Last Updated: December 2025
1. Introduction and Scope
As Picsolv Anonim Şirketi ("Picsolv" or the "Company"), we attach great importance to the protection of personal data of our users ("User" or "Data Subject") who benefit from the services we provide through the www.picsolv.com website and mobile applications (the "Platform").
This Privacy Policy has been prepared to transparently explain the processes regarding the personal data collected, processed, stored and transferred by Picsolv within the scope of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), the European General Data Protection Regulation ("GDPR") and other applicable legislation.
In particular, due to the AI-powered photo matching, face recognition and image enhancement services offered by Picsolv, detailed information on how your biometric data and visual data are processed is a key focus of this policy.
2. Your Personal Data We Process
Our Company processes your data in the categories set out below by the nature of our services:
2.1. Identity and Contact Information
- First name, last name.
- Email address, phone number.
- Date of birth (where age verification is required).
2.2. Visual and Biometric Data (Special Category Personal Data)
For photo matching and analysis operations that form the basis of Picsolv services:
- Facial Biometrics: Numerical data containing a mathematical map of your face (face template/embedding) obtained from the "selfie" or reference photos you upload. This data is used to find you in event photos.
- Photographs: Photos taken at events or uploaded to the system, in which you or other persons appear.
- Liveness Test Data: Instant image and facial movement data during camera scanning performed to verify that you are a real person.
2.3. Transaction and Security Information
- User ID, password (in hashed form).
- Log records, IP address, device information (Device ID), browser type.
- Last login date/time information.
2.4. Event and Behavioural Analytics Data
- Events you participate in, photos you add to favourites.
- Photo download and sharing habits.
- In-platform navigation (clicks, page views).
3. Purposes of Processing Personal Data
Your collected data is processed for the following purposes:
- Service Delivery: Scanning faces in event photos with your uploaded selfie using Artificial Intelligence (AI) algorithms (e.g. AWS Rekognition, Google AI) and finding and matching photos that belong to you.
- Image Enhancement: Where you request it, enhancing low-resolution or degraded photos using AI technologies (e.g. AWS Bedrock, Generative AI).
- Security and Verification: Performing liveness checks to secure your account and prevent fake accounts.
- Analytics and Reporting: Creating anonymised statistical reports for event organisers on participant demographics (estimated age, gender, etc.) and event interactions.
- Legal Obligations: Keeping log records in accordance with Law No. 5651 and related legislation.
4. Processing of Biometric Data and Use of AI
Picsolv uses advanced artificial intelligence and machine learning technologies to provide the photo matching service.
- Face Recognition Technology: Your reference photo uploaded to the system is analysed through services such as AWS Rekognition and a numerical vector (template) of your face is created. This vector is compared with event photos in our database to find matches.
- Storage: Instead of your original biometric data (raw face data), encrypted numerical codes derived from it that cannot be converted back into a face image by reverse engineering are stored.
- Consent: The processing of your biometric data is carried out on the basis of your Explicit Consent in accordance with KVKK Article 6. The explicit consent you give when you start using the application is the legal basis for this processing.
5. Transfer of Personal Data and International Transfer
Picsolv works with technology partners whose servers and infrastructure providers are located abroad in order to provide services to global standards.
- International Transfer: Your data (photos and numerical data derived from them) is stored and processed on Amazon Web Services (AWS - Ireland/Germany/USA) and Google Cloud Platform servers with high security standards. This transfer is carried out on the basis of the consent you give in the Explicit Consent Form.
- Business Partners: With event organisers, only data relating to that event and to which you have allowed access or anonymised statistical data is shared.
- Authorities: Sharing may be made with authorised public bodies where there is a court order or legal obligation.
6. Data Security
Our Company takes industry-standard measures for the security of your data:
- All data transfers are carried out with SSL/TLS encryption.
- Sensitive data (passwords, biometric templates) in databases is stored encrypted.
- Access rights are restricted and regular security testing is carried out.
7. Data Retention and Deletion
- Your personal data is retained for as long as your membership continues or for the statutory retention periods provided for in the relevant legislation.
- When you delete your membership or withdraw your explicit consent, your biometric data and photos are permanently deleted from the system or anonymised, except for log records that must be retained by law.
8. Your Rights as Data Subject
In accordance with KVKK Article 11:
- To learn whether your data is being processed,
- To request information if it has been processed,
- To learn the purpose of processing and whether it is used for that purpose,
- To know the third parties to whom it has been transferred domestically or abroad,
- To request correction if processing is incomplete or incorrect,
- To request deletion or destruction of data (right to be forgotten),
- To object to results that are against your interests and to request compensation for damage,
you have these rights.
To exercise these rights (including the right to request deletion of your data), contact us at hello@picsolv.com.
9. Contact Us
Data Controller: Picsolv Anonim Şirketi
Address: Istanbul, Turkey
Email: hello@picsolv.com
For any request regarding your personal data, privacy or this policy, please email us at hello@picsolv.com.