This policy requires legal counsel review before production launch.
The current version is a best-practices draft based on GDPR Articles 15–22 and Fotiqo's actual data flows. Final wording is subject to review by qualified legal counsel and the appointment of a Data Protection Officer.
GDPR — Your Rights
Last updated: 2026-04-20
If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland — or a resident of a country with equivalent legislation — the General Data Protection Regulation (GDPR) gives you the rights summarised below. This page explains how Fotiqo honours them.
Data Controller
Fotiqo acts as the data controller for account data (staff + photographers) and as a data processor for end-guest data that Venues upload to the platform. Contact details for the controller:
- Email: dpo@fotiqo.com
- Postal address: [to be added pending counsel review — registered office + street address]
- Data Protection Officer: to be formally appointed; interim contact via dpo@fotiqo.com
Your rights (Art. 15 – 22)
Art. 15 · Right of access
Get a machine-readable copy of every personal data point we hold on you.
- How to exercise
- Email dpo@fotiqo.com with subject “Art. 15 — access request” and the email / phone number tied to your account.
- Our SLA
- We respond within 30 days (extendable by 60 days for complex requests, per Art. 12(3)).
Art. 16 · Right to rectification
Correct inaccurate personal data or complete incomplete data.
- How to exercise
- Email dpo@fotiqo.com with subject "Art. 16 — rectification" and the fields that need correcting.
- Our SLA
- We act without undue delay, and at the latest within 30 days.
Art. 17 · Right to erasure (“right to be forgotten”)
Delete your personal data, subject to overriding retention obligations (tax, legal holds).
- How to exercise
- Email dpo@fotiqo.com with subject “Art. 17 — erasure request” OR use the self-service endpoint at /account/delete once signed in.
- Our SLA
- We confirm within 30 days and complete deletion (including R2 object deletion + face vectors) within 30 days of confirmation.
Art. 18 · Right to restrict processing
Pause processing while a dispute about accuracy or legal basis is resolved.
- How to exercise
- Email dpo@fotiqo.com with subject "Art. 18 — restrict processing" and the reason.
- Our SLA
- We apply the restriction within 7 days and maintain it until the underlying issue is resolved.
Art. 20 · Right to data portability
Receive your data in a structured, machine-readable (JSON) format.
- How to exercise
- Email dpo@fotiqo.com with subject “Art. 20 — portability”, or use the self-service export at /account/export once signed in.
- Our SLA
- We respond within 30 days with a downloadable JSON archive.
Art. 21 · Right to object
Object to processing based on legitimate interests (e.g. analytics). Where consent-based, just withdraw consent in the cookie banner.
- How to exercise
- Email dpo@fotiqo.com with subject "Art. 21 — objection" and the processing activity.
- Our SLA
- We stop the objected-to processing within 7 days unless we can demonstrate an overriding legitimate ground.
Art. 22 · Right not to be subject to automated decision-making
You will not be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects. Fotiqo does not make any such decisions today — AI culling and face matching inform a human photographer but do not determine contractual outcomes.
- How to exercise
- Email dpo@fotiqo.com with subject "Art. 22 — automated decision".
- Our SLA
- We respond within 30 days confirming whether any such processing applies to you.
Request format
For any request above, please include:
- The specific right you are invoking (e.g. “Art. 17”).
- The email address and / or phone number tied to your Fotiqo account (so we can locate your data).
- A brief description of the scope — everything, a specific gallery, a specific date range, etc.
To protect you against impersonation, we may ask for proof of identity before acting on a request (Art. 12(6)).
Legal bases for processing
- Contract (Art. 6(1)(b)) — delivering the galleries, orders, and kiosk experience you've paid for.
- Consent (Art. 6(1)(a) / Art. 9(2)(a)) — analytics cookies, marketing messages, optional face-ID matching (special-category biometric data).
- Legal obligation (Art. 6(1)(c)) — tax records, anti-money-laundering, lawful requests from regulators.
