a small note
privacy policy
Effective 28 May 2026 · last updated 15 June 2026.
at a glance
FamFrame is a place to draw your family and make frames of the moments that mattered. To do that, we keep the things you save — your account, the people you add, the photos you upload, the frames you make. We use a small set of trusted services to run the product. We do not sell your data, we do not run facial recognition on your photos, and we only load analytics or marketing cookies if you say yes.
This page explains what we collect, why, who else sees it, how long we keep it, and what you can ask us to do with it. If anything is unclear, write to admin@thebaio.com.
1. Who we are
FamFrame is operated by Alon Mittelman, trading as Mimona Technologies, a sole proprietor registered with the Israeli Tax Authority under the Osek Patur regime, registration number 300171220, with a place of business at 24 Hertzl Street, Ramat Gan, Israel. In this policy “we”, “us”, and “FamFrame” mean that person, acting as the controller of your personal data.
For privacy questions, requests to exercise your rights, or any other matter described here, contact us at admin@thebaio.com.
2. Who this applies to
This policy applies to everyone who uses FamFrame at famframe.com or any related domain. FamFrame is open to people aged 16 and over. If you are under 16, you may not create an account; if you have done so, please ask a parent or guardian to write to us at the address above and we will delete the account.
Although FamFrame is operated from Israel, this policy is written to meet the requirements of the EU General Data Protection Regulation (GDPR) for users in the European Economic Area and the UK, the Israeli Privacy Protection Law, 5741-1981 (as amended, including Amendment 13), and to acknowledge the rights of users in California under the CCPA/CPRA where applicable.
3. What we collect
From you, when you sign up and use the product
- Account. Your email address and, if you sign in with Google, your Google account name and profile picture.
- Profile. A display name and theme preference. You may change these at any time.
- Family tree content. The people you add (their names, approximate years of birth or passing, short bios and memories you choose to write), the relationships between them, and the photos you choose to upload of those people.
- Frames. The frames you make in the app — including the cast (who is in the frame), the medium and style you chose, an optional title and description, and the resulting image.
- Credit ledger. A record of frame credits you have received, earned, purchased, or spent.
From you, when you pay us
Frame purchases are processed by LemonSqueezy, which acts as the merchant of record. LemonSqueezy collects your billing information and processes the payment under its own privacy policy. We receive a confirmation that the purchase succeeded, the products purchased, a transaction identifier, and limited billing metadata (for example the billing country) that we keep for tax and accounting purposes. We do not see or store your full card number.
Automatically, when you use the site
- Technical data. Your IP address, browser user-agent, approximate location derived from the IP, the pages you visit and the actions you take, and the time of each request. We use this to keep the service running, to detect abuse, and to debug problems.
- Session cookies. A signed session cookie set by NextAuth so you stay logged in. See section 8.
- Analytics cookies (only if you consent). If you accept the analytics category in our cookie banner, we load the Meta (Facebook) Pixel, which records the pages you visit and a small set of conversion events (account creation, first frame made) so we can measure how the product is being used. If you decline, we do not load the Pixel at all.
A note on photos and faces
Photos you upload of family members are personal data, and they are sometimes photos of people other than yourself. To place each person in a frame and make the result resemble them, FamFrame performs automated face processing on the photos in a frame’s cast: it detects faces, computes a numerical “face signature” (a facial-geometry embedding) for each person, and uses it to match and blend that person’s likeness into the image. These face signatures are a form of biometric data. We use them only to make and improve your frames — never to identify strangers, and never for advertising or profiling. Because this is special-category data under the GDPR, we rely on your explicit consent, which you give when you upload photos and teach a face; you can withdraw it at any time by deleting the person or your account (see “How long we keep it”).
The photos themselves are stored for display in your tree and for the cast you choose when you make a frame. By uploading a photo of another person you confirm that you have the right to do so and, where the law requires it, that you have their consent to this face processing. If you are the subject of a photo on FamFrame and want it removed, write to admin@thebaio.com and we will remove it.
