Privacy policy
Last updated: 9 August 2026
This policy explains how FotoQR processes personal data when creating private galleries, uploading photos via QR links, managing user accounts and purchasing paid gallery expansions. Processing is governed by the GDPR and Act No. 18/2018 Coll. on personal data protection.
1. Who is the controller?
The operator of FotoQR is:
- Company name: spinout, s. r. o.
- Registered office: Karpatské námestie 7770/10A, 831 06 Bratislava – Rača district
- Company registration number: 51 430 461
- Tax identification number: 2120751820
- VAT identification number: SK2120751820
- Contact email: info@spinout.sk
2. Roles in data processing
We distinguish between data needed to operate accounts and galleries, and the gallery content itself.
- Account, gallery and order data, such as the organiser's email, payer's email, gallery name, settings, technical data and information needed to process a paid expansion, are processed by us as controller.
- Gallery content, meaning photos uploaded by people with a QR link or by the organiser, is processed on behalf of the gallery organiser as a technical service provider. The organiser determines why photos are collected and with whom they are shared, and is therefore responsible for the lawfulness of their use in the gallery.
3. What data we process
| Category | Specific data |
|---|---|
| Organiser data | email, password stored only as a secure hash, the account's public key and corresponding private key stored only encrypted with the organiser's password, account creation date and last activity time |
| Gallery data | name and optional gallery message, QR link, settings for uploads, closing time, order, appearance, limits, notes, email summaries, viewing, approval and paid features, optional gallery and upload passwords stored only as one-way hashes, encrypted backup of the gallery's private key and its verification fingerprint, file limits and counts, creation and scheduled deletion dates |
| Order data | purchased gallery expansion, price, currency, payment status, whether the purchase was initiated by the organiser or a QR guest, optional payer email or email received from the payment provider, current storage limit used to calculate a standalone time extension price, payment or checkout session identifier and expansion activation time |
| Gallery content | encrypted display copies, encrypted thumbnails and, when full-quality storage is enabled, encrypted original photos or videos; file type and size, dimensions, upload time, publication status and optional guest note for the organiser |
| Technical data | IP address or its secure hash, signed random browser identifier and its distinct one-way hash for each gallery, access time, device and browser type, email summary delivery status and essential security logs |
| Business contacts | publicly listed business email of a photographer or photography business, business name, public source URL, one-off outreach status and any unsubscribe request |
4. Purposes and legal bases for processing
- Providing the service – creating accounts, creating and managing galleries, uploading, viewing, approving and publishing photos, purchasing paid expansions for one's own or another person's gallery, and downloading photos when the paid feature is active; the legal basis is performance of a contract or pre-contractual measures.
- Service security – preventing abuse, rate limiting, handling incidents and preventing unauthorised access; the legal basis is legitimate interest.
- Support and communication – answering questions, resolving errors and complaints; the legal basis is performance of a contract or legitimate interest.
- Service notifications – combined email summaries of new uploads across an organiser's galleries according to the times enabled for each gallery, and warnings before deletion; the legal basis is providing the ordered service. Both summary times can be disabled independently in gallery settings.
- One-off B2B outreach – introducing FotoQR to photographers and photography businesses using their publicly listed business contacts; the legal basis is legitimate interest in presenting a relevant complementary service and Section 116(15) of Act No. 452/2021 Coll. The address source is stated in the message. Each message provides a simple, free unsubscribe option. We do not track opens or link clicks.
- Legal obligations – particularly accounting and communication with public authorities regarding paid services.
5. Photos of third parties and children
Photos may depict people who did not upload them. The gallery organiser is responsible for obtaining any necessary consent or other appropriate legal basis for collecting, making available and potentially downloading photos in that gallery. The organiser must also appropriately inform participants that photos may be available to others with the QR link, possibly subject to paid gallery passwords, upload passwords, photo approval before publication or paid downloads.
For photos of children, school events, clubs and similar situations, the organiser should exercise particular care and obtain the consent of a legal guardian or another legal basis where required.
As a technical service provider, FotoQR does not select the people in photos, determine a particular gallery's purpose or review content before publication. If photo approval is enabled, the gallery organiser decides whether to publish or hide a specific photo. We are not responsible for whether the organiser obtained necessary consent or fulfilled information duties towards people depicted; this does not affect our statutory obligations following a valid report of illegal or unlawful content.
Anyone who believes a photo in a gallery infringes their rights can contact the gallery organiser or us at info@spinout.sk. We will help remove content where a request is justified.
6. Where data is stored and who receives it
The service is hosted by Hetzner in Germany. Gallery and account data and encrypted files are stored in the European Union.
We retain order and purchase data primarily to administer the service, provide support, handle complaints and refunds, and for accounting. When a QR guest makes a purchase, we record that the expansion was paid for a particular gallery, but do not use payment data to grant access to gallery management. On account closure, we delete this data with the account unless legislation requires longer retention, for example for accounting documents.
| Provider | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Service operation, database and private storage of encrypted photos | Germany, European Union |
| Stripe Payments Europe or the relevant Stripe company | Processing online payments and related payment confirmations | EU/EEA or other countries according to the provider's documentation and safeguards |
| Websupport, s. r. o. | Sending service and verification emails, such as email verification, new-upload summaries and warnings before gallery deletion; the recipient's email address is provided for delivery | Slovakia, European Union |
| Websupport, s. r. o. | Sending one-off business outreach; the recipient's email address and message content are provided | Slovakia, European Union |
We do not sell data, provide it to advertising networks or use it for third-party advertising profiles.
