Last updated: September 25, 2026
1. About this policy
This policy explains how Ovis (“Momentli”, “we”) collects, uses, stores and destroys biometric data as part of the Momentli face recognition feature. It supplements our Privacy Policy and Terms of Service, and is intended to meet the requirements of the Israeli Privacy Protection Law, 5741-1981, the GDPR and US state biometric privacy laws, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI) and Washington’s biometric identifiers law.
This policy is published in Hebrew and in English. In case of conflict, the Hebrew version prevails.
2. What biometric data we process
“Biometric data” in this policy means face geometry data: a numerical representation (a “face vector”) calculated from the features of a face in an image. A face vector is not a photo, and we do not use it to recreate one.
We create face vectors from two sources:
- Selfies taken by Guests who choose to register for face recognition.
- Faces that appear in Event photos uploaded by Guests or the Host. Every face visible in an uploaded photo is converted to a vector, because this is how we find the photos in which a registered Guest appears.
We also store the selfie itself and the resulting matches (which photos a registered Guest appears in).
3. The sole purpose: matching guests to photos within one Event
We use biometric data for one purpose only: to find the photos from a specific Event in which a registered Guest appears, so that we can send that Guest a personal link and show them their photos in the “find me” filter.
- Faces are compared only within the same Event. Each Event has its own separate face collection, and we never search for a face across Events or outside the Service.
- We do not use biometric data to identify people by name, to verify identity, to profile, to track, or to infer any characteristic (such as age, gender, ethnicity or emotion).
4. Notice and explicit consent
- Before taking a selfie, the Guest is shown written notice explaining what data is collected, why, how long it is kept and how to withdraw consent, with a link to this policy.
- The Guest must give explicit, active opt-in consent before the selfie is taken and processed. We do not use pre-ticked boxes.
- The selfie step is optional. A Guest who skips it can still upload photos and browse the gallery, but face matching will not be performed for them and they will not receive an SMS with their photos.
- Guests under 18 may register for face recognition only with the consent of a parent or guardian.
5. People who appear in photos but did not register
Photos uploaded at an Event may include people who did not register. Their faces are converted to vectors only so that they can be compared with the selfies of registered Guests within that Event’s collection.
- These vectors are never linked to a name, phone number or any other identifying detail, and are not used for any other purpose.
- They are deleted together with the Event’s collection, as described in section 9.
- Anyone who does not want to appear in an Event’s photos may contact the Host, or write to privacy@momentli.co.il to request removal of photos and face data (see section 10).
The Host is responsible for informing attendees about photo sharing and face recognition at the Event, including by displaying the QR notice sign (see section 11).
6. No sale, no advertising, no AI training
We never sell, lease, trade or otherwise profit from biometric data. We do not use it for advertising or marketing, and we do not use it (or allow anyone to use it) to train artificial intelligence or machine learning models.
7. Disclosure
We do not disclose biometric data to any third party except:
- Amazon Web Services (AWS), our processor, which performs face indexing and matching through the Amazon Rekognition service on our behalf and according to our instructions only; and
- where disclosure is required by law, by a valid court order or by a competent authority.
Hosts and Guests do not receive face vectors. They see only the result: which photos a registered Guest appears in.
8. Where and how data is stored
- Face vectors are stored in AWS Rekognition in the il-central-1 region (Tel Aviv, Israel), in a separate collection for each Event.
- Data is encrypted in transit and at rest.
- Access is restricted to authorized personnel on a need-to-know basis.
- Selfies are stored encrypted in our storage infrastructure together with the Event’s data.
9. Retention and destruction schedule
We keep biometric data only as long as needed for the purpose for which it was collected, and destroy it at the earliest of the following:
| Event | When destroyed |
|---|---|
| The plan’s storage period for the Event ends | When the storage period ends (1 to 12 months, depending on the plan, and no later than 12 months after the Event) |
| The Host deletes the Event | When the Event is deleted |
| A Guest withdraws consent or asks for deletion | Within 30 days of the request |
| In any case | No later than 3 years after the Guest’s last interaction with the Service |
When the Event’s face collection is deleted, all face vectors in it (from selfies and from photos) are destroyed together with the selfies and matches. Remaining copies in backups are deleted within 30 days.
10. Withdrawing consent and deletion requests
You may withdraw your consent at any time. To do so, email privacy@momentli.co.il with:
- The name of the Event (and, if possible, the Event link).
- The phone number you registered with.
We may ask for additional details to confirm the request comes from you. After withdrawal, we will delete your selfie, your face vector and your matches within 30 days, and you will no longer receive face matching for that Event. Withdrawal does not affect processing performed before it.
People who did not register but appear in photos can also ask us to delete photos in which they appear and the related face data.
11. Host duties
A Host who uses Momentli at an Event undertakes to:
- Display the QR sign (or an equivalent notice) in visible places at the Event, including the text we provide about photo sharing and face recognition.
- Inform attendees in advance, where possible, that photos will be shared through Momentli and that face recognition will be used for Guests who choose to register.
- Obtain any consent required by law, including from parents or guardians of minors, and honor requests from attendees who do not want to be photographed or matched.
- Not use the Service or its results to identify people outside the Event or for any purpose other than sharing Event photos.
12. Security
We protect biometric data using a reasonable standard of care that is at least as protective as the way we protect our other confidential and sensitive information, including encryption, access control, per-Event separation, logging and monitoring, and contractual obligations with our processor. If a security incident affects biometric data, we will notify the relevant authorities and affected people as required by law.
13. Changes
We may update this policy from time to time. The updated version will be published on this page with an updated date. We will not use biometric data for any new purpose without obtaining new consent.
14. Contact us
Ovis, company / ID number [COMPANY / ID NUMBER] [REGISTERED ADDRESS]
- Biometric and privacy matters: privacy@momentli.co.il
- General support: support@momentli.co.il