Biometric Information Privacy Policy

MATERIAL
DATED 2026-08-11 · VERSION 20260812_rev01 · FIRST CAPTURED VERSION

What changed, in plain language

Photobucket rewrote its biometric policy for the new "Groupsy by Photobucket" service. The good news: it now states in plain terms that it will never sell your content or use your photos and videos to train AI, and it spells out exactly what the FaceFinder consent pop-up must tell you. The trade-offs: FaceFinder is now a paid Plus Plan feature that only searches Groups (not your personal Library), Photobucket added a security disclaimer saying it can't guarantee your data is safe, added a line saying it isn't responsible if you use FaceFinder on photos of other people, allowed deleted content to linger in backups, and carved FaceFinder data out of the policy's own protections.

Changes that may affect you

You now carry the blame for using FaceFinder on other people's facesMATERIAL
LIABILITY LIMITS

If you run face-matching on pictures that include friends, family, or strangers, Photobucket now says flatly that it is not responsible. Some states, like Illinois, let people sue over face scans. This wording aims to leave you holding that risk on your own.

“Photobucket is not responsible for your use of the FaceFinder Feature with respect to the Biometric Information of third parties.”

What you can do — Ask people for permission before adding photos of them to a Group where you use FaceFinder, and avoid running it on photos of people you don't know.

Face data made on your phone is exempt from this policy's protectionsMATERIAL
OTHER

The policy's rules about how Photobucket handles, stores, and refuses to profit from biometric data no longer apply to anything FaceFinder creates. The reasoning is that this data never leaves your device. That is likely true today, but it means if the feature ever did send data, the promises in this policy would not clearly cover it.

“Because no Biometric Information is transmitted to or received by Photobucket in connection with the FaceFinder Feature, the provisions of this Biometric Policy relating to Photobucket's collection, storage, or commercialization of Biometric Information do not apply to data generated by the FaceFinder Feature.”

What you can do — If you don't want faceprints created at all, leave FaceFinder turned off, or delete saved faces using the pencil icon next to each person.

Photobucket no longer guarantees your data is secureMINOR
LIABILITY LIMITS

A new disclaimer says Photobucket can't promise your information is safe and names hacking and equipment failures as risks. It still promises reasonable protections, but this wording is designed to limit what you can claim if there's a breach.

“However, we cannot guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your information at any time.”

What you can do — Turn on a strong, unique password and any available two-factor login, and keep your own copies of photos you can't afford to lose.

Deleted photos may linger in backupsMINOR
DATA RETENTION

The 30-day deletion promise is still there, but Photobucket now says leftover copies can stay in its backup systems for a "limited period" with no set deadline. So deleting something may not remove it everywhere right away.

“Residual copies may remain in our backup systems for a limited period and will be deleted in the ordinary course.”
Time limit on face data stored on your phone was droppedMINOR
DATA RETENTION

The old policy said face data created by FaceFinder was kept only as long as needed to run the feature. That sentence is gone. The data still sits only on your own device and you can delete it, but there's no longer a stated limit on how long it stays.

“Withdrawing consent does not affect any other provisions of this Biometric Policy.”

What you can do — Delete faces you no longer want stored by tapping the pencil icon next to that person's face in the app.

FaceFinder now costs money and skips your personal LibraryMINOR
OTHER

Face-based photo organizing is now limited to paying Plus Plan subscribers, and it only searches photos inside Groups. Pictures in your private Library won't show up in results, so the feature does less than the old description suggested.

“FaceFinder searches only photos and videos stored within your Groups; content in your personal Library is not included in FaceFinder results.”
Policy is now tied to the Groupsy serviceMINOR
OTHER

This biometric policy used to refer to Photobucket's services generally. It now names the Groupsy by Photobucket Services. If you use other Photobucket products, it's less clear that these biometric protections apply to them.

“handles Biometric Information in connection with the Groupsy by Photobucket Services ("Services")”

What you can do — If you use a Photobucket product other than Groupsy, email support@photobucket.com to ask which biometric policy covers it.

