Privacy Policy

Last updated: October 19, 2026. This version replaces the policy dated October 16, 2026.

1. Who we are

Recuerdos ("we", "us") is a private family photo and video album at recuerdos.app, with Android and iPhone apps and a WhatsApp number that families send their memories to. The company responsible for your personal data is On3D, LLC, a company registered in Delaware, United States, with its registered office at 2140 South Dupont Hwy, Camden, Delaware 19934. In the App Store, the iPhone app is published by ON3D STUDIOS S A S, a company registered in Colombia. On3D, LLC remains responsible for your personal data, and any related company with access to it protects it as this policy describes. For anything about your privacy, write to support@recuerdos.app.

2. Who this policy covers

This policy covers: (a) account owners, who create a Recuerdos account; (b) family members who send photos to a family's album through WhatsApp or the app, with or without their own account; (c) people who appear in the photos, including children; (d) anyone who messages our WhatsApp number; and (e) visitors to our website.

3. What we collect

• Your account: name, email address, password (stored only in scrambled form by our sign-in provider), language, and the phone number you link to your account with a six-digit code on WhatsApp. If you sign in with Google, Google shares your name and email address with us. If you sign in with Apple, Apple shares your name and your email address, or a private Apple address, with us.
• Family members who send photos: WhatsApp phone number, WhatsApp profile name, the name the account owner gives you, and which albums you can send to.
• What you send us: photos, videos, documents, the text you write with them, your button choices in the WhatsApp chat, and comments you write in the app. In our Android and iPhone apps, only the photos and videos you choose to import.
• Information inside your files: the date a photo was taken and, if the file contains it, the GPS location, which we turn into a place name (for example "Medellín").
• Information about the people in your photos, including children: names, birthdays and relationships that an account owner enters; face data, only if the account owner allows it (see section 5); descriptive tags created by AI (for example "beach", "birthday cake"); and estimated ages.
• Visual summary of your photos: so you can find a photo by describing it, each photo and up to five moments of each video are turned into a visual summary: a list of numbers that describes what the picture shows. It is not a face pattern, and we do not use it to recognize people. We only make it if the account owner said yes to Organize with AI; until they answer, we make none. We make it on any plan, so search is ready if the album has Plus.
• Payments: if you subscribe to Plus, our payment provider Stripe collects your card details directly. We receive your plan, payment status and a customer reference, never your full card number.
• Purchases on iPhone: if you subscribe to Plus in the iPhone app, Apple processes the payment through your Apple account. We receive from Apple your plan, the dates and status of the subscription and a purchase identifier, never your card details.
• Devices and use: a notification token so we can send push notifications, how you use the website and app (pages visited, sign-ups, and the steps and screens you use; see section 14), crash and error reports, and your IP address and browser details (for security and to block automated sign-ups).
• Consent records: when and to what you agreed.

If you report content, we keep the report and may view the reported item to act on it.

4. How we use it

We use your information to:

• receive what your family sends, work out which family and album it belongs to (by the sender's phone number), and save it there;
• show your albums to the people you invite, and let you search and browse them by date, place, tag and person, or by describing what you are looking for;
• send you replies on WhatsApp, emails and push notifications about your albums and your account;
• only if you ask for it (a box when you create your account, or the switch in Settings > Notifications), send you at most one email a month with news about Recuerdos and offers. You can turn it off at any time with that switch or the link at the bottom of each email, and we keep a record of when you said yes and when you said no. In the same place you choose which other emails and notifications you get, and every one of those emails has a link to stop that kind;
• group your photos by person with face recognition, only if the account owner allows it (section 5), and tag them and make their visual summary with AI (section 7);
• handle your subscription and payments;
• keep the service secure, prevent abuse, and fix errors;
• understand how the website and app are used so we can improve them, and measure our website ads;
• meet legal obligations, such as keeping billing records.

We do this to provide the service you asked for, with your consent (which you can withdraw), to meet legal obligations, and for our legitimate interest in keeping the service safe and working.

We do not sell your personal data. We do not show ads inside Recuerdos. We do not use your photos, your family's faces, your messages or your searches to train AI models, and Google, whose AI we use to organize and search your photos and to estimate ages, does not use them to train its AI either.

5. Face recognition (optional)

Face data is sensitive data. That is why face recognition is optional: it only runs if the account owner allows it, and it is not a condition for using Recuerdos. Without it, your photos and videos are saved and shown just the same; they are only not grouped by person.

• Who allows it. The account owner, for their album: with a separate, optional box when creating the account (it starts unticked), with the question we ask in the app, or in Settings > Account > Group by faces. They can change their answer anytime in that same place.
• What it does. When it is on and a photo or video is saved, our system finds the faces in it and compares them with the people already known in that same album, so you can browse the album by person. A face is never compared with people in another family's album.
• Where it runs. On our own face-recognition server (open-source software called CompreFace), hosted by Hetzner in Germany. No outside face-recognition company receives your photos.
• What we store. On that server: small images of each known person's face cut from your photos, and the numeric face pattern made from them. In our database: the name, birthday and relationship if an account owner adds them, where each face appears in each photo, and an estimated age range and gender.
• Age estimate. Only if the account owner has allowed both face recognition and organizing with AI, in albums where the owner has added a child, we send a cropped image of each face (not the full photo, and never a name or phone number) to Google's Gemini AI to estimate the person's age, so the album can tell a child apart from their siblings over the years.
• Who can see it. Everyone with access to the album can see who is tagged. Only the account owner can name, merge or hide a person.
• How to turn it off. In Settings > Account > Group by faces. When you turn it off we stop recognizing faces right away and the People view is empty. If you do not turn it back on within 30 days, we erase the album's face data: the face images and patterns, and which photos each face appears in. Your photos and your children's names and birthdays stay. If you turn it back on before then, everything shows again as it was.
• Deletion. Face data is also erased when the photo is permanently erased (30 days after you delete it), right away when you delete an album, and when your account is deleted. Hiding a person in the People view hides them but does not erase their face data. To erase one person's face data, write to support@recuerdos.app and we will erase it without turning off Group by faces for the rest of the album. To erase the face data of your whole album, turn off Group by faces in Settings. If you ask us not to recognize you again, we keep one face pattern of you, used only to recognize and skip you in new photos, and nothing else.

