Draft for legal review. Not yet in effect.
Effective date: [to be set]
Nearby Photo Share lets someone show photos from their iPhone or iPad to people nearby, who watch in a web browser. It is run by Flarecorp Media Group LLC, a Nebraska company ("we").
The short version. Photos are encrypted on the presenter's phone and decrypted in each viewer's browser. The key is part of the link, in the part after #, which browsers never send to a server. Our server passes the encrypted photos along without being able to see them, and keeps no copy. There are no accounts, no ads, no analytics and no tracking.
Our server (the "relay") forwards encrypted data between the presenter's phone and viewers' browsers. This is everything it handles and how long it keeps it:
| What | Where | How long |
|---|---|---|
| Photos | Never stored. Encrypted photos are held in memory only while being forwarded. We can't decrypt them. | Seconds |
| Decryption keys | Never sent to us. The key is in the part of the link after #, which browsers don't send. | Never held |
| Show details: a random show ID, a random presenter code, open viewer connections, counters and times | Server memory | Until the show ends |
| IP address of a phone starting a show | Server memory, only to limit how many shows one network can start per hour | At most 1 hour. Never written down anywhere. |
| IDs of shows ended by a report, takedown request or us | Server memory, so the link can't be used again | 24 hours, or until the server restarts |
| Totals: shows running, shows started today, data forwarded today, reports | Server memory and the server's own log | Daily totals reset each day; others reset when the server restarts |
| The server's log: its startup settings, errors, and the totals above | One log file of at most 10 MB | Overwritten when full |
| Takedown requests (see below) | A file on the server | [retention period to be set] |
The server's log never contains show IDs, presenter codes, IP addresses, browser details or links.
We don't keep web server access logs. We don't use cookies, browser storage, analytics, advertising, or any third-party services in the viewer page, and there is no database. The viewer page loads nothing from anywhere but our server.
Viewers need nothing but the link. Your browser connects to our server to receive the encrypted photos and decrypts them itself. We don't know who you are, and we don't keep your IP address. The page keeps only the photo on screen, in memory, and nothing after you close it.
The Report button ends the show for everyone and blocks the link. We record only that one report happened. We don't record who reported, why, or what was on screen.
If you use the takedown form, we keep what you send: your name, your email address, the link (without the part after #), your description, the time, and the tracking number we give you. This is the only personal information our service stores. We use it to act on and reply to your request, and to keep a record of it. Only the people who run the service can read it. We keep it for [retention period to be set], then delete it.
Email sent to abuse@flarecorp.com is kept in that mailbox. If an email reports apparent child sexual abuse material, the law requires us to report it to the National Center for Missing & Exploited Children (NCMEC) and to preserve the report and what we received for a set period. We report it to NCMEC and to Nebraska authorities as the law requires.
We don't sell or share personal information for advertising.
Nearby Photo Share is not directed to children under 13, and we don't knowingly collect personal information from them.
If we change this policy, we'll post the new version here with a new effective date.
Flarecorp Media Group LLC, [postal address]. Email: abuse@flarecorp.com.