Privacy Policy

1. Who we are and what this covers

125 Ventures LLC, a Wyoming company doing business as TurboHeadshots, runs turboheadshots.com. This policy explains what we collect, what we do with it, who else sees it, and how long we keep it. It covers the website and the headshot service, and it is part of our Terms of Service.

TurboHeadshots is offered to people in the United States. If you use it from elsewhere, your information is processed in the United States under this policy.

Questions, or a request about your data: support@turboheadshots.com.

2. What we collect

We do not ask for, and you should not send us, government identifiers, health information, or financial account details.

3. What happens to your photograph, step by step

This is the part most people actually want to know, so here is the whole path.

• You upload one photograph. It goes to our storage at Cloudflare R2, in the United States.
• We check it is usable. Our own processing server looks for exactly one person and a clearly visible face, and measures where the eyes and nose are so the photograph can be cropped and straightened. That measurement is used in the moment and is never stored. An OpenAI vision model separately checks the photograph for lighting, blur, sunglasses and framing, and returns a pass or fail with reasons.
• We generate previews. The prepared photograph is sent to fal.ai and to OpenAI, which generate headshots from it. We watermark them and show them to you at no cost.
• If you buy, we generate the rest. You choose outfits and backgrounds, and the same providers generate the headshots in your package. You download them individually or as an archive.

We do not use your photograph, or the headshots made from it, to identify or authenticate anyone, and we are not training anything to do so. We do not run face recognition, we do not match your face against any database, and we do not build a profile of your face.

4. Your photographs are never used to train AI models

Not by us, and not by the providers who generate your headshots. This is a contractual term with them, not a preference: OpenAI does not train on data sent through its API, and fal's terms bar it from using customer content to create, train or develop its products.

Two honest footnotes, because a promise with a hidden exception is worse than no promise. Our providers keep short-lived operational logs for abuse monitoring, typically up to 30 days. And fal's terms reserve the right to use anonymized, aggregated data derived from customer inputs to develop its own products and models — so we can tell you your photographs are never used to train AI models, and we will not claim more than that.

We have never sold your photographs or headshots, and we do not.

5. How we use what we collect

• to generate, watermark, store and deliver your headshots;
• to take payment, and to keep the order and tax records a business has to keep;
• to send you the emails the Service depends on — your one-time sign-in code, order confirmations, and a note when your headshots are ready;
• to answer you when you write to support;
• to keep the Service working and secure: rate limiting, abuse prevention, error reports, fraud checks;
• to understand how the site is used and how well our advertising works; and
• to comply with the law and to enforce our Terms of Service.

We do not make decisions about you that have legal or similarly significant effects using automated processing alone.

6. Who else sees your information

We use other companies to run the Service. They receive only what they need, only to do the job we hired them for, and they may not use it for anything else.

Beyond that, we disclose information only: when the law or valid legal process requires it; when it is needed to protect someone's safety or our rights; and if the business is ever sold or merged, in which case this policy travels with it and we will say so before anything changes.

7. Advertising, analytics and your choices

We advertise on Google. When you arrive from an ad, the link carries a click identifier (gclid, gbraid or wbraid) and we store it with your session so we can tell which ads lead to purchases. Google Analytics also sets cookies that give us a client ID and a session ID.

When a purchase completes, our server sends Google a purchase event containing the amount, the transaction reference, those identifiers, and a one-way hashed (SHA-256) version of your email address — hashed so it can be matched without our sharing your actual address.

Under California law this counts as sharing personal information for cross-context behavioral advertising. You can stop it in either of two ways, and both are honored:

• Use the "Do Not Sell or Share My Personal Information" link in the footer. Your choice is remembered on that browser.
• Turn on Global Privacy Control. Some browsers and extensions send a GPC signal on every request; we treat it as an opt-out automatically, with nothing for you to click.

Opting out does not change the Service, the price, or the headshots you get. Independently of us, you can also opt out through Google's own Ads Settings and the industry tools at the Network Advertising Initiative and Digital Advertising Alliance.

We do not sell your personal information for money, and we never sell photographs or headshots at all.

