Privacy Policy

This Privacy Policy explains how 64Smiles.com collects, uses and protects personal information when you use the 64Smiles website and application.

1. About Us

64Smiles.com is operated by Joe & Sean McDermott in the United Kingdom. 64Smiles is a free, non-commercial service used to share old photographs, memories and family connections between family members and friends.

2. Information We Collect

Depending on how you use 64Smiles, we may collect:

• Your name and email address when you create an account or accept an invitation.
• An email address provided by an existing member when they invite you.
• Photographs, profile pictures, memories, notes, comments and other content you upload or add.
• Information about family or other relationship links that members create within the Photo Family Tree.
• Account information and information needed to manage your login or reset your password.
• Basic technical information such as IP address, browser type, device type and information about how the service is accessed.
• Information contained in communications you send to us, such as support or privacy requests.

3. Invitations

64Smiles is an invite-only service. When an existing member provides an email address to invite someone, we use that address to send the invitation and manage the invitation process.

If an invitation is not accepted, we may retain limited invitation information for a reasonable period to operate, secure and manage the invitation system, after which it may be deleted or anonymised where appropriate.

4. How We Use Your Information

We use personal information to:

• Create and manage your 64Smiles account.
• Provide access to your private photo collections and family connections.
• Maintain the Photo Family Tree and relationships created by members.
• Store, process and display photographs and other content as part of the service.
• Send account, invitation, security and service-related communications.
• Protect the service and its members against misuse, fraud and security threats.
• Maintain, troubleshoot and improve the performance and reliability of 64Smiles.
• Meet legal and regulatory obligations where necessary.

5. Our Legal Bases

Depending on the purpose, we may process your personal information because it is necessary to provide the 64Smiles service you have requested, because it is necessary for our legitimate interests in operating and securing the service, because we have a legal obligation to do so, or because you have given consent where consent is required.

6. Photos, Family Information and Other People

64Smiles is designed for private sharing within family groups. Members may upload photographs and add information about other people, including names and family relationships.

Information supplied by members is treated as user-provided information. We do not independently verify the accuracy of family relationships or historical information.

Your photos and profile information are intended to be accessible only to members who are connected to you within the 64Smiles family tree, subject to the technical operation, security and administration of the service.

7. Sharing Your Information

We do not sell your personal information or share it with third parties for their own marketing purposes.

We may use trusted service providers, such as hosting, storage, email, security or technical service providers, where necessary to operate 64Smiles. These providers may process personal information on our behalf and only for purposes connected with providing their services to us.

We may also disclose information where necessary to comply with the law, protect the rights or safety of 64Smiles or its members, or detect and prevent fraud, abuse or security incidents.

8. International Transfers

Some service providers may process information outside the United Kingdom. Where this happens, we will take appropriate steps required by applicable data protection law to protect personal information.

9. How Long We Keep Information

We keep personal information for as long as reasonably necessary to provide and manage your account and the 64Smiles service.

Some information may be retained for longer where necessary for security, legal, backup or record-keeping purposes. We aim to delete or anonymise information when it is no longer needed.

10. Cookies

64Smiles uses cookies and similar technologies, including cookies needed to keep you logged in, protect your account and operate the service. More information is provided in our Cookie Policy.

11. Data Security

We take reasonable technical and organisational steps to protect personal information against unauthorised access, loss, misuse or alteration. However, no website or online service can guarantee complete security.

12. Your Rights

Depending on the circumstances, you may have the right to:

• Ask for a copy of the personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Ask us to delete your personal information.
• Ask us to restrict certain processing.
• Object to certain processing.
• Ask for your information to be provided in a portable format where applicable.
• Withdraw consent where we rely on consent to process your information.

You can contact us at info@64smiles.com to exercise your rights or ask a question about your personal information.

You also have the right to complain to the Information Commissioner's Office (ICO) if you believe your personal information has not been handled properly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated date.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us at seanmcd@64smiles.com.