6. Children

Recuerdos is made for families, so albums often contain photos of children, and account owners can add a child's name and birthday (even a due date, before the baby is born). Only a parent, a legal guardian, or someone with their permission may add a child's photos or details; by adding them, you confirm you have that right. We use children's information only to run the family's album: to show it to the people the family invites, to recognize faces if the account owner allowed it (section 5), to show ages in the album, and to help the family find their photos when searching. We never use it for advertising and never sell it. A parent or guardian can ask to see, correct or delete a child's information at any time (section 11). Accounts are for adults: you must be 18 or older to create an account, and 13 or older to send photos to a family album.

7. Who we share it with

We share personal data only with the companies that run parts of the service for us, and only what each one needs. They may use it only to provide their service to us. Google may keep what we send to its AI for a limited time, only to detect abuse, for security and when the law requires it, and does not use it to improve its products.

We may also disclose information if the law requires it, to protect people's safety, or to a buyer if Recuerdos is sold (you would be told first). We do not sell your personal data.

8. Where your data is stored

Your photos and videos are stored in Germany. Our database, our app servers and most of the companies in section 7 are in the United States. Because of this, your information is processed outside your country.

9. How long we keep it

10. Your rights

You can: see the personal data we hold about you and get a copy; correct it; delete it; object to or limit how we use it; withdraw your consent at any time (this does not undo what was done before); and complain to the data protection authority in your country (in Colombia, the Superintendencia de Industria y Comercio). You can download your photos one by one from the gallery at any time, and Plus accounts can download whole albums as ZIP files. Anyone, on any plan, can ask us by email for a free copy of their data. Write to support@recuerdos.app. We may ask you to confirm your identity (for example, from the email address or WhatsApp number on the account). We confirm receipt within 2 business days and answer within 10 business days.

11. How to delete your data

• If you own an account: open the app or recuerdos.app, go to Settings > Delete Account, and confirm. Your account is scheduled for deletion in 30 days and we email you; you can cancel from the same screen until then. If you pay for Plus, it stops renewing right away; you keep what you already paid for until the deletion date, and there is no refund. On the deletion date we erase your photos, videos, albums, face data, family member list, messages and download files, your sign-in, and your phone number (unless it is also linked to another family's album); we ask our analytics provider to delete your data; and we email you a goodbye. What stays: billing records without your name or email (required for accounting), your consent records (section 9), and photos you sent to other families' albums, which belong to those albums.
• If you only send photos to a family's album: in the app, go to Settings > Remove my access. This removes you from every album and stops us saving what you send. To also erase your phone number and name from our records, email support@recuerdos.app. The photos you already sent stay in the family's album; ask the album owner to delete them, or write to us.
• A single photo, memory or album: delete it from the gallery (see section 9 for timing).
• Your album's face data: turn off Settings > Account > Group by faces (section 5).
• Your photos' visual summaries: turn off Settings > Account > Organize with AI (section 9). This also stops us organizing your new photos with AI.
• If you appear in a family's photos, or have no account: email support@recuerdos.app and we will help, together with the album owner where needed.
• To stop WhatsApp messages from us: block our number in WhatsApp.
• By email, for anything above: write to support@recuerdos.app with the subject "Data deletion request" and the email address or WhatsApp number on the account. We confirm receipt within 2 business days, complete requests within 30 days, and confirm by email.

Messages you sent us also stay in your own WhatsApp and on WhatsApp's servers under WhatsApp's policy; we cannot delete those.

12. Security

All connections to Recuerdos and between our systems use encryption (HTTPS). Each family can see only its own albums: our database and our servers check this on every request. Messages that claim to come from WhatsApp are checked with Meta's signature before we accept them. Passwords and service keys are never stored in our code. No system is perfectly secure; if a breach affects your data, we will tell you and the authorities as the law requires.

13. WhatsApp

Messages you send to our number travel through WhatsApp, a Meta service, so WhatsApp's own privacy policy also applies to them: https://www.whatsapp.com/legal/privacy-policy. We do not use Facebook Login and do not receive your Facebook profile.

14. Cookies and analytics

Our website and our Android and iPhone apps use Amplitude, a product analytics service, to understand how they are used. We also keep our own usage log: which steps and screens are used and how often (for example, how many memories are saved). That log never includes your photos, your messages, phone numbers or names, and we keep it for 18 months. Our website also uses the Meta Pixel to measure our ads on Facebook and Instagram; our apps do not use the Meta Pixel. At sign-up, Cloudflare Turnstile checks that you are a person.

15. Changes to this policy

When we change this policy we update the date at the top. If a change is important (for example, a new use of face data), we tell account owners by email or in the app before it applies, and ask for consent again where the law requires it.