Privacy policy

Who processes the data

The data controller is TECH EVENT SRL, tax number 49696690, VAT number RO49696690. For any question about your data, write to us at contact@photoboothcraft.com.

What data we collect

For an order we need your name, email, phone and country. The country is asked on every order, however small, because the payment processor requires it and because the list in the form is exactly the list of countries we sell to; it stays recorded on the order. The street and the town we ask for only when we have something to send you or when the order is placed by a company, because a company invoice is issued on the company's own details; for a file bought by an individual we do not need them. For company orders, the company name and the tax number.

We do not ask for a personal identification number at checkout. We do not need one to issue your invoice.

For a company in an EU country other than Romania, the VAT number is checked in VIES, the European Commission service, because the reverse charge requires a valid number. We send the number and the country there, and the answer is kept on the order as proof of the check.

Card details never pass through our site. The payment happens on the page of the payment processor, Stripe Payments Europe, Limited.

When you write to us on WhatsApp, Messenger or Instagram, we have your profile name, your phone number (on WhatsApp) and the messages.

Why we use it

To perform the contract: to produce, to invoice and to deliver. The legal basis is the performance of the contract.

To meet our tax and accounting obligations. The legal basis is the legal obligation, and the retention period is the one the law sets for financial documents.

Who we share it with

The payment processor, Stripe Payments Europe, Limited, to collect the money. The courier company, to deliver. The invoicing provider, to issue and send the fiscal documents to the Romanian tax authority.

The AI provider of the shop assistant, Anthropic or OpenAI, for the text typed into the assistant, as described in the section The shop assistant.

Only after consent in the cookie banner: Google Analytics and Microsoft Clarity, for statistics and interaction analysis; Meta Platforms Ireland Ltd. (Facebook, Instagram) and, from the moment we link Google Analytics to a Google Ads account of ours, Google Ads, for ad measurement and personalised ads. Separately, Meta, for the conversations you start with us on WhatsApp, Messenger or Instagram, as described below.

We do not sell data to anyone. If you accept, Meta and, once our Google Ads account is linked, Google use your visit to the site to measure ads and to show you personalised ads, which is profiling for advertising. If you refuse the banner, none of this happens on the site.

Traffic statistics

Microsoft Clarity provides click maps, scroll maps and visit replays on public pages. It is not enabled on administration, sign-in, search, checkout forms or private order pages. Sensitive content is masked. For Clarity we do not enable advertising storage.

Microsoft Ireland Operations Limited and Microsoft process Clarity data under the Microsoft Privacy Statement (https://privacy.microsoft.com/privacystatement); processing may take place outside the EEA. Clarity uses pseudonymous identifiers and the _clck and _clsk visitor/session cookies. Microsoft describes these and possible third-party cookies at https://learn.microsoft.com/clarity/setup-and-installation/clarity-cookies.

Clarity recordings are normally available for 30 days; favourites and some samples may be retained for up to 9 months. Withdrawal does not automatically delete data already collected by providers.

For consenting orders we separately keep Analytics identifiers until consent expires or is withdrawn, for at most 180 days. The HttpOnly pbc_analytics_handle cookie enables withdrawal and has the same maximum lifetime. Order placement, full receipt and refunds are sent from our server to Google without contact details or the private order link.

Withdrawal stops browser collection immediately. Unsent events are cancelled after server acknowledgement; if the connection fails, we show a message and retain the withdrawal request locally for retry until acknowledged. Requests already in flight may complete before withdrawal is acknowledged.

If you accept in the cookie banner, we use Google Analytics 4 to see how the shop is read: the pages visited, the products viewed, added to the cart and ordered, with the product name, the price, the order number and the totals, the type of device and browser, and the approximate location Google derives from the IP address. Your name, email, phone, address and the access link to your order never reach it.

The legal basis, for statistics and for advertising, is your consent: article 6(1)(a) GDPR and article 4(5) of Romanian Law 506/2004. You can withdraw it at any time, from the cookie policy page, with immediate browser shutdown and separate confirmation for server deliveries.

