Terms of Use

These terms of use apply 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.

Upon downloading or utilizing the Application, you are automatically agreeing to the following terms. It is strongly advised that you thoroughly read and understand these terms before using the Application.

Usage Restrictions

Unauthorized copying, modification of the Application, any part of the Application, or our trademarks is strictly prohibited. Any attempts to:

• Extract the source code of the Application
• Translate the Application into other languages
• Create derivative versions

are not permitted. All trademarks, copyrights, database rights, and other intellectual property rights related to the Application remain the property of the Service Provider.

Modifications & Charges

The Service Provider is dedicated to ensuring that the Application is as beneficial and efficient as possible. As such, they reserve the right to modify the Application or charge for services at any time and for any reason. However, the Service Provider assures that any charges for the Application or its services will be clearly communicated to users.

Data & Security

The Application stores and processes personal data that you have provided, including photos and images you upload, in order to provide the Service. It is your responsibility to maintain the security of your phone and access to the Application.

The Service Provider strongly advises against jailbreaking or rooting your phone, as this:

• Removes software restrictions imposed by the operating system
• Can expose your phone to malware, viruses, and security threats
• May result in the Application not functioning correctly or at all

Photo Storage & Privacy

Your photos are stored securely on our servers and remain private. They are never published publicly, sold to third parties, or used for any purpose other than providing you with the Application's services—specifically, allowing you to organize and share your photos with the specific contacts you choose. Your photos are never used to train AI models, build facial recognition databases, perform facial analysis, or for any automated processing beyond providing the Application's photo sharing services.

Face Data and Photo Processing

Photos you upload 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. Any face data contained within your photos is not sold, shared with advertisers, used for facial recognition, or disclosed to any third parties except as described in our Privacy Policy. 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.

Contacts Access

If you grant the Application access to your device's Contacts list, this information will be used solely to help you find and share albums with friends and family. We do not store your entire contacts list on our servers and do not share this information with third parties. You may revoke this permission at any time through your device's settings.

Age Restrictions

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.

In-App Purchases and Subscriptions

The Application offers in-app purchases (IAPs) and subscription-based services, facilitated through third-party payment processors.

• Any purchases made within the Application are final and non-refundable, except where required by applicable law.
• The Service Provider is not responsible for transaction issues, failed payments, or unauthorized charges.
• Users are responsible for managing their subscription settings through their respective app store accounts (e.g., Apple App Store or Google Play Store).
• The Service Provider cannot modify, cancel, or refund subscriptions on behalf of users.
• Subscription terms, including renewal policies and cancellations, are governed by the respective app stores' policies.

Connectivity & User Responsibility

Some functions of the Application require an active internet connection, which can be Wi-Fi or mobile data. The Service Provider cannot be held responsible if the Application does not function at full capacity due to:

• Lack of Wi-Fi or mobile data
• Exhausted data allowance

If you are using the Application outside a Wi-Fi area, please be aware:

• Your mobile network provider's agreement terms still apply
• You may incur charges from your mobile provider for data usage
• Roaming data charges may apply if you use the Application outside of your home territory without disabling data roaming

If you are not the bill payer for the device on which you are using the Application, it is assumed that you have obtained permission from the bill payer.

Limitation of Liability

The Service Provider strives to keep the Application updated and accurate, but they rely on third-party data sources. As such, the Service Provider accepts no liability for any loss, direct or indirect, that you experience as a result of relying on the Application's functionality.

Application Updates & Termination

The Service Provider may update the Application at any time.

• You must download updates to continue using the Application.
• The Service Provider does not guarantee that updates will always be relevant to you or compatible with your device.
• You agree to accept updates when offered.

The Service Provider may discontinue the Application at any time without notice. Unless informed otherwise, upon termination:

• Your rights and licenses granted under these terms will end.
• You must stop using the Application and delete it from your device if necessary.

Changes

The Service Provider may periodically update these Terms and Conditions. You are advised to review this page regularly for any changes.

The Service Provider will notify users of changes by updating this page with the new Terms and Conditions.

These Terms and Conditions are effective as of 2026-02-22.

Contact

If you have any questions or suggestions about these Terms and Conditions, please contact the Service Provider at keepsapp@bytortuga.com.

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