from providing a requested test, we will explain that consequence and available options.

Use the email address associated with your account where possible and describe your request. We may request proportionate verification or evidence of an authorized agent's authority. Do not send passwords or full payment card numbers. Verification is not required for an opt-out request where the law prohibits requiring it. We respond within applicable legal deadlines and explain any permitted extension or denial. To appeal a denial where an appeal right applies, email us with "Privacy appeal" in the subject line.

California consumers. If our processing is subject to the California Consumer Privacy Act, including its amendments, you may request access to and a portable copy of covered information, correction, and deletion, subject to lawful exceptions. You may direct us not to sell or share covered information, and limit uses of sensitive personal information where that right applies. We do not discriminate unlawfully against you for exercising these rights. Sections 2 through 7 identify the information, sources, purposes and recipients; Section 9 supplies retention periods or criteria.

Submit requests by emailing info@emlovz.com, by calling (415) 306-3900, or by writing to emlovz LLC at the address in Section 1. Our website’s privacy contact provides access to the request channel. For CCPA requests to know, correct, or delete, we respond within 45 calendar days after receiving the request; verification does not restart that period. If a further 45 days is reasonably necessary and lawful, we explain the extension within the first 45 days. Requests to opt out or exercise other rights follow their applicable deadlines.

An authorized agent may submit a request as permitted by law. We ask only for proof of authority and identity verification appropriate to the request, and we do not require verification for an opt-out where law prohibits it. Privacy requests are ordinarily free; any permitted fee or refusal will be explained. You may contact the California Privacy Protection Agency or the California Attorney General if you believe your rights have been violated.

12. International users and transfers

We operate in the United States. Your information may be processed where we, our raters, or providers operate, which may involve countries with different privacy laws.

photolab's servers run in the United States. Our raters are currently recruited in the United States, Canada, the United Kingdom, Ireland, Australia, and New Zealand. Our rater recruitment platform is based in the United Kingdom; it receives a link to your test, not your photos. Stripe and our other providers may process information in other countries under their own policies.

Where EEA or UK data protection law applies, relevant processing must have an appropriate legal basis: providing a requested service where necessary for the contract, compliance with legal obligations, legitimate interests where permitted after balancing relevant rights, or consent where required. You may complain to your local data protection authority where applicable.

13. Children and other people in photos

photolab is intended for adults aged 18 or older. We do not knowingly offer accounts or photo testing to minors, and our Terms prohibit identifiable images of minors. If you believe a child submitted information or appears in an uploaded photograph, contact us so we can investigate and remove information as appropriate.

If another person submitted a photograph of you without permission, contact info@emlovz.com with enough information to identify the submission. We will assess the report, take appropriate action, and address any applicable privacy rights without unnecessarily disclosing another customer's information.

14. Changes and contact

We will post the effective date of revisions and explain material changes through email or a prominent service notice before they apply, and obtain consent where required. A revision does not itself authorize an incompatible new use of previously collected information. Before a new retention schedule removes previously stored customer reports, we provide reasonable advance notice and an opportunity to download them.

Privacy questions and requests: info@emlovz.com

Operator: emlovz LLC

Mailing address: One Sansome Street, Suite 1400, San Francisco, CA 94104

Business telephone: (415) 306-3900