Privacy Policy
Last updated: October 2026
1. What Data We Collect
When you use PhotoPass ID, we may collect the following information:
- Your name and email address (when you place an order)
- Your phone number (optional)
- Photos you upload for processing
- Payment information (processed securely via Stripe — we never store card details)
- Technical data such as IP address and browser type (for security and analytics)
2. How We Use Your Data
- To process your order and deliver the requested photo service
- To contact you regarding your order status
- To comply with legal obligations
- To improve our service (anonymised analytics only)
3. Photo Storage and Deletion
Photos you upload are used solely to generate your formatted passport or visa photo. Both your original upload and the processed image are automatically and permanently deleted from our servers within 72 hours of your order being processed. Download links for a paid digital order work until the photo is deleted. We never reuse or sell your photos, and we do not share them with anyone other than the image-processing providers listed in section 5, who act as our processors under contract and are not permitted to use your photo for any other purpose.
Our software detects where your face is in the photo so it can be cropped, sized and checked. We never create, keep or share a face template or any other biometric identifier. Every upload records which version of this notice you were shown, the time, the storefront country and a one-way hash of your IP address (never the address itself).
Retention schedule
| What | How long we keep it |
|---|---|
| Your uploaded photo, the finished photo, the print sheet and the watermarked preview | 72 hours after the photo is made, then permanently deleted |
| Download links for your photo | Before payment, 24 hours after the photo is made; once paid, until the photo is deleted (72 hours after it was made) |
| Anonymous order-step analytics (no name, email or IP address) | 90 days |
| Visit counts measured on our own servers, with no cookie (page, country, region and city from your connection, the site or campaign that sent you, device type, operating system and browser family, whether the visitor is a browser or a bot, and the type of network; a one-way hash of your IP address, never the address itself, and no hash at all if your browser sends Global Privacy Control). If you place an order, the same visit details are kept with the order so we can help you with it | 90 days |
| Record of emails we sent you (address, subject, time) | 12 months |
| Order change history kept for security and support | 24 months |
| Record of the privacy notice or biometric consent shown at upload (version, time, country, a one-way hash of your IP address) | 24 months |
| The email address you chose to leave on a free tool page, the tool and document, the consent wording you accepted, the time and a one-way hash of your IP address | 24 months, or until you unsubscribe or ask us to delete it |
| The email address you chose for a renewal reminder, your document type and expiry month, the consent wording you accepted, the time and a one-way hash of your IP address | Until the reminder is sent (a reminder can be at most 11 years ahead), then 24 months; a reminder we could not send is deleted 24 months after its date. Sooner if you unsubscribe or ask us to delete it |
| Your referral code, the referral rewards you earned (amount, time, the friend's order number) and the reward codes we emailed you | 24 months, or until you ask us to delete them. A record that you unsubscribed is kept as a one-way hash so we do not email you again |
| Your data access or deletion requests and how we answered them | 24 months |
| Messages you send our support team, our replies and any photo-rejection claim (with the country, city and type of device you wrote from) | 24 months |
| Order and invoice records (amount, date, document type) | 6 years, as Irish tax law requires; your name and contact details are then removed |
4. Legal Basis for Processing
We process your personal data under the following legal bases:
- Contract performance — to fulfil your order
- Legitimate interests — to improve our service and prevent fraud
- Legal obligation — to comply with Irish and EU law
5. Data Sharing
We do not sell your personal data. We may share limited data with:
- Stripe — for secure payment processing
To produce your photo, the image itself is sent to the following image-processing providers, who act as our data processors and are contractually prohibited from using it for any other purpose:
- OpenAI and Anthropic (United States) — automated AI check that a compliant photo can be made and what the applicant is wearing
- Cutout.pro (Hong Kong SAR) — background removal and cropping to official dimensions
- remove.bg (Germany) — background removal, used as a fallback
Transfers to providers outside the European Economic Area are made under the European Commission’s Standard Contractual Clauses. Photos sent to these providers are deleted in line with the 72-hour retention period described in section 3.
