Does Expo Camera require disclosure in a privacy policy?

Yes. Expo Camera accesses sensitive device hardware and collects user-generated media content. Privacy policies must disclose camera access, explain what photos and videos are captured, how they're used, and whether they're transmitted to servers. iOS specifically requires a usage description in app configuration. Transparency about camera access is required under GDPR Article 13 and CCPA Section 1798.100.

What specific data does Expo Camera collect?

Expo Camera collects photos and videos captured by users through the device camera, along with associated camera metadata. This includes timestamp, camera settings, device identifiers, and location data if available. The actual media files themselves constitute the primary data collected, which may contain sensitive visual information.

Does Expo Camera require a cookie consent banner?

No. Expo Camera does not use cookies. However, you must obtain explicit informed consent before accessing the camera through Expo Camera, which is a separate permission from cookie consent. This consent must be requested through the operating system's native permission prompt before camera access is granted.

Who processes Expo Camera data and where is it transferred?

Expo is developed by 650 Industries, a United States-based company. Photos, videos, and metadata collected through Expo Camera may be processed by Expo's infrastructure located in the United States. Any international data transfers must comply with GDPR adequacy decisions or Standard Contractual Clauses. Clarify in your policy whether captured media is stored locally, transmitted to Expo servers, or both.

Media

Privacy policy clauses for Expo Camera

Expo Camera is a media library that enables Expo applications to access device camera hardware for capturing photos and videos. It requires explicit user permission and collects camera data including captured images, videos, and associated metadata during use.

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What data Expo Camera collects

Your privacy policy must disclose each of the following data types when you use Expo Camera.

Photos and videos captured by user

Camera metadata

When does Expo Camera trigger privacy obligations?

Installation triggers immediate obligations

Adding Expo Camera to your Expo application initiates photo and video capture capabilities tied directly to user devices. The moment Expo Camera is integrated, you are collecting visual media content and associated metadata (timestamps, geolocation if embedded, device identifiers) through the device camera hardware. This is not passive analytics—it is direct capture of potentially sensitive personal data.

### Regulatory thresholds

GDPR (EU/EEA users): Expo Camera triggers GDPR Article 6 (lawful basis) and Article 13/14 (transparency obligations) immediately upon installation if any EU user can access the feature. Camera data qualifies as personal data under GDPR Article 4(1). You must establish a lawful basis *before* requesting camera permission—typically "consent" under Article 6(1)(a), which requires explicit opt-in *before* collection begins (ePrivacy Directive Article 5(3) on cookies/tracking applies to consent management too).

CCPA (California users): Photo/video collection triggers CCPA Section 1798.100 disclosure obligations. You must provide a "Notice at Collection" before capture, listing specific data categories being collected and the purposes for use.

Common compliance pitfalls

Pitfall 1: Vague permission disclosure

Many teams implement Expo Camera's permission prompt with generic or missing context. The iOS and Android permission dialogs are system-level and limited in detail—developers often assume the OS dialog is sufficient. This is insufficient for GDPR/CCPA. Users must understand *before* tapping "Allow" that you are capturing photos/videos, storing them, and how you use them. If your app's purpose is not explicit (e.g., a photo-editing tool), users may grant permission thinking it's for a different feature. Consequence: GDPR violation of transparency (Article 13), potential fine, and user trust damage. iOS App Store rejection if usage description is missing or misleading.

Pitfall 2: No data processor agreement with Expo

Expo (650 Industries) acts as a data processor when handling camera data flows through its infrastructure. Under GDPR Article 28, you must have a signed Data Processing Agreement (DPA) with Expo before any personal data is processed. Many indie teams skip this because Expo's SDKs feel like internal tooling. This is a critical gap. Expo's documentation and terms of service govern how they handle your application's data. Without a DPA, you lack contractual guarantees around security, sub-processors, and deletion. Consequence: GDPR non-compliance (Article 28 violation), exposure to supervisory authority enforcement, and potential inability to prove Expo meets GDPR safeguards if audited.

Pitfall 3: Undefined data retention and deletion

Expo Camera captures photos and videos, but your privacy policy often lacks specifics on how long these files are stored, where they are stored, and how users request deletion. Many founders assume "captured locally on the device" means zero compliance obligation—but if you sync photos to cloud storage, analytics, or backup services, the data lifecycle must be documented and contractually enforced. Consequence: GDPR Article 5(1)(e) (storage limitation) and CCPA Section 1798.105 (deletion rights) violations. Regulatory action if users cannot prove their data was deleted.

Privacy policy clauses for Expo Camera

What data Expo Camera collects

When does Expo Camera trigger privacy obligations?

Installation triggers immediate obligations

Where data goes

Common compliance pitfalls

Pitfall 1: Vague permission disclosure

Pitfall 2: No data processor agreement with Expo

Pitfall 3: Undefined data retention and deletion

Legal note

Sample privacy policy clause

What regulators look for

DPA audit priorities for Expo Camera

Frequently asked questions

Does Expo Camera require disclosure in a privacy policy?

What specific data does Expo Camera collect?

Does Expo Camera require a cookie consent banner?

Who processes Expo Camera data and where is it transferred?

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