Changelog

  1. ± CHANGEDPolicy now covers the "Groupsy by Photobucket" service

    The policy used to apply to "its Services" generally. It now says it explains how Photobucket handles biometric data for the Groupsy by Photobucket Services. If you use other Photobucket products, it is less clear that this policy covers them.

    explains how Photobucket handles Biometric Information in connection with its Services.

    explains how Photobucket.com, Inc. ("Photobucket," "we," "our," or "us") handles Biometric Information in connection with the Groupsy by Photobucket Services ("Services").

  2. + ADDEDNew promise: your photos won't be used to train AI

    Photobucket added a clear statement that it does not use your photos or videos to train artificial intelligence, and repeated it in the disclosure section. It also expanded its no-sale promise to include "license."

    We do NOT use your photos or videos to train artificial intelligence.

  3. ± CHANGEDFaceFinder is now a paid Plus Plan feature and only searches Groups

    The face-organizing feature is now available only to Plus Plan subscribers, and it only looks at photos and videos inside your Groups. Photos in your personal Library are not included in the results.

    "FaceFinder Feature" refers to an optional feature that allows you to organize photos on your Device.

    The FaceFinder Feature is available exclusively to Plus Plan subscribers and is designed so that all facial detection and recognition processing occurs exclusively on your device using on-device computing resources.

  4. + ADDEDThe consent pop-up must now disclose four specific things

    The policy now lists exactly what the in-app consent screen has to tell you before you turn on FaceFinder: that face detection happens only on your device, that your photos and face data stay there, that Photobucket never receives or stores that data, and what the feature is for.

    The modal discloses: (a) that face detection occurs only on your device; (b) that your photos and any generated face data remain on your device; (c) that Photobucket does not receive, store, or access the face data generated on your device; and (d) that the feature is used to help organize your photos within your Groups.

  5. + ADDEDFaceFinder data is carved out of this policy's protections

    New language says that because face data never reaches Photobucket, the parts of this policy about collecting, storing, or profiting from biometric data simply don't apply to anything FaceFinder creates on your phone.

    Because no Biometric Information is transmitted to or received by Photobucket in connection with the FaceFinder Feature, the provisions of this Biometric Policy relating to Photobucket's collection, storage, or commercialization of Biometric Information do not apply to data generated by the FaceFinder Feature.

  6. − REMOVEDPromise to keep on-device face data only as long as needed was dropped

    The old policy said face data made by FaceFinder was kept only as long as necessary to run the feature. That sentence is gone. The new text just says the data stays on your device, and adds that withdrawing consent doesn't change anything else in the policy.

    Any Biometric Information generated in connection with the FaceFinder Feature is stored solely on your Device and remains under your control, and is retained only for as long as necessary to provide the feature.

    Withdrawing consent does not affect any other provisions of this Biometric Policy.

  7. ± CHANGEDHow to delete a face changed

    You used to remove a face from a "Manage Face" screen. Now you tap the pencil icon next to the person's face. The effect is the same: that face's data is deleted from your device.

    including by deleting a particular face from the "Manage Face" screen

    including by deleting a particular face by clicking on the pencil icon next to the applicable person's face

  8. + ADDEDPhotobucket says it isn't responsible for how you use FaceFinder on other people

    You were already responsible for getting permission to upload photos of others. New wording adds that Photobucket takes no responsibility at all for your use of FaceFinder on other people's faces.

    Photobucket is not responsible for your use of the FaceFinder Feature with respect to the Biometric Information of third parties.

  9. + ADDEDNew section about where you live

    A new section says Photobucket does not sell or profit from your content for users in any region, that it limits how much location data it keeps, and points you to support@photobucket.com with questions about your state or country's rules.

    ## 4\. REGION SPECIFIC RESIDENT DISCLOSURE

  10. + ADDEDDeleted content can stay in backups

    Photobucket still deletes your content within 30 days of a request, but it now warns that leftover copies can sit in its backup systems for an unspecified "limited period."

