1. Who we are
Fotoflo is operated by Ventured Oy, business ID 2654364-4, Erkinkuja 11, 04420 Järvenpää, Finland ("Fotoflo", "we", "us"). Contact for anything about your data: info@fotoflo.co.
This policy explains how we handle personal data for five groups of people: photographers who use Fotoflo (Part A), people who are photographed and viewers of galleries (Part B), visitors of our website (Part C), people who report content (Part D), and users of the desktop app (Part E).
Our role differs by situation:
- We are the controller for photographers' account, billing and support data, for security logs, for content reports and for our own legal obligations.
- For the photos in a gallery and the contact details a viewer enters in the contact form, the photographer is the controller and Fotoflo is the processor. See the Data Processing Addendum.
Part A — Photographers (Fotoflo users)
A.1 What we collect
| What | Details |
|---|---|
| Account | name, email address, sign-in method (password or Google), profile picture from Google if you use Google sign-in, your acceptance of the Terms (version, time, browser details) and age confirmation |
| Photos and project data | the images you upload and their file metadata (name, size, dimensions, capture time, camera make and model; if a photo contains location data we show it to you in the app, and we clear it from the stored JPEG original that viewers download), project settings and gallery design, collections, access codes |
| Contact details from viewers | what viewers enter in the optional contact form (see Part B) |
| Payments | purchases of credits are processed by Stripe. We store the transaction record (amount, currency, items, status, receipt link, billing country, the time you accepted the withdrawal waiver) and your Stripe customer ID, not your card details |
| Credits and referrals | credit balance and history; referral and gift-code links between accounts by internal ID |
| Support | what you send us in a support ticket or by email, with technical details the desktop app attaches (app version, operating system) |
| Usage and device | actions in the service, gallery access counts, IP address and browser type in server logs |
A.2 Why we use it, and on what legal basis (GDPR art. 6)
| Purpose | Legal basis |
|---|---|
| Create and run your account, host and deliver your galleries, process payments and credits, give support | Performing our contract with you (6(1)(b)) |
| Keep the service secure, prevent abuse and fraud, monitor errors, improve the product | Our legitimate interests (6(1)(f)) |
| Keep accounting records, respond to authorities and to valid legal requests, handle reports of unlawful content | Legal obligation (6(1)(c)) and, for reports, our legitimate interest in keeping the service lawful |
| Record that you accepted the Terms and confirmed your age | Our legitimate interest in being able to show it, and the contract |
| Send service messages (receipts, security, changes to the Terms) | Contract / legitimate interests. We send no marketing without your consent |
A.3 Who we share it with
We do not sell your personal data. We share it only with:
- Service providers (processors) that run the service for us: Supabase (database, storage and sign-in, hosted in the EU, Paris), Vercel (hosting; functions run in Paris), Resend (email), Sentry (error monitoring for the desktop app, EU region) and Zoho Mail (our support mailbox). They may use data only on our instructions.
- Stripe (Stripe Payments Europe, Ltd.), which processes your payment and is an independent controller of payment data under its own privacy policy.
- Google, if you sign in with Google (its privacy policy applies to that sign-in).
- GitHub, from where we fetch the desktop app's releases for the updater; no personal data about you is sent to it for that.
- The people you share galleries with, as you choose.
- Authorities and advisers where the law requires or to protect our rights, and a successor if the business is sold (you will be told).
A.4 How long we keep it
| Data | Kept |
|---|---|
| Account and profile data | while your account exists; deleted when you delete your account |
| Photo files in a project | deleted automatically about 3 days after the project's delivery window closes (Trial 7 days, paid 20 days), or earlier if you delete them |
| Project records and contact details collected from viewers | until you delete them or close your account |
| Payment records | kept without a link to your account after you delete it, for 6 years from the end of the calendar year in which the financial year ended (bookkeeping law) |
| Support tickets | kept without a link to your account after you delete it; the email address and technical details are cleared 24 months after the ticket is resolved |
| Record of Terms acceptance | while your account exists |
| Server logs (IP address, browser details) | cleared after 90 days (shorter at our hosting provider) |
| Error reports (Sentry) | up to 90 days |
A.5 Deleting your account
You can delete your account in the app. This deletes your projects, photos, collected contacts and your sign-in. The payment records and support tickets described above remain, unlinked from you.
Part B — People who are photographed, and gallery viewers
B.1 What data is involved
- Photos of you (the image files, previews and file metadata).
- Contact details, only if you choose to enter them in the optional contact form: name, email address, phone number, company. Giving them is voluntary.
- Marketing choice: if the photographer has switched on a marketing checkbox, whether you ticked it. It is a separate box from sending the form, and ticking it is voluntary.
- Access data when you open a gallery: your IP address and browser details, the time, which photo or collection was opened or downloaded, and, if you enter a PIN, the referrer and country. A small session cookie keeps a PIN-protected gallery open for 24 hours.