For statistics, Google Ireland Limited processes this data on our behalf, as a processor. For advertising, the roles are those in the next section.

The retention period in Google Analytics is 14 months from your last visit, after which Google deletes the data. The details on cookies, durations and transfers are in the cookie policy.

Advertising, only with your consent

If you accept and Google Analytics is linked to a Google Ads account of ours, Google uses the data from Google Analytics to measure Google ads and to show you personalised ads. For these purposes Google Ireland Limited is an independent controller, under the Google Ads Controller-Controller Data Protection Terms (https://business.safety.google/controllerterms/); Google describes how it uses data from partner sites at https://policies.google.com/technologies/partner-sites.

If you accept, the Meta Pixel also loads on the shop's public pages. Meta receives the page address, the IP address, browser and device information, Meta's cookies, and four events: page visited, product viewed, product added to the cart, and a tap on the WhatsApp link, with the product code, the price, the currency and the number of items. We do not send it your name, email, phone or address, the pixel's automatic configuration is switched off, and no purchase event leaves the browser. Meta may link this data to your Facebook or Instagram account.

The Meta Pixel does not load in the cart, at checkout, on order pages, in search, on the contact page, at sign-in or in administration.

For the collection and transmission of this data through the Meta Pixel, TECH EVENT SRL and Meta Platforms Ireland Ltd. are joint controllers, under the Meta Controller Addendum (https://www.facebook.com/legal/controller_addendum). Meta alone is responsible for what it does with the data afterwards, under the Meta Privacy Policy (https://www.facebook.com/privacy/policy/), and you can also exercise your rights directly with Meta.

Google and Meta may transfer the data to the United States, under the EU-US Data Privacy Framework and standard contractual clauses.

We do not set how long Google Ads and Meta keep this data: the periods are those in their policies, https://policies.google.com/technologies/retention and https://www.facebook.com/privacy/policy/. The cookies and their durations are in the cookie policy.

Conversations on WhatsApp, Messenger and Instagram

Conversations on WhatsApp go through WhatsApp Ireland Limited, and those on Messenger and Instagram through Meta Platforms Ireland Ltd.; each processes them under its own terms and privacy policy (https://www.whatsapp.com/legal/privacy-policy-eea, https://www.facebook.com/privacy/policy/). We use them to answer you and to carry out your order; replies before and after an order rest on the contract, including the steps before it taken at your request (article 6(1)(b) GDPR).

When a channel is connected to our Facebook Page and the Page's data sharing is on, business activities marked by us or automatically by Meta's tools (for example an order, what was ordered, the shipping region, labels and conversation stages) are shared with Meta to measure and improve our ads, including showing our ads to people similar to customers. Meta processes this data under the Meta Business Tools Terms (https://www.facebook.com/legal/businesstech), which include the Controller Addendum, and its privacy policy.

The legal basis is our legitimate interest, article 6(1)(f) GDPR: to know whether our ads bring real conversations and orders, and to reach people who want a photo booth. We weighed it against your interests: only the business activities listed above are shared, never the message text, we never apply a label or stage that reveals health, beliefs or another special category of data, you chose a Meta channel to talk to us, and objecting takes one message and no reason.

You can object at any time, without giving a reason: write to us on WhatsApp at +40 754 677 117 or at contact@photoboothcraft.com. From then on we stop applying labels and stages to your conversation, we record the objection, and we close and archive the conversation in the Page inbox. Meta's automatic detection on the channel is outside our control; if you want no such use at all, write to us by email instead of WhatsApp, Messenger or Instagram. What was already shared stays with Meta, under its policy.

Meta and WhatsApp may transfer the data to the United States, under the EU-US Data Privacy Framework and standard contractual clauses.

We keep conversations and their labels for 3 years from the last message, then delete them. What goes into an invoice is kept as long as the law requires for financial documents, and what was already shared with Meta, under Meta's policy.

The shop assistant

On the site you can use an automated assistant, based on artificial intelligence, that answers questions about the products and the shop's rules (delivery, returns, warranty, payment). The data controller is TECH EVENT SRL, as for the rest of the site.