    Residual copies may remain in our backup systems for a limited period and will be deleted in the ordinary course.

  11. + ADDEDNew security disclaimer

    Photobucket still promises reasonable security measures, but now adds that it cannot guarantee your information is safe and lists break-ins and equipment failures as things that could expose it.

    However, we cannot guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your information at any time.

  12. ± CHANGEDFormatting, renumbering, and contact details

    Headings were converted to numbered sections with markdown formatting, definitions were merged into single paragraphs, sections were renumbered because a new section was inserted, "Device" became lowercase "device," and a mailing address in Denver, Colorado plus trademark notices were added.

    © 2026 Photobucket.com, Inc. All rights reserved.

    Our legal address is: 621 Kalamath Street, Suite 135 Denver, CO 80204 USA

Full text changes

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

1Effective Date: April 13, 2026
1Effective Date: August 11, 2026
22
31\. INTRODUCTION
3## 1\. INTRODUCTION
44
5Photobucket is committed to protecting your privacy and the security of your information. This Biometric Information Privacy Policy (the "Biometric Policy") explains how Photobucket handles Biometric Information in connection with its Services.
5Photobucket is committed to protecting your privacy and the security of your information. This Biometric Information Privacy Policy (the "Biometric Policy") explains how Photobucket.com, Inc. ("Photobucket," "we," "our," or "us") handles Biometric Information in connection with the Groupsy by Photobucket Services ("Services").
66
77This Biometric Policy should be read together with Photobucket's [Privacy Policy](https://photobucket.com/legal/privacy-policy), [Terms of Use](https://photobucket.com/legal/terms-of-service), and other applicable agreements (collectively, the "Agreements"). Capitalized terms not defined here have the meanings set forth in those Agreements.
88
9Photobucket does not collect, capture, or otherwise obtain biometric identifiers and does not use Biometric Information to identify individuals. Any biometric-related processing available through optional features is performed solely on your Device, under your control, and is not accessed or processed by Photobucket.
9Photobucket does not collect, capture, or otherwise obtain biometric identifiers and does not use Biometric Information to identify individuals. Any biometric-related processing available through optional features is performed solely on your device, under your control, and is not accessed or processed by Photobucket.
1010
11We store your photos and videos only to provide the hosting and cloud storage services you request. **Beyond that, Photobucket does NOT sell, lease, trade, or otherwise profit from the content you upload or your Biometric Information.**
11Photobucket does NOT sell, lease, trade, license, or otherwise profit from the content you upload or your Biometric Information. We do NOT use your photos or videos to train artificial intelligence.
1212
132\. DEFINITIONS
13## 2\. DEFINITIONS
1414
15Biometric Information
15### Biometric Information.
1616
17"Biometric Information" refers to data that depict or describe physical, biological, or behavioral traits, characteristics, or measurements of or relating to an identified or identifiable person's body.
17"Biometric Information" refers to data that depict or describe physical, biological, or behavioral traits, characteristics, or measurements of or relating to an identified or identifiable person's body. Biometric Information includes, but is not limited to, depictions, images, descriptions, or recordings of an individual's facial features, iris or retina, finger or handprints, voice, genetics, or characteristic movements or gestures (e.g., gait or typing pattern). Biometric Information also includes data derived from such depictions, images, descriptions, or recordings, to the extent that it would be reasonably possible to identify the person from whose information the data had been derived. By way of example, both a photograph of a person's face and a facial recognition template, embedding, faceprint, or other data that encode measurements or characteristics of the face depicted in the photograph constitute Biometric Information.
1818
19Biometric Information includes, but is not limited to, depictions, images, descriptions, or recordings of an individual's facial features, iris or retina, finger or handprints, voice, genetics, or characteristic movements or gestures (e.g., gait or typing pattern).
20
21Biometric Information also includes data derived from such depictions, images, descriptions, or recordings, to the extent that it would be reasonably possible to identify the person from whose information the data had been derived.
22
