FrameMe (operated by PAL Production FZE - LLC)

Privacy notice

Last updated: 18 October 2026

This Privacy Notice explains how PAL Production FZE - LLC (“we”, “us” or “our”) collects, uses and protects your personal data when you use FrameMe, our event photo service at frameme.palproduction.ae. We process personal data in line with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021).

1. Who we are

• Service: FrameMe
• Operator and data controller: PAL Production FZE - LLC
• Registered address: Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
• Email: contact@palproduction.ae
• WhatsApp: +971 58 532 4670

All our contact details are also on the Contacts page.

2. What data we collect and why

We use personal data only to help you find, view and receive the photos of you from an event you attended.

• Your selfie (biometric, sensitive data). Used once to compare your face with the faces in the event photos. The selfie and its face description are not stored: they are discarded as soon as the search is finished. We never use them to train AI models.
• Event photos and the faces in them. Photos we take at the event on behalf of the event organiser. To make them searchable, our face search provider creates a numerical description of each face in the event photos. This is kept only for that event.
• Your search result. A short code (for example PAL-AB12CD) linking to the photos found for you, so you can open them again.
• Your consent record: when you ticked the consent box and which version of this notice you agreed to.
• Your WhatsApp number, only if you choose to message us to receive your photos. Used only to send your photos and answer you. In our records the number is kept only in a scrambled (hashed) form.
• A device cookie and a scrambled form of your IP address, kept for up to one hour, only to protect the service from abuse (limiting the number of searches).

3. Legal basis

• Your explicit consent, which you give by ticking the consent box before taking a selfie and, for WhatsApp, by messaging us yourself. You can withdraw it at any time (see section 7).
• Providing the service you asked for, which we deliver on behalf of the event organiser.

4. How long we keep data

• Selfie: not stored, discarded right after the search.
• Event photos, face descriptions, search results and consent records: deleted automatically 1 month after the event, unless the event organiser agreed a different period with us (from 1 week to 3 months).
• WhatsApp delivery records (scrambled number, time, delivery status): deleted after 90 days. If you send STOP, we keep the scrambled number so that we do not message you again.
• Messages already delivered to your WhatsApp stay on your phone until you delete them.

5. Service providers

We share data only with the providers needed to run the service. They process it on our instructions and under their data protection terms.

• Amazon Web Services (Amazon Rekognition): face search. Processed in Frankfurt, Germany (European Union).
• Cloudflare: website hosting, security and storage of event photos. Stored in Europe.
• Meta Platforms (WhatsApp Business Platform): delivering photos to your WhatsApp, only if you message us.

We do not sell, rent or trade your personal or biometric data, and we do not use it for advertising.

6. International transfers

Our providers process data in the European Union, outside the UAE. The European Union has comprehensive data protection laws, and we rely on our providers’ contractual data protection commitments as a safeguard, as permitted by the UAE Personal Data Protection Law.

7. Your rights

Subject to the law, you can:

• ask what data we hold about you and get a copy of the event photos that show you;
• ask us to correct or delete your data, including event photos of you;
• withdraw your consent at any time (this does not affect processing that happened before);
• object to or ask us to restrict processing;
• stop WhatsApp messages by replying STOP in the chat.

Write to contact@palproduction.ae or message us on WhatsApp at +971 58 532 4670. We reply within 30 days. You may also complain to the UAE Data Office.

8. Security

We use encrypted connections (HTTPS), access limited to authorised staff, separation of each event’s data, and automatic deletion as described above.

9. Changes to this notice

We may update this notice when the law or our service changes. The current version is always published on this page with its “Last updated” date.