B.2 Who is responsible
For the photos and the contact details, the photographer (or the company that commissioned the photos) is the controller; Fotoflo only stores and delivers them for the photographer as a processor. For the access data, which we keep for security and to stop abuse, Fotoflo is the controller.
B.3 How the data is used
- Delivering your photos: the photographer uses Fotoflo to give you a link, a QR code or a PIN for your photos.
- Contact details: used by the photographer to send you your photos and for the follow-up you were told about. If the photographer or the commissioning company wants to use your details for marketing, they act as independent controllers and need their own legal basis, normally your explicit prior consent (the optional box). Fotoflo does not use your contact details for its own marketing.
- Access data: for security, to count views and downloads for the photographer, and to prevent abuse. The photographer sees how many times photos were opened or downloaded; Fotoflo does not show viewers' IP addresses or browser details to photographers, in the app or in the contact export.
B.4 Who can see it
The photographer, the commissioning company if the photographer shares the contact list with it, and Fotoflo and its service providers as listed in A.3, which only store and deliver the data.
B.5 How long
- Photo files are deleted about 3 days after the delivery window closes (20 days for a full project, 7 for a Trial), or earlier if the photographer deletes them.
- Contact details are kept until the photographer deletes them or closes their account.
- IP address and browser details are cleared after 90 days.
B.6 Your rights, and how to use them
You can ask for access to your data, correction, deletion, restriction, to object to processing, to receive your data in a portable form, and to withdraw consent at any time. Contact the photographer first, with the details given at your photo session, because they are the controller of your photos and contact details. You can also write to info@fotoflo.co and we will pass your request to the photographer and help them respond, or answer it ourselves where we are the controller (access data). Withdrawing consent does not affect what was done before. To stop marketing messages from the photographer or the commissioning company, contact them directly; Fotoflo cannot unsend messages they have sent.
Part C — Visitors of our website, cookies and local storage
We use no advertising or tracking cookies. What we do use:
| Name / storage | Purpose | Lifetime |
|---|---|---|
| Sign-in cookies (set by Supabase) | keep you signed in | until you sign out or the session expires |
fotoflo-ref cookie | remember a referral link until you sign up | 30 days |
fotoflo-consent cookie | carry your Terms/age confirmation from the sign-up form to your account | 1 hour |
ff_guest_<project> cookie (HTTP-only) | keep a PIN-protected gallery open after you entered the PIN | 24 hours |
| Browser session storage | remember the gallery session, avoid counting a view twice, remember contact-form steps | until you close the tab |
| Browser local storage | keep an unsent support-ticket draft | until you clear it |
These are strictly necessary to provide what you asked for, so they do not need a consent banner. Vercel Web Analytics counts visits to our marketing pages without cookies and without identifying you.
Part D — People who report content
If you use our report form or email us about content, we process the name and email address you give, the web address and your description, to review the report and, where needed, to tell the account holder what was reported. Our legal basis is our legal obligations and our legitimate interest in keeping the service lawful. We keep your name and email address for 12 months after we have handled the report (or, if it was never followed up, after we received it; longer only if needed for a legal claim), and then clear them.
Part E — The desktop app
The desktop app keeps your projects and a local database on your computer. It sends your photos and project data to Fotoflo as you use it, checks for updates through our server, and sends error and performance reports to Sentry. These reports do not include your email address or IP address; you are identified only by an internal ID. From desktop version 0.6.9, location data in JPEG originals is cleared before upload.
5. International transfers
Your data is stored in the EU. Some of our service providers are part of groups headquartered outside the EEA (for example in the United States), and may access data from there, for example for support or through a global delivery network. Where that happens we rely on an adequacy decision, including the EU-US Data Privacy Framework, or on the European Commission's Standard Contractual Clauses.
6. Security
We use encryption in transit and at rest (through our infrastructure providers), access controls and per-account data separation, unguessable gallery links, PIN codes with rate limits for protected galleries, and we limit access to production systems to the people who need it. No system is perfectly secure; if a breach affects you, we will notify you and the authorities as the law requires.
7. Children
Fotoflo accounts are for people aged 13 or over, and we do not knowingly collect personal data from children under 13 through account sign-up. If we learn that we have, we delete it. Children may appear in photos and open galleries; the photographer is responsible for having the permission of a parent or guardian where the law requires it.
8. Your rights
You can ask us for access to your data, correction, deletion, restriction, objection and portability, and withdraw any consent, using info@fotoflo.co. We answer within one month. Account holders can delete their account in the app. You also have the right to complain to the supervisory authority: in Finland the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), tietosuoja.fi, or the authority in your own country.
9. Automated decisions
We do not make decisions about you based solely on automated processing, and we do not use biometric identification.
10. Changes to this policy
We may update this policy. We will tell account holders about material changes, and show the current version and its date on this page.
11. Contact
Ventured Oy, business ID 2654364-4, Erkinkuja 11, 04420 Järvenpää, Finland. Email: info@fotoflo.co. For requests from photographed people about their own photos, please contact your photographer first.