23By way of example, both a photograph of a person's face and a facial recognition template, embedding, faceprint, or other data that encode measurements or characteristics of the face depicted in the photograph constitute Biometric Information.
24
2519This definition is based on the Federal Trade Commission's Policy Statement on Biometric Information and is broader than certain legal definitions. Where applicable law defines biometric data more narrowly, those legal definitions control for purposes of compliance with that law.
2620
27FaceFinder Feature (On-Device Only)
21### FaceFinder Feature (Plus Plan, On-Device Only).
2822
29"FaceFinder Feature" refers to an optional feature that allows you to organize photos on your Device.
23"FaceFinder Feature" refers to an optional on-device feature available exclusively to Plus Plan subscribers that allows you to identify and organize photos within your Groups by the faces appearing in them, using on-device processing that you initiate and control. References in this Biometric Policy to "identifying" individuals through the FaceFinder Feature describe an action you take yourself, on your own device, for your own organizational purposes - not any identification performed by Photobucket. As described throughout this Biometric Policy, Photobucket itself does not use Biometric Information to identify individuals.
3024
31This feature operates entirely on-device. Photobucket does not receive or have access to any data generated by this feature.
25This feature operates entirely on your device. Photobucket does not receive or have access to any data generated by this feature. FaceFinder searches only photos and videos stored within your Groups; content in your personal Library is not included in FaceFinder results.
3226
333\. HOW WE HANDLE BIOMETRIC INFORMATION
27### Library.
3428
35User Uploaded Content
29"Library" refers to your personal private photo and video storage within the Services.
3630
37Photobucket allows you to upload, store, and manage photos and other content ("User Uploaded Content"), which may contain Biometric Information.
31### Groups.
3832
39Photobucket stores and processes this content solely to provide the Services you request. Photobucket acts only as a storage provider and does not independently analyze User Uploaded Content to identify individuals or extract biometric identifiers.
33"Groups" refers to the private, invite-only shared spaces within the Services where subscribers can upload, organize, and share photos and videos with invited Group Members.
4034
41On-Device Photo Organization
35### User Uploaded Content.
4236
43The Photobucket application may offer optional features that help you organize photos by grouping visually similar images and allowing you to apply labels (such as names).
37Our Services allow you to upload the most commonly-used image and video files to your Library or to a Group. These image files and video files, both in their native uploaded form and any subsequently edited version stored with the Services, are referred to individually and collectively as "User Uploaded Content."
4438
45These features:
39## 3\. HOW WE HANDLE BIOMETRIC INFORMATION
4640
47- are initiated and controlled by you;
48- operate solely on your Device; and
49- are not performed by Photobucket.
41### User Uploaded Content Storage.
5042
51Any labels, associations, or underlying data created through these features remain on your Device and are not accessible to Photobucket.
43Photobucket allows you to upload, store, and manage photos and other content ("User Uploaded Content") in your Library and in Groups, which may contain Biometric Information. Photobucket stores and processes this content solely to provide the Services you request. Photobucket acts only as a storage provider and does not independently analyze User Uploaded Content to identify individuals or extract biometric identifiers. Photobucket does not sell, lease, trade, license, or otherwise profit from User Uploaded Content or any Biometric Information it may contain.
5244
53FaceFinder Feature
45### FaceFinder Feature (On-Device Only).
5446
55If enabled, the FaceFinder Feature may assist you in organizing photos by detecting similarities between images on your Device.
47The FaceFinder Feature is available exclusively to Plus Plan subscribers and is designed so that all facial detection and recognition processing occurs exclusively on your device using on-device computing resources.
5648
5749This feature:
5850
59- operates locally on your Device;
60- generates data that remains under your control; and
61- does not transmit data to or make it accessible by Photobucket.
51- Is initiated and controlled solely by you;
52- Operates solely on your device;
53- Generates data that remains under your control and on your device; and
54- Does not transmit data to or make it accessible by Photobucket.
6255
63Consent and Control
