Privacy Policy

1. Who is responsible

Occur is responsible for the processing described in this Policy. For privacy questions or requests, contact [email protected].

Organizers and participants separately decide which people to photograph, what to upload, whom to invite and how to use downloaded copies. They are responsible for their own notices, permissions and lawful use. Depending on the circumstances, a business organizer may have its own data-protection obligations. That does not remove responsibilities that apply to Occur's own processing.

2. Information we handle

Information depends on the experience and features you use. Some information comes directly from you; some comes from your device, an authentication or purchase provider, an organizer, another participant or someone making a report.

• Accounts and access: display name, email address where supplied, internal account or guest identifiers, sign-in provider identifiers and authentication records. Guest sessions can be linked to a name, device session and Event even without a verified email.
• Events and content: photos and covers you submit, Event title, occasion, dates and time zone, visibility and reveal choices, invitation identifiers, participation records, photo authorship and upload or capture times.
• Embedded information: original photo files may include metadata such as device details, capture time and, if already embedded in a file, location. Not requesting a location permission does not establish that every uploaded original is free of location metadata. Photos themselves may reveal people, places and sensitive circumstances.
• Purchases: product and transaction identifiers, purchase status, receipts or verification information and Event entitlements. Apple handles payment credentials; Occur does not receive your full payment-card number.
• Technical information: IP address, browser or device and operating-system details, access or session information, requests, security information and error or diagnostic records generated in providing the Service.
• Usage and attribution: interactions such as sign-in, Event setup, capture, upload and purchase events; app or installation identifiers; and an internal account identifier associated with analytics. Where permitted, attribution can associate an installation or purchase with a marketing source.
• Notifications and communications: a device push token when you authorize push notifications and the feature is used; support correspondence, privacy requests, content reports and information necessary to investigate or respond.

We do not request access to your address book or microphone, run facial recognition to identify people or create biometric identification templates. We do not need a precise device-location permission for the shared camera. Do not upload identity documents, confidential records or unnecessary sensitive information. This does not mean that ordinary photos are inherently anonymous or cannot contain sensitive information.

3. Why we use information

• Provide accounts and guest access, create and join Events, apply settings, accept uploads, show authorized galleries, apply camera styles and provide downloads.
• Verify purchases, apply paid Event options, prevent duplicate or fraudulent use and assist with purchase or refund problems.
• Secure accounts and infrastructure, diagnose failures, maintain reliability, investigate specific abuse reports, protect people's rights and enforce lawful rules.
• Answer requests and send necessary account, purchase, safety, retention or service communications through available channels.
• Understand product usage and, where permitted, measure the source and effectiveness of installations or purchases.
• Comply with legal obligations, respond to valid legal process and establish, exercise or defend legal claims.

We do not use private Event photos as advertising material merely because you upload them. We do not use them to train general-purpose artificial intelligence models. Authorized processing for storage, previews, camera effects, delivery, support or a specific safety investigation is different from such uses.

4. Legal grounds and required information

Where applicable law requires a legal basis, we use information as necessary to provide the service you request and perform a contract, to comply with law, or for permitted legitimate interests such as security, fraud prevention and proportionate service improvement, after considering affected people's rights. We obtain consent where the applicable activity requires it, including optional tracking or non-essential device access when required.

A participant's contract does not automatically supply the legal basis for processing every non-user appearing in a photo. Organizers and uploaders must have a lawful basis for their actions, and we assess our own obligations, including requests from depicted people. We do not rely on a blanket acceptance of these Terms to authorize every use of sensitive information, international transfer or optional tracking.

Without information needed for authentication, Event participation, purchase verification or delivery, the corresponding feature may not work. Optional permissions can be declined, though the feature needing them may then be unavailable. If we rely on consent, you may withdraw it without affecting processing already lawfully performed.

5. Sharing within an Event and downloaded copies

The organizer and other authorized participants can see information according to the Event's visibility, reveal and access settings. Your display name and photo authorship may appear. An invitation preview may reveal Event information, such as its title and cover, to a person holding the link before they join.

Someone who receives a forwarded invitation may be able to join the Event. Authorized viewers may save, screenshot or share content outside Occur. We cannot withdraw copies others already hold or control their independent accounts, devices or services. Those people remain responsible for respecting privacy, copyright and the permissions they obtained.

Private file storage and temporary access links help control access, but are not end-to-end encryption or a guarantee against copying. Limited authorized access by us or a provider may be necessary to operate the Service, provide requested support or investigate a report. We do not undertake to routinely review every private photo.

