Privacy notice
Draft PhotoMe3D privacy notice: uploaded photos, orders, retention and deletion.
DRAFT — legal review required before launch.
Version T3 · 17 October 2026. Outstanding provider details remain to be completed.
1. Who controls your data?
PhotoMe3D’s controller is {cégnév}, registered office {székhely}, tax number {adószám}. Privacy requests: {adatvédelmi_email}; postal address: {levelezési_cím}; Contact us. Whether a data protection officer is required and their contact details need legal review. [JOGÁSZ] You supply the image; other people depicted may also be data subjects and should receive this notice.
2. What do we use, why and on what basis?
| Data | Purpose | Lawful basis |
|---|---|---|
| Uploaded photo, image-related description, digital preview, 3D model and versions | Creating and refining your preview, model and figurine | Consent for image processing; separation of order-fulfilment operations requires review [JOGÁSZ] |
| Name, email, order reference, product choices and change requests | Order handling, personal order link, status messages and approval | Steps towards a contract and contract performance |
| Phone and delivery address | Delivery and necessary coordination | Contract performance |
| Billing name/address, business name/tax number where required, invoice items | Issuing and retaining invoices | Legal obligation |
| Payment amount, status and provider reference | Checking payment and settlement | Contract performance; legal obligation for mandatory financial records |
| Consent time, text version, selected purpose and withdrawal | Recording and demonstrating your choices | Obligations relating to evidence of consent; retention requires review [JOGÁSZ] |
| Account identifier and sign-in details | Providing an optional account | Performance of the account service contract |
| Separately saved photos, previews, models and addresses | Access to previous figurines and repeat orders | Separate, withdrawable consent |
| Consented usage events | Aggregate website analysis | Consent; Cookie notice |
We request only necessary details. Name, email, phone and delivery address are required during ordering for orders involving delivery. Without necessary billing details we cannot issue a compliant invoice. We do not request delivery details just for a preview. Accounts, account storage and analytics are optional.
The required checkout checkbox does not turn processing necessary for a contract or law into consent-based processing. Without image-processing consent we cannot create an image-based preview. [JOGÁSZ]: review whether mandatory image consent is freely given, the lawful basis for images of other people and how those people receive notice.
External image and model providers process images; descriptions help interpret the order. Do not include unnecessary sensitive information in images or text. A photograph is not automatically biometric data; recognition for unique identification is neither promised nor needed by this service. Special-category data cases require legal review. [JOGÁSZ]
Order permission does not automatically permit advertising or public gallery use. The terms describe automatic model acceptance after five days without a response. Its privacy implications, including human review, require assessment. [JOGÁSZ] Contact us for personal assistance if you dispute acceptance.
3. How long do we retain data?
| Situation | Data and deletion deadline |
|---|---|
| Upload without an order | Uploaded photo and preview are automatically deleted 7 days after upload. |
| Completed order | Photos, previews, 3D models, delivery address and phone are deleted 30 days after delivery. |
| Cancelled order | Eligible order images and personal data are deleted 7 days after cancellation. |
| Invoice | Kept by the invoicing provider for 8 years, without photos; mandatory invoice retention cannot be ended early. |
| Account storage with separate consent | For the account’s lifetime, until individual deletion or withdrawal; 24 months of inactivity triggers notification followed by deletion. |
Required billing names and addresses remain on the invoice. This does not justify keeping separate delivery-address copies or photos. The 30-day deletion period does not end statutory rights concerning defective goods.
Order names, emails, consent records and payment references cannot be kept indefinitely. [JOGÁSZ] [ÜZLETI MEGERŐSÍTÉS]: before launch, specify purpose-specific deadlines for these categories not separately detailed in SPEC, mandatory complaint records and security logs. This draft invents neither new periods nor blanket exceptions. Backup and processor-copy deletion must also be aligned with and verified against these commitments.
