Privacy
Policy.
Your photographs are the most personal thing you entrust to us. Here, in plain language, is what we do with them, how long we keep them and what you can ask of us at any time.
1. Who processes your data
The controller under the GDPR is:
- Bab City Studio — Štefan Biro
- Registered office: Iglaseegasse 21–23, 1190 Vienna, Austria
- Tax number (Steuernummer): 09 337/4601
- Registered with: Magistrat der Stadt Wien, no. 29780976
- E-mail: sales@framebook.eu, telephone: +421 910 93 94 93
We have not appointed a data protection officer — we are not required to. For data protection matters write directly to the address above.
2. What data we process
Contact and order details
- name, e-mail address and, where given, telephone number
- billing details, where an invoice is required
- the content of our correspondence and the details of your order
The photographs you send us
A photograph is personal data whenever an identifiable person appears in it. Along with the images we also process the data the files carry — the date and time of the shot, technical details of the device and sometimes the location (EXIF).
We never use photographs for facial recognition or any other biometric identification. We do not process them as a special category of data under Article 9 GDPR.
Website usage data
We measure traffic with Umami Analytics (Umami Software, Inc.; servers in the European Union). It collects aggregate, anonymous data only — the page visited, where you came from, the type of device and the country. We also record whether you submitted a form, opened a sample book or clicked a contact link, so that we know which parts of the site are useful.
The service uses no cookies or other browser storage, does not store your IP address and does not derive any persistent identifier from it. We cannot recognise you between visits or follow you across other websites. That is why we do not ask for cookie consent — there are no cookies to consent to. The legal basis is our legitimate interest in a website that functions properly and is easy to use (Article 6(1)(f)).
There are no advertising or tracking scripts on this website.
The typefaces are loaded from Google Fonts. Your browser fetches them directly from Google’s servers, which means Google sees your IP address in the process. No other data is transferred.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Replying to an enquiry before an order | Steps prior to entering a contract — Article 6(1)(b) GDPR |
| Designing the photo book and delivering the work | Performance of the contract — Article 6(1)(b) |
| Passing files to the manufacturer for printing | Performance of the contract — Article 6(1)(b) |
| Issuing and archiving accounting records | Legal obligation — Article 6(1)(c) |
| Publishing a sample of your book in our portfolio | Your consent — Article 6(1)(a) |
| Defending a complaint or dispute | Legitimate interest — Article 6(1)(f) |
Publication in the portfolio is always voluntary. Withholding or withdrawing consent changes neither the price nor the way your book is made.
4. Photographs of children
Where photographs show children under 16, consent to their publication must be given by their legal guardian. Without it we never publish photographs of children — neither in the portfolio nor on social media.
No consent is needed to make the book itself; that is done under our contract with you. Consent concerns publication only.
5. Who we share data with
We do not sell your photographs or make them available for anyone else’s advertising. We share them only with those whose involvement is necessary to provide the service:
| Recipient | Reason |
|---|---|
| Photo book manufacturer (of your choosing) | Printing and production from the prepared files — we pass them only to the manufacturer you name in the order |
| Cloud storage for file transfer | Secure delivery and collection of photographs |
| E-mail and web hosting provider | Corresponding with you and running the website |
| Umami Analytics (servers in the EU) | Anonymous, cookie-free website statistics |
We list categories of recipients; we will provide the names of the individual processors at any time upon request — just write to the address above. We have a data processing agreement under Article 28 GDPR with each of them. Where any of them processes data outside the EU, this is done under standard contractual clauses approved by the European Commission.
6. How long we keep data
| Data | Period |
|---|---|
| Enquiry with no order | 6 months from the last message |
| Photographs supplied and working files | 90 days after delivery, then permanent deletion |
| Final print file | 12 months (in case of a reprint) |
| Accounting records | 7 years — statutory period under § 132 of the Austrian Federal Fiscal Code (BAO) |
| Material published with consent | Until consent is withdrawn |
We e-mail you before deleting photographs so that you have time to ask for the files. Backups are overwritten continuously, so deleted data is removed from them within 30 days at the latest.
7. How we protect data
- Only the person working on the book has access to the photographs
- Devices are password protected with full-disk encryption
- Transfer links are time limited and revoked once collected
- Photographs are never stored on publicly accessible drives or sent over unencrypted channels
8. Your rights
Under the GDPR you have the right to:
- know what data we hold about you and receive a copy of it
- have inaccurate data corrected
- have your data erased, including your photographs
- restrict the processing or object to it
- have your data transferred to another provider
- withdraw consent to publication at any time — withdrawal does not affect the lawfulness of processing before it
Just write to sales@framebook.eu. We reply within 30 days at the latest.
If you are not satisfied with our handling, you may lodge a complaint with a supervisory authority. As we are established in Austria, the relevant authority is the Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, dsb.gv.at. You may also lodge a complaint with the supervisory authority in your country of residence.
9. What you are responsible for
By supplying the photographs you confirm that you hold the rights to them and that the people shown agree to their use in the book. Where children appear, you confirm that you are their legal guardian or have that guardian’s consent. If a professional photographer took them, make sure your licence permits further processing.
10. Changes to this policy
We may update this policy. The current version is always on this page with its effective date. Where a material change affects your rights, we will notify you by e-mail.