6. Providers and other disclosures

We use providers to perform defined functions, with appropriate restrictions and safeguards as required by law. Some providers also act independently for their own platform functions under their notices. The integrations relevant to the current product include:

• Cloudflare: website and guest-web delivery, network and security services, and private R2 file storage.
• Railway: application infrastructure and database hosting.
• Apple: App Store payments, Sign in with Apple when chosen, App Clip platform functions and Apple Push Notification service when used.
• RevenueCat: purchase validation and associated transaction or entitlement information in the full app.
• Google Firebase Analytics: full-app usage measurement, which can be associated with an internal account identifier rather than your name or email. This is pseudonymous information, not a claim that all analytics are anonymous.
• Tenjin: installation and marketing attribution in the full app when the relevant tracking permission is granted. Associated installation, account and purchase identifiers may be used for that purpose.
• Authentication and communication providers: a sign-in provider you choose where available, and a transactional email provider used to deliver login or essential service messages. Support providers or professional advisers may receive information necessary to handle a request or legal obligation.

We may disclose relevant information when required by valid legal process, necessary for a lawful safety response, or otherwise permitted to protect rights and address fraud or abuse. We do not authorize indiscriminate access merely because someone asks. We assess the request and disclose only what is appropriate in the circumstances.

Information may be transferred in a lawful merger, acquisition or transfer of the Service, subject to applicable notice, confidentiality and data-protection requirements. Such a transfer does not authorize unrelated exploitation of private photos. We do not sell private photos or personal information for money. Whether a specific attribution disclosure is legally classified as sharing or another regulated activity depends on the applicable law; required permissions and opt-outs must still be respected.

When handling a copyright notice or counter-notice, we may share the submission and relevant contact information with the affected uploader or rights claimant where necessary or legally required for that process. This does not authorize blanket disclosure of a privacy or safety reporter's identity. We limit disclosures to what is appropriate for the report and applicable law.

7. Analytics, tracking and local storage

The marketing website does not currently include an advertising pixel, analytics SDK or marketing-cookie banner. Hosting and security infrastructure still process technical requests. The browser guest experience uses authentication cookies and local device storage, including storage of pending originals and cached photos, to provide access and upload reliability.

The full iPhone app includes Firebase Analytics for product measurement. Event parameters are limited, but an internal account identifier is associated with measurement. Our analytics events are not intended to contain private photo files, names, email addresses, Event titles or invitation codes.

Tenjin attribution is enabled only after Apple's App Tracking Transparency authorization on supported devices. Refusing that permission does not prevent core Event use. Apple's permission addresses its tracking rules; it does not replace any separate consent or choice required by local law. Firebase Analytics and Tenjin are not included in the App Clip or browser guest client.

You can change tracking, camera, photo and notification permissions in system settings. You can contact us to withdraw a consent or exercise a privacy choice where applicable. We must apply any legally required analytics-consent or withdrawal controls before the relevant processing. Clearing browser storage may delete unuploaded photos and end guest access; download or finish permitted uploads first.

8. Device permissions and communications

Camera access is used to capture photos when you use the camera. A photo selected through the system picker can be uploaded as an Event cover. Saving an exported photo may require permission to add it to your library. These permissions do not grant unrestricted access to all photos on your device.

Push permission is optional. Where enabled, a token associates a device with your authenticated session for notifications. Service notices may also be delivered through available email or in the Service. A guest with no verified contact may receive only notices available in the experience they use. You may miss a notice if contact information is outdated, access is lost or notifications are disabled.

Necessary service, safety and legal communications are separate from marketing. If we send optional marketing, we will apply the consent and unsubscribe rules required by law. No notification is a guarantee of perpetual photo storage or a substitute for keeping your own copies.

9. Retention, expiry and deletion

Event photos and covers have a maximum retention period of 12 months after the Event's scheduled end date, unless removed sooner. This limit applies to originals and derived copies under our control, including backup copies, except material that must be preserved for a specific legal obligation. It is a maximum, not a guarantee of a full year of availability.

Before ordinary scheduled expiry, we will give the organizer reasonable advance notice through an available account contact or the Service, ordinarily aiming for 30 days, so permitted photos can be downloaded. An organizer should inform participants. Earlier deletion may follow a user request, Event or account deletion, a rights complaint, enforcement, service closure or an unexpected failure as described in the Terms.

When an organizer's account is deleted, its Events and their photos are deleted. When a contributor's account is deleted, that contributor's uploads can also be deleted from other people's Events. We do not promise that their photos will remain anonymously in someone else's album. Previously downloaded copies held by others are outside our deletion controls.