4. Registered users
Registration is optional. A separate, unticked choice lets you keep photos, previews, models and addresses in your account. Creating an account alone does not consent to retaining images. Without saving, normal order deletion periods apply.
Delete saved items individually or with your account, or withdraw storage consent at any time. This does not delete mandatory invoices or separate data still needed to fulfil an active order. After 24 months of inactivity, we notify you and then delete the account and saved content. The interval between notification and deletion and the definition of inactivity require business confirmation. [ÜZLETI MEGERŐSÍTÉS]
You can later link a guest order using “Save to my account” from your personal order link, with separate storage consent. This cannot restore already deleted images.
5. Who receives your data?
We share only what each task needs. Complete real names, countries, roles, retention, contracts and further-provider details before launch. Payment, delivery and invoicing services may act as independent controllers for some operations. [JOGÁSZ]
| Role | Provider and country | Data shared | USA / outside EEA |
|---|---|---|---|
| AI image generation | {képgeneráló_neve, ország} | Image, necessary description, processing reference | {USA_igen_nem, további_országok} |
| 3D model provider | {modellkészítő_neve, ország} | Selected preview and change description | {USA_igen_nem, további_országok} |
| Email delivery | {email_küldő_neve, ország} | Email, greeting, order notification, post-payment preview image and personal link | {USA_igen_nem, további_országok} |
| Hosting and backups | {tárhely_neve, ország} | Stored orders, account data, images and models | {USA_igen_nem, további_országok} |
| Payments | {fizetési_szolgáltató_neve, ország} | Necessary payment, identification and settlement data | {USA_igen_nem, további_országok} |
| Invoicing | {számlázó_neve, ország} | Invoice data without photos | {USA_igen_nem, további_országok} |
| Delivery | {szállító_neve, ország} | Name, delivery address, necessary phone/email | {USA_igen_nem, további_országok} |
| Google Analytics 4 | {szerződő_Google_jogalany, ország} | Permitted usage events; no images, names, emails, phone numbers, addresses or private order links | US access/transfers possible; verify actual arrangements |
For each transfer to the USA or outside the European Economic Area, identify the applicable safeguards: {megfelelőségi_határozat_vagy_szerződéses_garancia, másolat_elérhetősége}. Overseas providers are not automatically assumed to offer appropriate protection. [JOGÁSZ]: verify transfer grounds, onward recipients, deletion and any provider use of images for its own purposes. Upload consent cannot be published before the provider register is completed.
6. Deletion and your other rights
From a closed order’s personal page, reached through your emailed link, you can request immediate deletion of eligible photos and order data using “Delete my data”. Delete separately saved account copies from the account as well. The action identifies its scope and does not delete mandatory invoice records. For an active order, contact us to discuss the effect on fulfilment. We send a short deletion confirmation; it does not promise deletion of the invoicing provider’s mandatory records.
You may request access and a copy, correction, deletion or restriction, and portability where applicable. Withdraw consent at any time without affecting the lawfulness of earlier processing. You may object under the applicable conditions to processing based on legitimate interests or public tasks; switch off consent-based analytics through Cookie settings. Rights apply differently depending on the data and circumstances.
You can also write to {adatvédelmi_email}. We request only proportionate identification; do not send a full identity-document copy without prior discussion. Requests are normally answered within one month; we inform you of a justified extension. You may complain to Hungary’s National Authority for Data Protection and Freedom of Information (NAIH) or seek a court remedy: NAIH contact.
7. Children’s photos and security
Only a parent or guardian with the required authority may upload a child’s photo. Avoid unnecessary information about children. Verification of parental authority and handling rights requests require legal review. [JOGÁSZ]
Keep your personal order link private. If lost or disclosed, ask customer service to replace it. Intended safeguards include encrypted transfer, access limited by task, backups and controlled deletion. [ÜZLETI MEGERŐSÍTÉS]: verify actual operation, provider deletion and backup deletion before launch. We cannot delete an image already delivered to your mailbox; you control that copy.