56Any labels, associations, facial geometry measurements, faceprints, or other data created through the FaceFinder Feature remain on your device and are not accessible to Photobucket or any third party through Photobucket. Because no Biometric Information is transmitted to or received by Photobucket in connection with the FaceFinder Feature, the provisions of this Biometric Policy relating to Photobucket's collection, storage, or commercialization of Biometric Information do not apply to data generated by the FaceFinder Feature.
6457
58### FaceFinder (Consent and Control).
59
6560The FaceFinder Feature is optional and subject to your control.
6661
67You must provide your express consent before using the FaceFinder Feature for the first time on a Device. This consent is obtained through an in-application consent modal presented when you enable the feature.
62You must provide your express consent before using the FaceFinder Feature for the first time on a device. This consent is obtained through an in-application consent modal presented when you enable the feature. The modal discloses: (a) that face detection occurs only on your device; (b) that your photos and any generated face data remain on your device; (c) that Photobucket does not receive, store, or access the face data generated on your device; and (d) that the feature is used to help organize your photos within your Groups.
6863
69Once consent has been provided on a Device, Photobucket will not request the same consent again for subsequent uses of the FaceFinder Feature on Devices associated with your Account, unless your consent has been withdrawn or there is a material change to this Biometric Policy or to the operation of the feature.
64Once consent has been provided on a device, Photobucket will not request the same consent again for subsequent uses of the FaceFinder Feature on devices associated with your Account, unless your consent has been withdrawn or there is a material change to this Biometric Policy or to the operation of the feature.
7065
71You may withdraw your consent at any time through controls available within the application, including by deleting a particular face from the "Manage Face" screen. Deleting a face will disable the FaceFinder Feature for that face and will remove the associated facial recognition data for that face from your Device. Any Biometric Information generated in connection with the FaceFinder Feature is stored solely on your Device and remains under your control, and is retained only for as long as necessary to provide the feature.
66You may withdraw your consent at any time through controls available within the application, including by deleting a particular face by clicking on the pencil icon next to the applicable person's face. Deleting a face will disable the FaceFinder Feature for that face and will remove the associated facial recognition data for that face from your device. Withdrawing consent does not affect any other provisions of this Biometric Policy.
7267
73Responsibility for Third-Party Content
68### Responsibility for Third-Party Content.
7469
75If your content includes images of other individuals, you are responsible for ensuring that your use complies with applicable laws, including obtaining any required permissions or consents.
70If your content includes images of other individuals, you are responsible for ensuring that your use complies with applicable laws, including obtaining any necessary permissions or consents. Photobucket is not responsible for your use of the FaceFinder Feature with respect to the Biometric Information of third parties.
7671
774\. RETENTION AND STORAGE
72## 4\. REGION SPECIFIC RESIDENT DISCLOSURE
7873
79Photobucket retains User Uploaded Content that may contain Biometric Information only for as long as you maintain an active Account or as necessary to provide our Services. If you request the deletion of your Account or specific User Uploaded Content, Photobucket will delete such information within thirty (30) days, unless a legal obligation requires Photobucket to retain it. Because optional biometric processing (such as facial grouping) occurs solely on your Device, Photobucket does not store or retain that data on its servers.
74Photobucket does not sell, lease, trade, license, or otherwise profit from User Uploaded Content or any Biometric Information it may contain, for any user in any region. Out of respect for your privacy, Photobucket limits the amount of geolocation information it possesses. If you have questions about how your information is handled based on your state or country of residence, please contact us at support@photobucket.com or update your user profile once logged into your Account.
8075
815\. DISCLOSURE
76## 5\. RETENTION AND STORAGE
8277
83Photobucket does not sell, lease, or otherwise disclose Biometric Information for commercial purposes.