7. How encryption and the private key work
Photos are encrypted in the user's browser before upload. The server receives an encrypted smaller display copy, an encrypted thumbnail and technical data needed to operate the gallery. If full-quality storage is enabled, an encrypted original may also be stored in a free gallery, ready for a later paid expansion; the paid expansion unlocks access and downloading. If full quality is disabled, only a compressed version is stored. Photos cannot be displayed in readable form without the private key.
Besides photos, the gallery's private key encrypts the optional guest note, the organiser's message to guests, custom upload confirmation and custom QR poster text. Only a person with the key (usually the organiser) can read these texts, and the operator normally cannot see them in readable form. The gallery name and other operational metadata remain unencrypted by the private key, including file type and size, dimensions, upload time and whether a photo is published or hidden. We do not store the original uploaded filename; downloads use a random identifier. Before encryption and upload, we also remove embedded metadata from photos and videos, such as EXIF and GPS location and device information.
The gallery's private key is not stored on the server in readable form. It is part of the private link or QR code and may be stored in the organiser's browser.
If the organiser has a password-protected account, the gallery key is automatically saved to the account in encrypted form. It is encrypted using the account's public key; the private half of this pair is protected by the organiser's password and, in normal use, is unlocked only in their browser. During registration, login and password verification, the password is transmitted to the server over encrypted HTTPS, but we do not store it in readable form. The database or stored backup alone is therefore insufficient to obtain the gallery key or view photos. This lets the organiser access the gallery from another device without keeping the QR link separately.
This protection assumes an uncompromised browser, device and FotoQR application code. Malicious code running in the browser or complete compromise of the active application server could capture data during use. Backup encryption primarily protects stored data in a standalone database or storage leak.
We also store a verification fingerprint of the gallery key. This is a one-way hash of the random key from which the key cannot be recovered. It lets the browser detect an incorrect key before it overwrites a valid backup.
After a paid purchase, the organiser may also enable an optional gallery password for guests, a separate upload password or photo approval before publication. Passwords provide an additional access check and are stored only as one-way hashes; we cannot display or recover them after they are set. Approval only determines whether an uploaded photo appears to people with the QR link. These are not photo encryption keys.
If the organiser loses the private key and cannot recover it from their account, FotoQR cannot recover or decrypt the encrypted photos.
8. How long we retain data
- Gallery content is retained only while the gallery is active. FotoQR is a temporary service for collecting and delivering photos, not permanent storage, a backup or an archive. Galleries are normally deleted automatically after 7 days unless the organiser extends validity or deletes them earlier. Every paid purchase sets the particular gallery's validity to 30 days from purchase.
- Warnings before deletion are sent to the organiser if we have their email. For paid galleries, warnings are sent approximately 7 days, 3 days and 1 day before deletion; for free galleries, approximately 1 day before deletion.
- Gallery deletion means permanent deletion of records and stored encrypted files, including originals, display copies and thumbnails. We do not move photos to a bin for later recovery, and they cannot be recovered after deletion.
- The organiser's account is retained while the service is used. Inactive accounts may be deleted after 1 year of inactivity, together with their galleries.
- Security logs are retained only as long as necessary to protect the service.
- One-off B2B outreach data including the address, public source and delivery history is deleted no later than 12 months after the campaign ends. Following an unsubscribe request, we retain only an irreversible keyed hash of the address to avoid accidentally contacting it again in a future import.
- The guest note and browser identifier hash are retained only with the particular upload and are removed when the photo or gallery is deleted.
- Email summary status is retained until the gallery is deleted. The technical browser identifier cookie lasts no more than one year; the note preference in local storage remains until the user deletes it.
- Paid order data and accounting documents, where generated by a paid service, are retained for statutory periods. This also applies to expansions paid for by QR guests for an organiser's gallery.
9. Your rights
You have the right to request access to personal data, rectification, erasure, restriction of processing and data portability, and to object to processing based on legitimate interest. Where processing is based on consent, you may withdraw that consent at any time.
You can exercise your rights by emailing info@spinout.sk. We will respond within one month unless legislation permits a longer period.
10. Right to lodge a complaint
If you believe processing does not comply with applicable legislation, you may contact the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava, dataprotection.gov.sk.
11. Cookies
FotoQR uses only essential technical cookies and similar technologies, such as local and session browser storage. These support login, form protection, secure sessions, storage of the private QR key, payment returns, remembering optional note preferences and a soft upload limit per browser. The random limit identifier is signed against tampering, is HttpOnly and has a different hash for each gallery. We do not use advertising cookies, analytics cookies or third-party tracking.
12. Security
We take appropriate technical and organisational measures: encrypted transmission, private storage, rate limiting, separate access controls, optional paid guest passwords, photo approval before publication and data deletion after gallery expiry. Because content is encrypted before upload, the operator normally cannot see photos in readable form.
13. Changes to this policy
We may update this policy as the service develops or providers change. The current version is always available on this page with its last-updated date.