Privacy Policy

We process personal data of four groups of individuals:

• Buyers: Individuals who search for and purchase event photos via guest checkout.
• Photo Subjects: Individuals who appear in event photos uploaded to the Platform.
• Photographers: Individuals who upload and sell event photos.
• Organizers: Event organizers who partner with Fokus for event coverage.

2.1 From Buyers.

• Checkout Data: First Name, Last Name, and Email Address (used solely for delivery of Digital Products and receipts).
• Search Data: The selfie image submitted for “Search by Selfie” and any bib numbers entered for search.

2.2 About Photo Subjects.

• Images: Event photos containing your likeness, uploaded by Photographers.
• Biometric Templates: Numerical facial geometry derived from photos to enable matching.

2.3 From Photographers (KYC).

• Identity: Full legal name and one (1) valid government-issued ID.
• Contact: Verifiable geographic address, mobile number, and email.
• Financial: Bank or e-wallet details for payouts.

2.4 Payment Information. All payments are processed by PayMongo. Fokus does not store credit card or payment credentials on its servers.

3.1 Explicit Consent. Search by Selfie is voluntary. By uploading a selfie, you provide explicit consent to the processing of your biometric data solely for matching your likeness with Photos in the gallery.

3.2 Processing for Platform Improvement. As stated in our Terms of Service, by uploading a selfie you provide explicit consent for the Platform to process and utilize the submitted image and derived templates to provide and improve our search and matching functionality. The Platform does not claim ownership of your personal images.

3.3 Data Retention. To support platform improvements and facilitate follow-up search results, search selfies and their derived biometric templates are retained for the duration of the event gallery’s availability or until you manually request their deletion, after which they are permanently deleted.

3.4 No Sale of Data. We do not sell, trade, or share biometric data with third parties for marketing or profiling purposes.

4.1 Lawful Basis for Processing. Our lawful basis for indexing faces in event photos is Legitimate Interest (Section 12(f), R.A. 10173). We have a legitimate interest in providing a searchable marketplace for participants to find their photos, which is balanced by our commitment to privacy and your right to removal.

4.2 Right to Removal. If you appear in a photo and wish for it to be removed, you may request removal at any time, free of charge, by emailing compliance@fokus.ph.

• Expedited Action: We act on valid requests within 24–48 hours for clear cases.
• Effect: Upon removal of a photo, all associated facial index data is also permanently deleted.

• Photographers: See anonymized sales reports (e.g., “5 photos sold”). They do not see Buyer names or contact details.
• Organizers: Receive aggregate event-level summaries (e.g., total sales volume).
• Authorities: We may disclose Photographer KYC data to the DTI, NPC, or law enforcement upon a valid subpoena or as required by R.A. 11967.

Under the Data Privacy Act, you have the right to:

• Access: Request a copy of the data we hold about you.
• Object: Object to the processing of your data.
• Erasure: Request the deletion of your data.
• Complaint: Lodge a complaint with the National Privacy Commission (NPC).

To exercise these rights, contact our Data Protection Officer at compliance@fokus.ph.

8.1 Guardian Consent. We do not knowingly collect or process the personal data of individuals under 18 (“Minors”) without the consent of a parent or legal guardian, as required by our Terms of Service. Where a Minor uses the Platform — including the Search by Selfie feature — the parent or guardian is responsible for providing any consent required for the processing of the Minor’s personal and biometric data.

8.2 Removal. If we become aware that we have processed a Minor’s personal data without the required consent, we will take steps to delete that information. A parent or guardian may request such deletion by emailing compliance@fokus.ph.

We implement organizational, physical, and technical security measures, including:

• Encryption: All data is transmitted via HTTPS and sensitive IDs are encrypted at rest.
• Watermarking: All preview images are protected by visible and invisible watermarks.
• Access Control: Role-based access ensures only authorized staff can view sensitive KYC data.

We may update this policy to reflect changes in law or platform functionality. The “Last Updated” date at the top will reflect the most recent version.