6. Your Rights
Under GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction or deletion of your data
- Object to or restrict processing
- Lodge a complaint with the Data Protection Commission (Ireland)
To exercise your rights, use the request form below or email us at privacy@photopass.ie. We confirm it is you by matching the email address and order number, and we reply within 30 days.
7. Cookies and advertising measurement
Strictly necessary cookies are always used to operate the website. Analytics and advertising cookies are used only if you choose "Accept all" in the cookie banner; choosing "Reject all" keeps them off, and you can change or withdraw your choice at any time with "Cookie settings" at the bottom of every page. Live chat (Tawk.to) also loads only after "Accept all".
If you accept, the following services may set cookies and receive information about your visit and, if you place an order, the fact and value of that order: Google Analytics, Google Ads, Meta (Facebook and Instagram), TikTok and Reddit. Where you have accepted, your email address may be shared with these services in hashed (one-way encoded) form so that they can match an order to an advert you saw; the address itself is not sent. Your photo is never shared with any advertising service.
Each of these providers acts as an independent controller for the data they receive; their own privacy notices apply to their use of it. You can disable cookies in your browser settings, though this may affect functionality.
8. Your privacy rights in Bahamas
Draft: pending legal review (PHOT-26)
Law that applies: Data Protection (Privacy of Personal Information) Act 2003.
Regulator: Office of the Data Protection Commissioner
Your rights in Bahamas:
- Access
- Correction
- Prevent processing for direct marketing
- Complain to the Data Protection Commissioner
Use the privacy request form or email our privacy mailbox.
9. Who processes your data
Every service that receives personal data from us, what it is used for, where it is processed and the legal basis for any transfer:
| Service | Purpose | Data | Location | Transfer basis |
|---|---|---|---|---|
| Stripe | Card and wallet payments, fraud checks | Name, email, billing details, payment card (held by Stripe only) | EU (Ireland) and United States | EU-US Data Privacy Framework and Standard Contractual Clauses |
| Google Cloud (Cloud Run) | Runs our servers and makes your photo | Photo (deleted within 72 hours), order details, hashed IP address | United Kingdom (London, europe-west2) | UK adequacy decision |
| Neon | Our order database | Order details, contact details, photo for up to 72 hours | To be confirmed (hosting region under legal review) | Standard Contractual Clauses where outside the EEA |
| Netlify | Hosts the website | IP address and browser details in server logs | United States and global edge network | Standard Contractual Clauses |
| OpenAI | Automated check that a compliant photo can be made | Your photo (not kept for training) | United States | Standard Contractual Clauses |
| Anthropic | Automated check that a compliant photo can be made | Your photo (not kept for training) | United States | Standard Contractual Clauses |
| Cutout.pro | Background removal and cropping to official size | Your photo | Hong Kong SAR | Standard Contractual Clauses |
| remove.bg (Kaleido) | Background removal (fallback) | Your photo | Germany (EU) | Not needed (within the EU) |
| Namecheap Private Email | Sends order and photo emails | Email address, name, order details, photo attachment | United States | Standard Contractual Clauses |
| Tawk.to | Live chat (loads only after you accept all cookies) | Chat messages, IP address, browser details | United States and EU | Standard Contractual Clauses |
| Trustpilot | Customer reviews (only if you choose to leave one) | Name and email if you review us | Denmark (EU) | Not needed (within the EU) |
| Google Analytics and Google Ads | Site analytics and advert measurement (only after "Accept all") | Cookie IDs, pages visited, order value, hashed email | United States | EU-US Data Privacy Framework |
| Meta (Facebook, Instagram) | Advert measurement (only after "Accept all") | Cookie IDs, pages visited, order value | United States | EU-US Data Privacy Framework |
| Advert measurement (only after "Accept all") | Cookie IDs, pages visited, order value | United States | Standard Contractual Clauses | |
| TikTok | Advert measurement (only after "Accept all") | Cookie IDs, pages visited, order value | United States, Singapore, Malaysia | Standard Contractual Clauses |
10. Contact
For privacy-related queries, contact us at:
Ingenie Technologies Ltd
Ireland
privacy@photopass.ie