Account information is kept while reasonably needed for an active account and the purposes described here. Deletion requests are processed without undue delay and within applicable legal deadlines, subject to necessary identity verification and lawful exceptions. Deactivation and physical deletion are different steps; deleting access does not by itself prove every stored copy has already been erased.

Pending or abandoned uploads, local caches, operational logs, support and abuse records are kept only as reasonably necessary for their defined purpose. Purchase, tax, security or legal records may need longer retention under applicable law. We do not keep whole Event albums indefinitely on the theory that a future dispute might arise. Specific preserved evidence is access-restricted, used only for that purpose and removed when the legal need ends.

Irreversibly anonymized statistics may remain where they no longer identify a person. Merely removing a display name or replacing it with an account identifier does not make information anonymous. Deletion of our copies cannot guarantee restoration or erase files independently kept by participants, devices or third-party services.

10. Security and international processing

We use safeguards appropriate to the information and processing, including encrypted network connections, private storage and access controls. No software, device or storage system is completely secure or immune to failure. We do not promise absolute security, permanent recoverability or error-free operation. This does not waive our legal duties to protect information or respond to an incident.

If a personal-data breach requires notification, we will notify affected people and competent authorities within the applicable legal requirements. Do not send a password, one-time code, full payment credentials or unnecessary sensitive documents to support.

Our providers may process information in countries other than your country, including the United States and other locations in their infrastructure. The exact locations depend on the provider and configured service. We apply the transfer mechanisms and safeguards required by applicable law, such as contractual safeguards where appropriate. We do not treat continued use alone as blanket consent to otherwise unlawful transfers. Contact us for information about safeguards relevant to your data.

11. Your rights and how to make a request

Depending on applicable law, you may have rights to access or obtain a copy of your information, correct it, request deletion, restrict or object to processing, receive portable information, withdraw consent, make a protected opt-out choice and complain to a competent authority. Where required, you may act through an authorized representative and appeal a refusal. We will not unlawfully discriminate against you for exercising a right.

Contact the address at the beginning of this Policy, describe the request and provide information sufficient to locate the account, Event or photo. A person depicted in a photo may make a request without an account. We may need proportionate verification of identity or authority, but will not request more information than reasonably necessary or disclose an album to an unverified claimant.

You can request account deletion from the full app's account settings or contact us for assistance, including for guest access. Use the Terms' reporting instructions for an unlawful photo or nonconsensual intimate image. Do not send prohibited material as an attachment when an Event reference and description can locate it.

Rights have legal conditions and exceptions, such as a specific preservation duty or protecting another person's rights. We respond within the deadline applicable to the request and explain a lawful refusal or extension where required. A generic time estimate does not override a shorter statutory deadline.

12. Regional information

Argentina: applicable rights include access, correction, updating and deletion under Law 25,326. Where that law applies, access requests are answered within 10 calendar days and applicable correction or deletion requests within five business days, subject to its legal conditions. You may complain to the Agencia de Acceso a la Información Pública, the Argentine supervisory authority.

EEA and United Kingdom: where the GDPR or UK GDPR applies, the rights and legal grounds described above apply subject to their conditions. You may complain to your local supervisory authority. A contractual liability cap does not waive compensation or another right that data-protection law makes nonwaivable.

United States: where a state privacy law applies to us and your request, we honor the applicable access, correction, deletion, portability, opt-out, authorized-agent and appeal rights. Attribution or cross-context disclosures must be assessed under that law's definitions even when no information is sold for money. This paragraph does not claim that every state statute applies irrespective of its scope or thresholds.

13. Children and people appearing in photos

The Service is not directed to children under 13, and users must meet the minimum age and authorization requirements in the Terms and applicable law. An organizer must not encourage an ineligible child to create an account or bypass those rules.

A lawful family-event photo may depict a child who is not a user. Uploaders and organizers must respect the child's privacy and obtain any required guardian authorization or other lawful basis. They must not upload sexual, exploitative, intimate or otherwise unlawful material involving a child. Our handling of that content remains subject to our own legal obligations.

If you believe an ineligible child supplied personal information, or a photo violates a child's rights, contact us promptly with a location reference. We will assess and take the action required by law. Do not download or forward suspected child sexual abuse material.

14. Changes and contact

We will update the date and version when this Policy changes and give any notice required for material changes. A new notice does not retrospectively legalize a different use of information. We obtain a fresh consent where required before changing a consent-based purpose.

Contact Occur at [email protected] for privacy requests, questions and content concerns. The Terms provide reporting instructions and explain the Service's temporary-storage rules.