4. Why we use your data and our legal basis
Under the GDPR we must have a legal basis to process your data. Under Israeli law we must use the data only for the purpose for which it was collected and as reasonably understood from the circumstances. Here is how that breaks down for FamFrame:
| What we do with it | GDPR legal basis |
|---|---|
| Create your account, sign you in, run the app, store and display the people and photos you save, deliver the frames you make. | Performance of a contract (Art. 6(1)(b)). |
| Detect faces, compute a per-person face signature (facial-geometry embedding), and use it to match and blend each person’s likeness into a frame (see “A note on photos and faces”). | Your explicit consent for special-category biometric data (Art. 9(2)(a)), given when you upload photos and teach a face. You can withdraw it at any time (see “How long we keep it”). |
| Process payment for frame credits and keep tax records. | Contract (Art. 6(1)(b)) and compliance with a legal obligation under Israeli tax law (Art. 6(1)(c)). |
| Keep the service secure, detect abuse, prevent fraud, and debug problems. | Our legitimate interests in operating a safe service (Art. 6(1)(f)). |
| Send you transactional email (magic-link sign-in, receipts, important account notices). | Contract (Art. 6(1)(b)). |
| Load the Meta Pixel and measure how the site is used. | Your consent, given through the cookie banner (Art. 6(1)(a) and ePrivacy Directive Art. 5(3)). You may withdraw consent at any time. |
| Respond to legal requests, defend legal claims, comply with court orders. | Legal obligation and our legitimate interests (Arts. 6(1)(c) and 6(1)(f)). |
5. Who we share it with
We do not sell your data. We do not share it for advertising other than the limited Meta Pixel signals described above (and only if you have consented). We use a small set of trusted service providers (“processors”) to actually run the product. Each is bound by a data-processing agreement and is listed below.
| Provider | What it does | Where |
|---|---|---|
| Amazon Web Services (AWS S3) | Stores uploaded photos and frame images. | United States / EU (see note below). |
| fal.ai (Features & Labels, Inc.) | Runs the image-making models: composes a frame from the photos in your chosen cast, trains a per-person likeness when you teach a face, and upscales finished frames. Receives those photos. May route an appearance-description step to a third-party vision-model provider. | United States. |
| RunPod, Inc. | Runs the face-refinement step: detects and matches faces and blends each person’s likeness into the frame, computing the face signatures described in “A note on photos and faces.” Receives photos and face crops. | United States. |
| Brevo | Sends transactional email, including magic sign-in links. | France (EU). |
| Google LLC | OAuth sign-in (only if you choose “continue with Google”). Google sees your sign-in event; we receive your Google email, name, and profile image. | United States. |
| LemonSqueezy | Processes frame-credit purchases as merchant of record. | United States. |
| Meta Platforms, Inc. (Pixel) | Receives page-view and conversion events only if you accept analytics cookies. | United States / Ireland. |
| Render | Hosts the FamFrame application and the Postgres database that stores your account and tree. | United States. |
| Sentry (Functional Software, Inc.) | Error monitoring: receives technical reports when something in the app breaks, so we can fix it. Reports are scrubbed before sending — no email addresses, photos, or photo links — and IP addresses are not collected. | United States. |
We may also disclose data when required by a binding legal request, to enforce our Terms of Service, or to protect the rights, safety, or property of FamFrame or others. If FamFrame is ever transferred to a new operator (acquisition, restructuring), we will tell you before your data is transferred and you will have a reasonable opportunity to delete your account first.
6. International transfers
FamFrame is operated from Israel. The European Commission has formally recognised Israel as providing an adequate level of data protection, so personal data may flow freely from the EU/EEA to FamFrame on that basis.
Several of our processors are based in the United States. We rely on the EU–US Data Privacy Framework where the provider is certified, on the Standard Contractual Clauses approved by the European Commission, or on the equivalent UK and Swiss safeguards. You can ask us for a copy of the safeguards in place by writing to admin@thebaio.com.
7. How long we keep it
- Account, tree, photos, and frames: for as long as your account is active. If you delete your account we erase your data within 30 days, except where we are required to keep it longer.
