Legal

Privacy Notice

Last updated and effective August 9, 2026

This privacy notice for Sherlock ('Company', 'we', 'us', or 'our') describes how and why we might collect, store, use, and/or share ('process') your information when you use our website or mobile application (collectively, the 'Services'), such as when you:

  • Download and use our mobile application (Sherlock), or any other application of ours that links to this privacy notice.
  • Engage with us in other related ways, including any sales, marketing, or events.

For purposes of this privacy notice, 'personal information' (sometimes referred to as personal data, personally identifiable information, or other like terms) means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person. Personal information does not include deidentified and aggregated information (which includes data that is not reasonably capable of identifying you or being linked to you) and does not include certain publicly available information. If we use deidentified data, we commit to maintain and use the information in deidentified form and not attempt to reidentify the information, unless permitted or required by law.

Sherlock is operated from the United States and intended primarily for users located in the United States. Our privacy practices are governed by applicable U.S. laws. Individuals accessing the Services from outside the United States do so at their own initiative and acknowledge that their information may be transferred to and processed in the United States.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@imsherlock.com.

Summary of Key Points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect or store face data? No. Photos you submit for searches are sent to a third-party image search service to run the search and are not stored by Sherlock.

Do we receive any information from third parties? We may receive information from third-party service providers that help us deliver our Services.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we disclose personal information? We may disclose information in specific situations and with specific categories of third parties.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a privacy rights request or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

  1. What information do we collect?
  2. Photo searches and third-party image search
  3. How do we process your information?
  4. When and with whom do we disclose your personal information?
  5. Is your information transferred internationally?
  6. How long do we keep your information?
  7. Do we collect information from minors?
  8. What are your choices?
  9. What are your privacy rights?
  10. Notice at collection
  11. Third party privacy policy
  12. Do we make updates to this notice?
  13. How can you contact us about this notice?

What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Sensitive Information. We do not process sensitive information.

Account Information. If you create an account, we collect the email address and authentication details needed to sign you in and store your search results for you.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment card information and the associated security code. All payment data is processed and stored by our payment processors — Apple (for purchases through the App Store), Google (for purchases through the Google Play Store), and Stripe (for purchases on the web) — and is not stored by Sherlock. You may find their privacy notices here: Apple, Google, and Stripe.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Mobile Device Data.We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
  • Mobile Device Access.We may request access or permission to certain features from your mobile device, including your mobile device's camera, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • Push Notifications.We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

  • Log and Usage Data.Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Sherlock allows users to submit photographs to conduct image-based searches. When you initiate a search, the submitted photo is sent to Tech Solutions - Belize, a third-party image search service, to find visually similar images from publicly available sources.

On our mobile apps, the photo is transmitted directly from your device to that service. On the web, the photo passes through a Sherlock server only as a transient relay on its way to that service — a security measure so the service's access key is never exposed in your browser — and is not stored on any Sherlock server at any point.

Sherlock does not use submitted photographs to identify individuals, create user profiles, serve advertising, or train artificial intelligence or machine-learning models. Sherlock also does not intentionally retain submitted photographs after the search request has been processed, except as may be necessary for transient technical processing, security, troubleshooting, legal compliance, or similar operational purposes.

Tech Solutions processes submitted photographs in accordance with its own privacy policy and terms. This is functionally similar to how reverse image search engines such as Google Images operate.

Sherlock does not intentionally:

  • Collect, create, store, or sell uploaded photos, biometric identifiers, or biometric information.
  • Use facial recognition technology.
  • Create face templates, facial geometry scans, or biometric profiles.
  • Use photos for advertising or analytics.
  • Link photos to your identity.

Aggregate and Non-Personal Information

Information that does not identify an individual or cannot otherwise be reasonably linked or connected with them is not considered personal information. Personal information may be aggregated or de-identified to become non-personal information. We may collect and use such non-personal information, such as customer activity on our Services, for any purpose, including to operate, analyze, and improve our Services. Notwithstanding anything to the contrary, Sherlock shall have the right, where permitted by law, to collect, aggregate, and analyze anonymized personal information. Sherlock may use anonymized data for any lawful business purpose without limitation to develop and improve our Services. We will not distribute anonymized data in a manner that personally identifies anyone or that would otherwise violate applicable laws.

How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual's vital interest.We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
  • To monitor and improve the Services.
  • To provide you with information or services you request.
  • To respond to law enforcement, government, or regulatory requests.
  • To protect our company and our customers' rights and interests.
  • To detect security incidents; protect against any malicious, deceptive, illegal, or fraudulent activity; and prosecute those responsible for that activity.
  • To comply with legal requirements, industry standards, and our policies.
  • To carry out any other purpose described to you at the time the information was collected or with your consent.
  • As otherwise permitted under applicable law.

When and with whom do we disclose your personal information?

