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Privacy Policy

Compliant with GDPR (EU 2016/679) and the French Data Protection Act. Last updated: to be completed.
Fotelya reference document. The fields [in brackets] will be completed upon company creation. Approach privacy-by-design , and data minimization.

1. Data Controller

The data controller is [COMPANY NAME / LEGAL ENTITY], [ADDRESS]. Contact: contact@fotelya.com. [Data Protection Officer (DPO): to be appointed if applicable.]

2. Our principle

Fotelya is built around minimization : Guests share their photos and videos , without an account or registration. We only collect what is strictly necessary for the Service to function. We do not sell any data, display any ads, or use data to train third-party artificial intelligence.

3. Data processed

4. Purposes and legal bases

PurposeLegal basis
Service provision (album, live wall, download)Contract performance; guest consent for scanning
Security, abuse and fraud preventionLegitimate interest
Content moderationLegitimate interest and legal obligation
Billing and accountingLegal obligation
Privacy-friendly analyticsLegitimate interest (aggregated/anonymized data)

5. Recipients and subprocessors

We work with carefully selected subprocessors, bound by a Data Processing Agreement (DPA), and prioritize processing within the European Union. Data recipients fall into the following categories:

A detailed list of our subprocessors is available upon request at contact@fotelya.com. No data is sold or shared for advertising purposes.

Automated AI moderation. When enabled by the organizer (three-level setting, disableable), photos, videos and messages sent may be automatically analyzed by our subprocess Mistral AI (European Union) to detect manifestly inappropriate content (explicit nudity, violence, etc.). This analysis does not make any final decisions on its own: the organizer retains control and the final say (validation, restoration or manual removal). No data is used to train AI models.

6. Transfers outside the European Union

Our data is by principle hosted and processed within the European Union. When a subcontractor involves processing outside the EU, it is governed by appropriate safeguards (European Commission standard contractual clauses and additional measures).

7. Retention periods

8. Security

Media are encrypted in transit and at rest (AES-256). Access is granted via signed expiring links and a code (PIN), on non-public galleries, with non-enumerable identifiers. EXIF location metadata is removed. Administrative access is protected by two-factor authentication.

9. Your rights

In accordance with the GDPR, you have the rights toaccess, rectification, erasure, objection, restriction, portability, the right to withdraw your consent at any time, and to set directives regarding the fate of your data after your death. Any identifiable person in media has a right to image and may request its removal. To exercise your rights: contact@fotelya.com. We respond within one month.

10. Complaint

You may lodge a complaint with the CNIL (French data protection authority, cnil.fr).

11. Minors

The Service is not intended for persons under 15 years of age without the consent of a parent or legal guardian. We delete any data of a minor brought to our attention in the absence of such consent.

12. Residents outside the European Union

We apply a GDPR-inspired protection standard worldwide. Specific rights may apply depending on your place of residence:

13. Cookies

The use of cookies is detailed in our Cookie Policy. No advertising trackers are used.

14. Changes and contact

This policy may evolve. The applicable version is the one published on this page. For any questions regarding your data: contact@fotelya.com.