- Face signatures and any trained likeness: the facial-geometry embedding we derive for a person, and any per-person likeness produced when you teach a face, are deleted when you delete that person or your account (within the same 30-day window). They are not kept separately from the photos they were derived from.
- Payment records and invoices: we keep transaction records for the period required by Israeli tax law, which is generally seven (7) years.
- Server logs and security data: kept for up to 90 days and then deleted or anonymised.
- Backups: our hosted database backups are retained for a rolling window (currently up to 30 days) and then overwritten.
8. Cookies and similar technologies
FamFrame uses two categories of cookies and local-storage entries.
- Essential. A signed NextAuth session cookie that keeps you logged in, a CSRF token, and a small
localStorageentry that records your cookie-banner choice so we do not ask again. These are always on; the site cannot run without them. - Analytics & marketing. The Meta (Facebook) Pixel and the related Meta cookies. These are only loaded if you accept the analytics category in the cookie banner. You can change your mind at any time from the “cookie preferences” link in the footer.
9. Your rights
Wherever you live, you can write to admin@thebaio.com to ask about, correct, or delete your data. If we cannot do what you ask we will explain why.
If you are in the EU/EEA or the UK, the GDPR gives you the right to: access the personal data we hold about you and receive a copy of it; ask us to correct inaccurate data; ask us to delete your data (“right to be forgotten”); ask us to restrict how we use it; receive your data in a portable, machine-readable format; object to processing that we base on our legitimate interests; withdraw any consent you have given (which does not affect processing that already happened on the basis of that consent); and lodge a complaint with your national supervisory authority.
If you are in Israel, the Privacy Protection Law (as amended) gives you the right to inspect the data we hold about you, to ask for it to be corrected or deleted, and to complain to the Israeli Privacy Protection Authority (Privacy Protection Authority of Israel).
If you are in California, the CCPA/CPRA gives you the right to know, delete, correct, and limit the use of your personal information, and the right not to be discriminated against for exercising those rights. FamFrame does not “sell” or “share” personal information for cross-context behavioural advertising within the meaning of the CPRA. If we ever do, we will update this policy and offer a clear opt-out.
If you are in Illinois or Texas (biometric laws). The face signatures described in “A note on photos and faces” are biometric identifiers/information under the Illinois Biometric Information Privacy Act (BIPA) and the Texas Capture or Use of Biometric Identifier Act (CUBI). We collect and use them only to make and improve your frames, with your consent; we do not sell, lease, trade, or otherwise profit from biometric data; and we permanently destroy a person’s face signature when you delete that person or your account, when the purpose for which it was collected has been satisfied, or within three (3) years of your last interaction with us — whichever occurs first.
10. Security
Connections to FamFrame are encrypted with TLS. Photos and frame images are stored encrypted at rest in AWS S3. Passwords are not used — sign-in is by magic link or Google OAuth, and session tokens are stored hashed in our database. Access to the production database is limited to the operator and protected by individual credentials. No system is perfectly secure; if we discover a breach that affects you, we will notify you in accordance with Israeli law and Article 33 of the GDPR.
11. Children
FamFrame is for people aged 16 and over. We do not knowingly collect personal data from anyone under 16. If you are a parent or guardian and believe your child has created an account, write to admin@thebaio.com and we will delete it. If you upload a photograph of a child as part of your family tree, you confirm that you are entitled to do so; the child or their guardian can ask us to remove it at any time using the same address.
12. Changes to this policy
If we make a material change to this policy — adding a new processor, changing the legal bases, adopting new tracking — we will update the effective date at the top and, when the change is significant, give you notice in the app or by email before the change takes effect. Continuing to use FamFrame after the change means you accept the updated policy.
13. How to complain
We hope you will always come to us first at admin@thebaio.com, but you do not have to. In Israel you may complain to the Privacy Protection Authority. In the EU/EEA you may complain to your national data protection authority (a list is maintained by the European Data Protection Board at edpb.europa.eu). In the UK you may complain to the Information Commissioner’s Office (ICO).
This page is the privacy policy. The companion document — what you can and cannot do with the service, and what we will and will not do for you — is the Terms of Service.