What data we process: the text you type into the assistant; technical data about each request (a request identifier, the time, the outcome, the model used and the number of text units processed), without the text of the message; a pseudonymous key derived from your IP address, which we use to limit abuse and costs; and the assistant's session cookie, described below. We do not keep the IP address: we keep only the key, which changes every day and cannot be turned back into the address.

Messages that contain passwords, access keys, card numbers, or order links and order access codes are refused before they leave for the AI provider. This check stops the known shapes, but it cannot recognise every piece of personal data; please do not type into the assistant details about yourself that it does not need in order to answer.

Checking an order happens in a separate form, with the order number and the access code or the confirmation link. The check and the answers about the order are given directly by the shop's server: order data is never sent to the AI provider. Access to an order from the assistant lasts at most 30 minutes and you can close it at any time from the panel.

Legal basis: answering your questions about products, orders and the shop is based on steps taken at your request before entering into a contract and on the performance of the contract, article 6(1)(b) GDPR. Limiting abuse and costs, with the pseudonymous key and the technical data, is based on our legitimate interest in keeping the assistant safe and within a budget, article 6(1)(f).

Who receives the text: the text of your message, together with the shop's instructions and the product information, is sent to the AI provider the shop is using at that moment, one at a time. The providers we may use are Anthropic (through Anthropic Ireland, Limited) and OpenAI (through OpenAI Ireland Ltd.), which process the data on our behalf, as processors, under their data processing agreements. The AI provider does not receive your IP address, the assistant cookie or any order data.

Where the data goes: the AI providers may process the data outside the European Economic Area as well. Transfers rely on the standard contractual clauses approved by the European Commission, included in the data processing agreements of both providers, or, for OpenAI, on a Commission adequacy decision where one exists.

How long we keep it: we do not keep the text of conversations and we have no archive of them. You see the conversation only in the open page; if you reload the page, a new one starts. A conversation expires 30 minutes after it starts and is deleted from our database within 24 hours after that; it holds only technical choices, such as the products shown, not the messages. The technical request data and the counters tied to the pseudonymous key are deleted after 48 hours. Daily and monthly cost totals, which are not tied to any person or conversation, are deleted after 90 days.

How long the AI providers keep it: Anthropic normally deletes data sent through its API, and the answers, within 30 days; if a message is flagged for a breach of Anthropic's usage policy, it may keep it for up to 2 years, and the classification scores for up to 7 years, and it may keep data longer where the law requires it. OpenAI keeps abuse monitoring logs for up to 30 days, longer where the law requires it or where it is reasonably necessary to protect its services or others. We have no zero retention agreement with either of them. Because we may switch from one provider to the other, the one used before may still hold data within these periods.

Model training: under their terms for API customers, Anthropic and OpenAI do not use the data the shop sends to train their models.

The assistant takes no automated decisions with legal effects on you and does no profiling. It does not conclude or change orders, set prices or approve returns: for those, the shop answers you.

The text of the messages does not reach Google Analytics or Microsoft Clarity, and the assistant panel is masked in Clarity recordings.

The assistant cookie: __Secure-pbc-assistant, strictly necessary, set only when you start a conversation. It holds a random value that ties the conversation to your browser, is sent only to the assistant's addresses and expires after 30 minutes. It is not used for statistics or advertising.

Your rights are those in the section "Your rights", including the right to object to processing based on legitimate interest. Because we do not keep the text of conversations and do not tie it to your name, once a conversation is over we usually hold no data we could show you or erase. You can write to us at contact@photoboothcraft.com. You can also lodge a complaint with the Romanian data protection authority, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), www.dataprotection.ro.

Your rights

You can ask for access to your data, its correction, its erasure, the restriction of processing, or its portability. Write to us at contact@photoboothcraft.com and we answer within 30 days at the latest.

You can object at any time to processing based on our legitimate interest, by the two ways given in the conversations section.

Data held in fiscal documents cannot be erased on request: it is kept under a legal obligation.

If you believe we process your data wrongly, you can complain to the Romanian supervisory authority, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), https://www.dataprotection.ro.