8. Cookies and similar technologies

We use a small number of cookies and similar storage:

• Necessary — to keep you signed in, remember the session you are working on, hold your progress through an upload, and remember a Do Not Sell or Share choice. The Service does not work without these.
• Analytics and advertising — Google Analytics and Google Ads, as described in Section 7. These are what an opt-out or a GPC signal turns off.

You can also delete or block cookies in your browser settings. Blocking necessary cookies will break sign-in and uploads.

9. Teams: what your organization can see

If you use TurboHeadshots through a team, the team owner and any administrator can view and download the headshots generated on your seat, and we record who viewed or downloaded what. The organization that bought the seats decides who is invited and can remove you from the team, which deletes the photograph on your seat.

Your photograph is still yours, and everything in this policy — including deletion on request — applies to you as an individual as well.

10. How long we keep things

We may keep something longer where the law requires it or where we need it for a dispute. When we no longer need information we delete it or strip it of anything that identifies you.

11. Deleting your photographs or your account

Email support@turboheadshots.com from the address on your account and tell us what you want removed — a single photograph, a session, or everything. We act on deletion requests within 7 business days.

One honest limit: after we delete something, copies can survive briefly in backups and system logs. Those remnants can persist for up to 90 days, after which they are gone too. We do not restore deleted photographs from backups for any other purpose.

Deleting your photographs also deletes the headshots generated from them, so download anything you want to keep first.

12. Security

Photographs and headshots are held in private storage that is not publicly listable, and are shown to you through links that expire. Traffic to the site and to our providers is encrypted in transit. Access to production data is limited to the people who need it.

No service can promise perfect security, and we do not. If a breach affects your information we will tell you and the authorities as required by law.

13. Where your information is processed

In the United States, by us and by the providers in Section 6. If you use TurboHeadshots from outside the United States, you are sending your information to the United States, where privacy law differs from your own.

14. Children

TurboHeadshots is for people 18 and over. We do not knowingly collect information from anyone under 18, and every person shown in an uploaded photograph must be 18 or over. If you believe a child's photograph or information has reached us, email support@turboheadshots.com and we will delete it.

15. Your privacy rights

Depending on where you live, you may have the right to: know what we hold about you and get a copy; correct it; delete it; opt out of sale, sharing, or targeted advertising; and not be treated differently for exercising any of these.

To use any of them, email support@turboheadshots.com from the address on your account, or use the "Do Not Sell or Share My Personal Information" link for the advertising opt-out. We answer within 45 days and will tell you if we need longer. We may need to confirm who you are before acting — usually by a code sent to the email on the account — and an authorized agent may act for you with written permission.

If we refuse a request, we will say why, and you may ask us to reconsider by replying to that response. Some states also let you complain to your Attorney General.

16. California

In the past 12 months we have collected the categories described in Section 2: identifiers (name, email, IP address, account and device identifiers), commercial information (what you bought), internet activity, approximate geolocation, visual information (your photograph and headshots), and inferences drawn for advertising measurement. We collect them from you, from your device, and from the providers in Section 6, for the purposes in Section 5.

We do not sell personal information. We do share identifiers, internet activity and a hashed email address for cross-context behavioral advertising, as Section 7 explains, and you can opt out with the footer link or by sending a GPC signal. We do not knowingly sell or share the personal information of anyone under 16.

California residents may also request the specific pieces of information we hold, ask us to correct or delete them, and are protected from discrimination for asking. Under California's "Shine the Light" law you may ask whether we disclosed personal information to third parties for their own direct marketing — we do not.

17. Other states

If you live in a state with a comprehensive privacy law — including Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Tennessee, Indiana, Kentucky or Rhode Island — you have rights close to those in Section 15, including access, correction, deletion, portability, and opting out of targeted advertising. Use the same route: support@turboheadshots.com, or the footer opt-out link.

Where your state's law requires consent before processing sensitive data, we rely on the consent you give when you upload a photograph, and you can withdraw it at any time by asking us to delete the photograph.

18. Changes to this policy

We update this policy when the Service changes. The date at the top is always the current version, and we will tell you by email before a material change takes effect.

19. How to reach us

125 Ventures LLC, doing business as TurboHeadshots, 30 N Gould St Ste N, Sheridan, WY 82801. Privacy requests and questions: support@turboheadshots.com. Everything else: support@turboheadshots.com.