Face Matching Tool Data Statement

Last Updated: February 2026

This Face Matching Tool Data Statement (“Statement”) explains how Candid Color Systems, Inc. (“CCS,” “we,” “us,” or “our”) facilitates the optional Face Matching feature available through certain CCS-owned brands and platforms, including NowCandid, Team Photo Network, Grad Photo Network, Oklahoma Party Pics, and other CCS-operated services.

This Statement supplements our Privacy Policy and Biometric Information Policy.

1. Overview of the Face Matching Tool

The Face Matching Tool is an optional feature that allows event participants to locate photographs in which they appear.

When enabled by the photographer or studio account:

  • Event images are analyzed using automated technology.
  • The system identifies relationships between images that appear to contain the same individual.
  • The feature allows users to more easily locate their images within an event gallery.

The Face Matching Tool is provided by a third-party technology vendor under contract with CCS.

2. How the Technology Works

When the Face Matching Tool is used:

  1. Images are transmitted to a third-party vendor.
  2. The vendor analyzes facial geometry using artificial intelligence.
  3. The vendor generates image relationship data (i.e., which images likely depict the same person).
  4. The vendor returns only image relationship results to CCS.
  5. CCS uses those relationships to power search and grouping functionality.

CCS does not receive or retain biometric templates.

3. Biometric Identifiers and Biometric Information

During processing, the third-party vendor may create biometric identifiers or biometric information (for example, scans of facial geometry) in order to perform the analysis.

Important distinctions:

  • CCS does not create, store, or maintain biometric templates.
  • CCS does not receive biometric templates from the vendor.
  • CCS receives only image relationship metadata.
  • CCS does not sell, lease, trade, or otherwise profit from biometric identifiers.

Any biometric identifiers created are controlled by the vendor and subject to contractual restrictions governing retention and destruction.

4. Retention and Destruction

Biometric processing occurs only for the limited purpose of generating image relationships.

CCS requires its Face Matching vendor to:

  • Use biometric data solely for providing the Face Matching service.
  • Retain biometric data only as long as necessary to complete the matching process.
  • Destroy biometric identifiers in accordance with applicable law and contractual obligations.

Where required by law (including Illinois BIPA), biometric data must be destroyed at the earlier of:

  • When the initial purpose for collection has been satisfied, or
  • Within the legally required time period (e.g., three years after the individual’s last interaction).

CCS does not maintain independent biometric retention systems.

5. Consent Requirements

Face Matching is enabled only:

  • When a Studio elects to enable the feature; or
  • When a CCS-owned studio brand enables it for an event.

Where required by applicable law:

  • The Studio (if independent) is responsible for obtaining legally required written consent from individuals before biometric processing.
  • When CCS operates the event directly, CCS is responsible for obtaining legally required consent.

Individuals may decline participation in Face Matching where required by law.

6. No Advertising or Secondary Use

Biometric data processed in connection with Face Matching:

  • Is not used for advertising.
  • Is not used for profiling unrelated to image search.
  • Is not sold.
  • Is not shared for cross-context behavioral advertising.
  • Is not used for unrelated analytics.

The sole purpose is enabling individuals to locate their photographs.

7. Security Measures

CCS requires its Face Matching vendor to implement reasonable administrative, technical, and physical safeguards designed to protect biometric data from:

  • Unauthorized access
  • Unauthorized disclosure
  • Misuse
  • Alteration

Access to image relationship results within CCS systems is restricted to authorized personnel.

8. Your Rights

Depending on your state of residence, you may have the right to:

  • Request access to personal information.
  • Request deletion of personal information.
  • Request information about biometric processing.
  • Withdraw consent where permitted by law.

Requests may be submitted to:

ccssupport@candid.com

We may verify your identity before fulfilling requests.

If CCS is acting as a service provider on behalf of an independent Studio, we may forward your request to the Studio for handling.

9. Interaction With Privacy Policy

This Face Matching Tool Data Statement:

  • Supplements our Privacy Policy.
  • Supplements our Biometric Information Policy.
  • Does not modify your rights under applicable privacy or biometric laws.

In the event of a conflict between this Statement and applicable law, applicable law governs.

10. Contact Information

For questions about Face Matching or biometric processing, contact:

Candid Color Systems, Inc.

Email: ccssupport@candid.com

1300 Metropolitan Ave

Oklahoma City, OK 73108