Last updated: 30 May 2026
In accordance with Article 13 of Regulation (EU) 2016/679 (GDPR), we inform you about the processing of your personal data when using the PhotoID24 service. This notice supplements the Privacy Policy.
1. Data controller
The data controller is FOP Shelekhan O.N. (RNOKPP / individual tax number 2853810181), address: Ukraine, Kharkiv, vul. Berestova 11, apt. 1, the operator of the PhotoID24 service. Email: [email protected].
Because the Service is offered to individuals located in the European Union, the processing falls within the scope of the GDPR pursuant to Art. 3(2) of the Regulation, as well as other applicable data protection law.
2. Purposes and legal bases of processing
providing the photo-processing service — Art. 6(1)(b) GDPR (performance of a contract);
processing the uploaded photo — Art. 6(1)(a) GDPR (your consent, which can be withdrawn at any time);
fulfilling payment and accounting obligations — Art. 6(1)(c) GDPR (legal obligation);
preventing abuse and ensuring the security of the service — Art. 6(1)(f) GDPR (legitimate interest).
The photo is processed as ordinary personal data. Automatic face recognition is used only for cropping and checking compliance with the requirements; biometric templates for the unique identification of a person (Art. 9 GDPR) are not created.
3. Data recipients
Data may be transferred to processors (Art. 28 GDPR) only to the extent necessary to provide the service:
cloud image-processing provider — a third-party cloud artificial intelligence service for the automatic processing of the uploaded photo;
Payment provider — processing of payments;
Hosting provider — storage of data and files.
4. Transfers outside the EEA
Some processors (in particular the cloud image-processing provider) may process data outside the European Economic Area. In such cases, the transfer is carried out on the basis of appropriate safeguards under Chapter V of the GDPR — in particular the Standard Contractual Clauses (SCC) approved by the European Commission.
5. Retention periods
original photo — deleted immediately after processing (in case of a processing error — no later than 24 hours);
watermarked preview — up to 24 hours;
finished result file — deleted after the first download; in any case no later than 72 hours after payment;
technical processing record (anonymised) — up to 30 days;
email address and transaction data (identifier, amount, date) — stored together with the order record for the period required by applicable tax and accounting legislation;
name (if you provided it for a personal guide) — stored with the order record and deleted upon your request.
6. Your rights
You have the right to:
access your data (Art. 15 GDPR);
rectification (Art. 16 GDPR);
erasure (Art. 17 GDPR);
restriction of processing (Art. 18 GDPR);
data portability (Art. 20 GDPR);
object to processing (Art. 21 GDPR);
withdraw consent at any time without affecting the lawfulness of prior processing (Art. 7(3) GDPR);
lodge a complaint with a data protection supervisory authority (Art. 77 GDPR) — in your country of residence in the EU.
To exercise your rights, contact [email protected] or use the data deletion form.
7. Voluntary provision of data
Providing the data is voluntary but necessary to provide the service. Without the required data it is not possible to use the service.
8. Automated processing
The photo is processed automatically (artificial intelligence algorithms check compliance with the requirements and generate the result). This is not a decision producing legal effects concerning you or similarly significantly affecting you within the meaning of Art. 22 GDPR — the result of processing is only a graphic file. No profiling is carried out.