PortraitDock · ILO APPLICATIONS SL

Privacy Policy

Last reviewed 14 September 2026 · Version 2026-09-14-v1

Who is responsible for your data

ILO APPLICATIONS SL, trading as PortraitDock. Tax ID (NIF) B93663862; EU VAT ESB93663862. Registered address: Calle Artemisa 2, 29640 Fuengirola, Málaga, Spain. Legal, privacy and customer enquiries: [email protected].

We are the controller for personal-customer orders, user accounts, billing, security and support. For portraits uploaded by a business or team on its instructions, that organisation is normally the controller and we act as its processor. Ask the organisation about its purpose, lawful basis, publication choices and retention of copies it downloads. We can help route your request to it.

What we collect and where it comes from

Your uploaded portrait is private. We receive photos, logos, chosen backgrounds, framing guides, filenames, optional person references and review decisions from you or your team administrator. Processing creates a foreground mask, placement measurements, previews, output images, batch status and error records.

We also process account and contact details, authentication and recovery records, purchase and payment references, credit transactions and support correspondence. Requests generate technical information such as IP address, timestamps, browser information and security logs. Stripe handles payment-card information; PortraitDock does not store full card details. Providing the source, required account details and payment information is necessary for the corresponding service; optional person labels and analytics are not.

Purposes and lawful bases

Provide your personal order and respond to pre-contract enquiries: performance of a contract or steps you request before it (GDPR Article 6(1)(b)).
Invoices, accounting and legal obligations: compliance with applicable law (Article 6(1)(c)).
Account security, fraud prevention, service diagnostics, business contacts and legal claims: our legitimate interests in a reliable service and protecting rights (Article 6(1)(f)), balanced against your rights. You may object.
Optional analytics, if enabled: your consent (Article 6(1)(a)), which you may withdraw at any time through cookie preferences.
Team portrait processing: the organisation’s documented instructions under its data processing agreement; the organisation must establish its own lawful basis.

How photo processing works

The configured OpenAI API receives portrait image content to extract a foreground mask and measure placement. PortraitDock then uses the original person’s colour pixels to compose the selected background and framing. Image processing is automated, but it is not an identity-verification or facial-recognition service and is not used to infer sensitive traits or make decisions about employment or eligibility. You or your team review the result.

We do not use customer photos to train our own models, sell them, or publish them in marketing without separate permission. Provider-side handling, safety review and retention depend on the contracted API service; a local deletion does not establish immediate deletion at a provider. We do not promise zero retention or processing exclusively within the EU. Optional generative editing is not enabled in this workflow.

Who can receive data

Access is limited to authorised users, personnel who need it for service or support, and providers involved in delivery. Team administrators and holders of authorised API credentials can access their workspace data. Keep private recovery and access links confidential.

Provider categories include OpenAI for photo processing, Stripe for checkout, infrastructure providers for hosting and private storage, and the configured transactional-email provider for account or service messages. Authorities and professional advisers may receive limited records where legally required or necessary for legal claims. Optional Google Analytics receives public-page usage data only after consent when configured, not the portrait files.

Provider and transfer details show the public runtime disclosures. Processing countries, the applicable transfer mechanism and provider retention must be verified for the deployed service; incomplete entries are not evidence of EU-only processing.

International transfers

Where a provider accesses personal data outside the EEA, the transfer needs a valid GDPR basis, such as an applicable European Commission adequacy decision or standard contractual clauses with any necessary additional safeguards. Ask [email protected] for the safeguards applicable to your data and how to obtain a copy. A provider’s brand name or an EU server location alone does not establish the legal basis for every transfer.

How long data is kept

Unpurchased portraits: 7 days from creation or the latest successful unpaid preparation, unless bought.
Purchased portraits: 30 days from confirmed payment. Successfully processed team portraits expire 30 days after their latest preparation.
Team brand assets and presets: retained for reuse while the workspace needs them, independently of the portrait-media expiry. Contact us to remove assets that cannot be removed in the workspace.
Account and support data: for the active relationship and as necessary to handle outstanding requests, disputes, security incidents or legal obligations. A rights request can ask us to assess and delete records no longer needed.
Required business records: Spanish commercial accounting records are generally kept for six years from the last accounting entry, with longer retention only where another legal requirement or unresolved claim requires it. This does not justify keeping portrait images for six years.

Expiry or deletion blocks normal access; queued cleanup removes stored source files, masks and exports. Cleanup can be delayed by active processing or errors requiring a retry. Backup and provider copies have separate schedules, so physical removal is not necessarily immediate. The deployed backup maximum and provider-specific retention are still awaiting verification before customer-data launch; they must be published here when confirmed. We do not treat the 7- or 30-day working expiry as a proven backup-deletion deadline.

Your rights and how to use them

You may request access and a copy, correction, erasure, restriction, and portability where applicable. You may object to processing based on legitimate interests and withdraw consent without affecting earlier lawful processing. These rights have legal conditions; we explain any limitation, including records that must be retained.

Email [email protected] or use our contact form. Include enough information to locate your account, order or team, but do not send a password, API key or an identity-document copy unless a secure verification method is specifically arranged. We may request proportionate identity evidence. Guest users can contact us without creating an account. For an organisation’s photos, we assist its controller with your request.

We normally respond within one month. If a complex or numerous request needs up to two further months, we explain the extension within the first month. Requests are normally free. You can complain to the Spanish Data Protection Agency (AEPD) or the supervisory authority where you live, work or consider an infringement occurred.

Security, children and changes

Private media access is checked against a guest capability, authenticated account or authorised API key. Access restrictions and deletion controls reduce risk, but no service can guarantee absolute security. Contact us promptly if a private link or credential has been exposed.

The service is not directed at children acting alone. An adult or organisation arranging a child’s portrait must have an appropriate lawful basis and provide information the child can understand. Avoid sensitive or unnecessary personal information. We update this notice when the service changes, show the review date, and give additional notice of material changes where required.