78Photobucket retains User Uploaded Content that may contain Biometric Information only for as long as you maintain an active Account or as necessary to provide our Services. If you request the deletion of your Account or specific User Uploaded Content, Photobucket will delete such information within thirty (30) days, unless a legal obligation requires Photobucket to retain it. Residual copies may remain in our backup systems for a limited period and will be deleted in the ordinary course.
8479
80Because the FaceFinder Feature operates solely on your device, Photobucket does not store or retain any facial recognition data, faceprints, facial geometry, or other Biometric Information generated by that feature on its servers. As a result, there is no Biometric Information associated with the FaceFinder Feature for Photobucket to retain, protect, or disclose to third parties.
81
82## 6\. DISCLOSURE
83
84Photobucket does not sell, lease, trade, license, or otherwise disclose Biometric Information for commercial purposes. We will never use your photos or videos to train artificial intelligence.
85
8586We may disclose User Uploaded Content only:
8687
8788- at your direction;
8889- as necessary to provide the Services, as further described in the Photobucket Privacy Policy; or
8990- as required by law.
9091
916\. DATA SECURITY
92## 7\. DATA SECURITY
9293
93Photobucket implements reasonable administrative, technical, and organizational measures designed to protect User Uploaded Content, including any Biometric Information it may contain.
94Photobucket implements reasonable administrative, technical, and organizational measures designed to protect User Uploaded Content, including any Biometric Information it may contain. However, we cannot guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your information at any time.
9495
957\. LEGAL COMPLIANCE
96## 8\. LEGAL COMPLIANCE
9697
97This Biometric Policy is intended to comply with applicable laws governing biometric information.
98This Biometric Policy is intended to comply with applicable laws governing biometric information. Certain laws, such as the Illinois Biometric Information Privacy Act ("BIPA"), regulate biometric identifiers and information used for identification purposes. Photobucket does not collect or possess biometric identifiers and does not use Biometric Information to identify individuals. To the extent optional features involve on-device processing, Photobucket provides appropriate disclosures and obtains user consent, and such processing remains under your control.
9899
99Certain laws, such as the Illinois Biometric Information Privacy Act ("BIPA"), regulate biometric identifiers and information used for identification purposes. Photobucket does not collect or possess biometric identifiers and does not use Biometric Information to identify individuals.
100
101To the extent optional features involve on-device processing, Photobucket provides appropriate disclosures and obtains user consent, and such processing remains under your control.
102
103100Nothing in this Policy is intended to expand or limit any rights or obligations under applicable law.
104101
1058\. CHANGES TO THIS POLICY
102## 9\. CHANGES TO THIS POLICY
106103
107Photobucket may update this Biometric Policy from time to time. The current version of this Biometric Policy will always be available on Photobucket's website. You are responsible for reviewing this Biometric Policy periodically to stay informed of any changes. Continued use of the Services - including storing photos or otherwise maintaining an account - following any update constitutes acceptance of the revised Biometric Policy. This Biometric Information Privacy Policy supersedes all prior versions of the Photobucket Biometric Information Privacy Policy. The current version will always be available on Photobucket's website and through the Services.
104Photobucket may update this Biometric Policy from time to time. The current version of this Biometric Policy will always be available on Photobucket's website and through the Services. You are responsible for reviewing this Biometric Policy periodically to stay informed of any changes. Continued use of the Services following any update constitutes acceptance of the revised Biometric Policy. This Biometric Information Privacy Policy supersedes all prior versions of the Photobucket Biometric Information Privacy Policy.
108105
1099\. CONTACT
106## 10\. CONTACT
110107
111If you have any questions about this Biometric Policy, please contact:
108If you have any questions about this Biometric Policy, please contact: [support@photobucket.com](mailto:support@photobucket.com)
112109
113[support@photobucket.com](mailto:support@photobucket.com)
110Our legal address is: 621 Kalamath Street, Suite 135 Denver, CO 80204 USA
114111
115© 2026 Photobucket.com, Inc. All rights reserved.
112© 2026 Photobucket.com, Inc. All rights reserved. Photobucket is a registered trademark and Groupsy is a trademark of Photobucket.com, Inc.