In Short: We may disclose information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers.We may disclose your data to third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may disclose personal information to are as follows:

  • Image Search Service (Tech Solutions - Belize):When you perform a search, your photo is transmitted to this service to conduct the image search. Sherlock does not store the photo. The service's handling of submitted photos is governed by its own privacy policy.
  • Cloud Hosting Services
  • Analytics and Advertising Services (do not receive photo data)
  • Payment Processing Services (Apple's App Store, Google Play, and Stripe)

We also may need to disclose your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • To our advisors and lawyers.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sherlock, our customers, or others.
  • As necessary if we believe that there has been a violation of our Terms or of our rights or the rights of any third party.
  • With your express consent.

Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see 'When and with whom do we disclose your personal information?' above), in the United States, and other countries. By using the Services or providing us with any personal information, you (a) acknowledge that the Services are subject to the laws of the United States, (b) consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We retain different categories of information for different periods:

  • Photos submitted for searches. Not retained by Sherlock (see below).
  • Account information. Retained for as long as your account is active. You can delete your account at any time.
  • Log, device, security, analytics, and fraud-prevention data. Retained only for as long as reasonably necessary for the purposes described in this notice.

Photo Data:Sherlock does not store or retain photos submitted for searches. Photos are transmitted to our third-party image search service to run the search, and Sherlock has no further involvement. That service's retention and deletion practices are governed by its own privacy policy.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market our Services to children under 18 years of age.

We do not knowingly solicit data from or market our Services to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@imsherlock.com.

We do not engage in targeted advertising to, or the sale of the personal information of, any consumer we know to be under 16 years of age in states that prohibit such activities.

Additionally, users are prohibited from uploading photos of minors under 18 years of age for searches.

What are your choices?

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Push notifications

If you wish to opt out from receiving push notifications, you may turn them off in your device's settings.

What are your privacy rights?

In Short: Subject to certain limitations, residents of certain US states have specific rights related to their personal information.

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

Right to request deletion of the data — Request to delete.

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law.

Right to request correction of the data — Request to correct.

You can request that we correct inaccurate personal information that we have collected about you.

Right to be informed — Request to know/access.

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights.

We will not discriminate or retaliate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We do not process consumer's sensitive personal information.

Right to a List of Third Parties.

Where required by applicable law, you can request a list of the specific third parties to which we have disclosed your personal information, if we maintain that information in a format specific to you. If we do not maintain that information specific to you, we will provide a list of specific third parties to whom we have disclosed or sold any consumers' personal information (except for information that reveals trade secrets).

Right to Opt Out of Sharing for Targeted Advertising or Sale.

We do not sell your personal information for monetary consideration. To the extent we share personal information (such as online identifiers) for targeted advertising, you have the right to opt out — you can do so through your browser and device ad-personalization settings or by contacting us at support@imsherlock.com.

Right to appeal.

In certain states, if we decline to take action in response to your rights request, you may appeal our decision by contacting us. We will inform you of the reason for denying your request within 60 days of receipt and provide instructions on how to appeal the decision. If your appeal is declined, you may submit a complaint with your state's Attorney General or other applicable regulator in your state.

How to exercise these rights

To exercise these rights, you can contact us by submitting a privacy rights request by email to support@imsherlock.com, or by referring to the contact details at the bottom of this document. For removal of a photograph or search result from the third-party image search service, you may use that service's removal portal.

Verification.

Upon receiving your request, we will need to verify your identity and state of residence before responding to your request. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us or that is in our system.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

We will respond to your request within 45 days of receipt. When reasonably necessary, we may extend the response period by an additional 45 days, and will notify you within the first 45-day period of the extension and the reason for it.

Authorized Agents.

If permitted or required by applicable law, your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. If we receive a request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please follow the instructions above.

Notice at collection

Summary of our processing activity. The table below describes the categories of personal information we process, the purpose of processing each category, and the third parties with whom we may disclose each category, since Sherlock began providing its Services in January 2026. We collect the categories of personal information described below from the following categories of sources: directly from you; your device and browser as you interact with our Services; and our third-party providers.

  • Identifiers, such as IP address and other similar identifiers. Processed for the purposes described in 'How do we process your information?' May be disclosed to service providers or third parties who provide us services for a business purpose. We have not sold this category of personal information for monetary consideration.
  • Commercial Information, including records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Processed for the purposes described in 'How do we process your information?' May be disclosed to service providers or third parties who provide us services for a business purpose. We have not sold this category of personal information for monetary consideration.
  • Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with our Services. Processed for the purposes described in 'How do we process your information?' May be disclosed to service providers or third parties who provide us services for a business purpose. We have not sold this category of personal information for monetary consideration.
  • Visual information, such as photo images. Processed only to run the image search you request; transmitted to our third-party image search service and not retained by Sherlock. We have not sold this category of personal information for monetary consideration.

Third party privacy policy

We use third-party service providers to help deliver our Services. When you perform an image search, your photo is transmitted to Tech Solutions - Belize, whose privacy practices are governed by their own privacy policy available at their website. We are not responsible for the content returned by third-party services or the accuracy of search results. We encourage you to review the privacy policies of any third-party services you interact with through our platform.

Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@imsherlock.com.