Privacy Policy

This privacy policy applies to the Keeps app (hereby referred to as "Application") for mobile devices that was created by Tortuga Labs, LLC (hereby referred to as "Service Provider"). This Application is a consumer-facing service that allows users to create and share private photo albums with their closest friends and family. It is a commercial product, meaning it may offer in-app purchases and subscriptions. Users are permitted to use the app for personal purposes but may not redistribute.

Face Data and Photo Processing

What Face Data We Collect

When you upload photos to Keeps, those photos may contain images of faces, including the faces of children and family members. The Application does not extract, analyze, or store facial geometry, biometric identifiers, or facial feature maps from your photos. We store only the image files themselves as you uploaded them.

How Face Data Is Used

Your photos—including any faces they contain—are used exclusively to create and share private photo albums with the contacts you choose. Your photos are never used to train AI models, build facial recognition databases, perform facial analysis, or for any purpose other than providing the Application's photo sharing services.

Face Data Sharing

Your photos and any face data they contain are not sold, shared with advertisers, used for facial recognition, or disclosed to any third parties except as described in the Data Disclosure section below.

Face Data Retention

We do not extract, store, or retain any facial geometry, biometric identifiers, or face data from your photos. The photos themselves are retained as described in the Data Retention Policy section below. If you delete a photo from the Application or request deletion of your data, the photo and any face data it contains will be removed.

Information We Collect

Keeps collects photos and images that you voluntarily upload to the Application. These images are used solely to create and share private photo albums with the contacts you choose. Your photos are stored securely on our servers and are kept private—they are never published publicly or used for any purpose other than sharing with the specific people you select.

Contacts Access: To help you easily share photo albums with your closest friends and family, the Application may request access to your device's Contacts list. This information is used only to suggest contacts for album sharing and to facilitate the sharing process. We do not store your entire contacts list on our servers, and we do not share this information with third parties.

How We Use Your Information

The Application collects information when you download and use it. This information may include:

• Your device's Internet Protocol address (e.g. IP address)
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• The operating system you use on your mobile device

Image Usage: The photos you upload are used exclusively to create private photo albums that you can share with selected contacts. Your images are never published publicly, are not sold to third parties, and are not used for any purpose other than providing you with the ability to organize and share your photos with the people you choose.

Contacts Usage: If you grant access to your Contacts list, this information is used only to help you find and share albums with your friends and family. We do not use your contacts data for marketing purposes or share it with third parties.

The Service Provider may use the information you provide to contact you from time to time to provide you with important information, required notices, and marketing promotions.

For a better experience while using the Application, the Service Provider may require you to provide certain personally identifiable information. The information that the Service Provider requests will be retained by them and used as described in this privacy policy.

Data Disclosure

The Service Provider may disclose User Provided and Automatically Collected Information:

• As required by law, such as to comply with a subpoena or similar legal process.
• When they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• With their trusted service providers who work on their behalf, do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement.

Opt-Out Rights

You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes available on your mobile device or via the mobile application marketplace or network.

If you have granted access to your Contacts list, you may revoke this permission at any time through your device's settings.

Data Retention Policy

The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. If you'd like them to delete User Provided Data that you have provided via the Application, please contact them at keepsapp@bytortuga.com, and they will respond in a reasonable time.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.

The Application does not address anyone under the age of 13, and the Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. If the Service Provider discovers that a child under 13 has provided personal information, they will immediately delete it from their servers.

If you are a parent or guardian and are aware that your child has provided personal information, please contact the Service Provider at keepsapp@bytortuga.com so they can take the necessary actions.

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. They provide physical, electronic, and procedural safeguards to protect the information they process and maintain. Your uploaded images are stored securely and are protected using industry-standard security measures. Your photos remain private and are only accessible to you and the contacts with whom you explicitly choose to share them.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes by updating this page with the new Privacy Policy.

You are advised to review this Privacy Policy regularly for any updates, as continued use of the Application is deemed approval of all changes.

This Privacy Policy is effective as of 2026-02-22.

Your Consent

By using the Application, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended in the future.

Contact Us

If you have any questions regarding privacy while using the Application or have concerns about data practices, please contact the Service Provider via email at keepsapp@bytortuga.com.

For more information about Tortuga Labs, LLC, please visit www.bytortuga.com.