This policy explains how Emblem handles personal data across the Emblem mobile app, emblemdigitalsouvenirs.com, cultural passports, forms, and related support services. Last Updated: August 30, 2026
Who Controls Your Data
Emblem: Digital Souvenirs S.à r.l.-S, 19 Rue de l'Industrie, 8069 Bertrange, Luxembourg, is the controller for the personal data described in this policy.
Information We Collect
Account and profile information, including your name, username, email address, profile image, authentication identifiers, language, and settings.
Content and activity you choose to create, including posts, comments, reactions, ratings, collection progress, quiz results, photos, reports, and saved or hidden items.
Precise device location when you use collection or nearby features. This verifies collection at a real place. On iOS only, if you separately allow background location, it can support optional nearby-Emblem alerts. Android does not monitor location in the background.
Technical and measurement data such as app version, device and browser type, operating system, IP-derived approximate location, referrer, page or screen activity, crash or diagnostic information, and Firebase analytics identifiers.
Information you send through contact, organisation, Emblem creator, support, feedback, report, or other application forms.
How We Use Information
Provide accounts, cultural passports, GPS-verified collection, rewards, community features, payments, notifications, and support.
Protect users and the service, prevent fraud and location manipulation, moderate content, investigate reports, and enforce our terms.
Understand product performance, diagnose errors, and improve routes, content, and conversion journeys.
Respond to requests and send service, security, account, or marketing messages where permitted.
Legal Bases
Depending on the purpose, we process data to perform our contract with you, with your consent, for our legitimate interests in operating and securing Emblem, or to comply with legal obligations. You may withdraw consent at any time without affecting earlier processing.
Location Choices
Location access is optional, but collection and nearby features cannot work without the relevant permission. Android requests location only while you use those features and does not monitor location in the background. On iOS only, you may separately allow background access for optional nearby-Emblem alerts. You can change location access in device settings. We use GPS checks to verify presence; we do not sell individual movement histories.
Camera, AR, and TrueDepth Face Data
Camera access is optional and begins only when you open a capture feature. Emblem uses the camera to take photos or videos for posts, Dual moments, and augmented-reality emblem experiences.
On supported Apple devices, face-worn AR effects such as Santa's Cap use Apple's ARKit and TrueDepth camera. While the face-filter view is open, ARKit supplies a face anchor and face-mesh vertex coordinates. Emblem reads those coordinates transiently to calculate face width, horizontal center, top-of-face position, and average forehead depth so it can scale and position the selected 3D effect. Apart from the user-approved rendered photo described below, Emblem does not directly access or serialize raw camera pixel buffers, save or transmit the live camera feed, or read TrueDepth depth maps, facial-expression blend shapes, named facial landmarks, Face ID identity data, face identifiers, or AR-anchor identifiers. The face anchor, mesh coordinates, and derived alignment values exist only in memory during the live AR session; Emblem does not store them, include them as separate data in the rendered photo, upload them, share them with any third party, or use them for identification, authentication, advertising, analytics, profiling, or data mining. The session pauses while you review a photo and when you leave the view, and its face data is discarded when the session ends.
If you tap Use Photo, Emblem creates a square rendered photo containing the camera image and AR effect. It is stored temporarily on your device and, when you have collected that emblem, uploaded to Google Firebase Storage as the cover of your emblem post. The resulting photo may appear on your profile and in the feed according to the post's visibility. Google receives the selected rendered photo for storage, but does not receive the underlying TrueDepth face geometry or depth-derived data, and is required to protect stored data consistently with this policy and applicable law.
Emblem deletes a temporary local capture after its upload and post update succeed, when you discard or replace the pending photo, or when you leave the Emblem page. If an app or operating-system interruption prevents immediate cleanup, the file may remain in the app's temporary directory until the operating system removes it; Emblem does not intentionally retain it. An uploaded AR or filter photo is kept with the post until you remove or replace it, delete the post, or complete account deletion, subject to the backup and legal-retention limits described in this policy. The in-app delete-photo action removes the photo from the post and requests deletion of its cloud file; provider or network failures may delay deletion.
You can deny or revoke camera access at any time in iOS Settings. Without camera permission, camera, Dual, AR capture, and face-filter features will not work, but you can continue using other Emblem features.
Analytics
Website analytics uses persistent visitor and session identifiers only after you accept analytics. Events can include the page, referrer, campaign parameters, device details, performance measurements, and approximate location derived from the request. The app may send registration, passport, collection, and performance events to Firebase services. Declining optional analytics does not block the core service.
Service Providers and Sharing
We do not sell personal data. We disclose only what is needed to providers that operate the service, including Google Firebase and Google Cloud, Apple and Google app-store or payment services, hCaptcha, email delivery, and measurement providers enabled with the required consent. We may also disclose information when required by law, to protect rights or safety, or as part of a lawful business transfer.
Partner Access and Reporting
Emblem does not give partners individual movement histories through public research or routine partner reporting. Campaign and project reports shared with partners use aggregate measures. If a specific service would require a partner to receive personal data, Emblem will limit access to that purpose and provide the applicable notice or obtain consent where required.
International Processing
Some providers process data outside Luxembourg or the European Economic Area. Firebase Authentication is operated from the United States, while other Firebase services can use global infrastructure. Where required, transfers rely on adequacy decisions, contractual safeguards, or another lawful transfer mechanism.
How Long We Keep Data
We keep account and content data while your account is active. An in-app account-deletion request starts a 30-day grace period, during which signing in may cancel the request. After the deadline, a daily deletion process permanently deletes the account and user-uploaded files; completion may occur after the next scheduled run or a retry. We retain information afterwards only as needed for safety, disputes, legal obligations, or legitimate operational records. Detailed first-party website analytics events are scheduled for deletion after 420 days. Form, support, payment, security, and moderation records are retained only for their operational or legal purpose. Provider operations and backup deletion may take additional time.
Data Security
We use access controls, encrypted transport, restricted administration, abuse prevention, and service-provider security measures. No system is completely secure, so we also limit collection and retention where practical.
Your Rights
Subject to applicable law, you can request access, correction, deletion, restriction, portability, or object to processing. You can also withdraw consent. We may need to verify your identity before completing a request. You can delete your account through the app or contact us.
You may also lodge a complaint with your local supervisory authority or Luxembourg's National Commission for Data Protection (CNPD).
Your Controls
Use device settings for location, camera, photo, microphone, and notification permissions, including the optional iOS-only background-location choice. Use the website consent control to accept or decline optional analytics. You can unsubscribe from marketing messages through the link provided, while essential service messages may continue.
Children's Privacy
Emblem is not directed to children under 13 and does not knowingly collect their personal data. Users under 18 should use the service only with permission from a parent or guardian where required. Contact us if you believe a child has provided data improperly.
Policy Changes
We may update this policy when the product, providers, or law changes. We will publish the revised date here and provide additional notice when a change materially affects your rights or choices.
Version History
The date at the top identifies the current published version. Earlier versions are not currently published online. Material changes will be described here when a public archive is available.
Contact Us
Use the contact below to report a security concern affecting Emblem or personal data. Do not include passwords, authentication codes, or unnecessary sensitive information.
To ask a privacy question or exercise your rights, contact danielmichels@emblemdigitalsouvenirs.com.