- Legitimate interests (Art. 6(1)(f)) — preventing fraud, securing the platform, and sending transactional messages that you reasonably expect to receive (receipts, gallery links).
International data transfers
Where personal data moves outside the EEA, Fotiqo relies on the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914, Module 2 or 3 depending on the counterparty), supplemented where needed by Supplementary Measures (encryption in transit and at rest, pseudonymisation, access-logged audit trails).
Retention
- Galleries & photos: 90 days after last access (customers) or until the Venue's contract ends (tenants). Extended only where the Venue enables Digital Pass or archival features.
- Customer contact (email, WhatsApp, room number): retained for the duration of the Venue relationship plus up to 24 months for transactional follow-up and “sweep-up” offers. Deleted on request.
- Face vectors: ephemeral for one-time matching (deleted within seconds of the match). For Digital Pass holders, retained for the duration of the pass and deleted within 24 hours of pass expiry. See the Privacy Policy for detail.
- Financial & tax records: 6 – 10 years, as required by the tax regime of the controller's jurisdiction.
- Audit logs: 24 months (tamper-evident hash chain).
Subprocessors
We engage the subprocessors below to operate the service. Each has signed a written contract meeting GDPR Art. 28(3) requirements, and each appears in our Data Processing Agreement. We notify tenants 30 days before adding or replacing a subprocessor.
| Provider | Purpose | Location | DPA |
|---|---|---|---|
| Stripe, Inc. | Payment processing, Stripe Connect payouts, fraud detection. | United States (SCCs + DPF-certified) | DPA |
| Cloudflare, Inc. (R2 + Workers) | Encrypted object storage for photos, videos, archives; edge delivery. | Global CDN; primary region configurable per-tenant | DPA |
| Cloudinary Ltd. | Image transformation, watermarking, serverless ZIP archive generation. | European Union + United States (SCCs) | DPA |
| Resend | Transactional email delivery (gallery links, receipts, OTPs). | United States (SCCs + DPF-certified) | DPA |
| Meta Platforms, Inc. (WhatsApp Cloud API) | Customer messaging — gallery delivery, booking confirmations, review requests. | Ireland (EU) + United States (SCCs) | DPA |
| Neon, Inc. | Serverless PostgreSQL database hosting (primary data store). | European Union (Frankfurt) + United States (SCCs) | DPA |
| Vercel, Inc. | Web application hosting, edge compute, CDN. | Global edge; primary region configurable | DPA |
| Functional Software, Inc. (Sentry) | Error monitoring. Stack traces and request metadata only — no PII content payloads. | United States (SCCs + DPF-certified) | DPA |
| Plausible Insights OÜ | Cookieless, anonymised product analytics (aggregated pageviews + events). | European Union (Germany) | DPA |
| Microsoft Corporation (Clarity) | Homepage-only heatmaps + session replay. Loaded only with user consent. | United States (SCCs + DPF-certified) | DPA |
| Megvii / Face++ (FACEPP_API_KEY) | Optional face embedding computation for selfie matching. Only invoked when the tenant enables face-ID features; never retained by Fotiqo beyond the match operation. | China (SCCs — feature disabled by default for EU tenants) | DPA |
Lodging a complaint — Italian Garante
If you believe we have mishandled your personal data, you have the right to lodge a complaint with your local supervisory authority. Fotiqo is accountable to the Italian supervisory authority:
Garante per la protezione dei dati personaliPiazza Venezia, 11 — 00187 Roma, ItaliaTelephone: +39 06 69677 1 · Fax: +39 06 69677 3785
Email: protocollo@gpdp.it · Certified email: protocollo@pec.gpdp.it
Web: www.garanteprivacy.it
Residents of other EEA countries may instead file with their own national supervisory authority (a directory is maintained by the European Data Protection Board).
Contact
Any question about this page or about how Fotiqo processes your data — including a data subject request under any of the articles above — can be addressed to dpo@fotiqo.com. See also our Privacy Policy, Cookie Policy, and Data Processing Agreement.
Last updated: 2026-04-20 · Best-practices drafts — pending legal counsel review