Privacy Policy
Last updated: placeholder — not yet published
Draft notice: this page reflects a detailed draft prepared for the business, but it has not yet been reviewed by a lawyer. A few items are still pending before this is final: the contact email below needs to actually exist (Google Workspace setup), and whether full or simplified invoices apply is pending confirmation from the accountant. This is also not the same document as the image/model release clients sign for portfolio and marketing use — that's a separate agreement.
Who is responsible for your data
Bálint Markoth, self-employed (autónomo), operating as Holiday Photo Tenerife. NIE: Y6884593-V. Location: Los Gigantes, 38683, Tenerife, Spain. Contact: info@photo-tenerife.com.
foto-tenerife.com is the same business, and redirects to photo-tenerife.com.
What data we collect, and why
- Name, phone number, email — to arrange and confirm your photo session via WhatsApp, Calendly, or email. Legal basis: performance of a contract / steps taken at your request before booking.
- Session date, time, and chosen package — to plan and deliver your session. Legal basis: performance of a contract.
- Payment details (bank transfer reference, or Revolut transaction data) — to process payment. Legal basis: performance of a contract.
- Address and ID number (DNI/NIE/CIF/passport number) — only collected if a full (non-simplified) invoice is required for your booking, per Spanish invoicing law. Legal basis: legal obligation.
- Photos taken during your session — to edit and deliver your final gallery. Legal basis: performance of a contract.
- Website usage data (via Google Analytics) — to understand how visitors use the site and improve it. Legal basis: your consent via the cookie banner — analytics only run after you actively accept.
We do not send marketing emails or newsletters.
Who else sees your data
We use the following third-party services to run the business. Each acts as our data processor and only uses your data to provide their service to us:
- WhatsApp Business (Meta) — booking communication
- Calendly — scheduling
- Google Meet / Google Workspace — video calls, business email
- Google Drive — delivery and storage of your photos
- Google Analytics — website statistics
- Revolut — international payments
International data transfers
Some of the services above (Google, Meta) are based outside the EU/EEA. Where this happens, the provider relies on the EU-US Data Privacy Framework and/or Standard Contractual Clauses to ensure your data is protected to EU standards. Revolut is regulated within the EU/EEA.
How long we keep your data
Contact and booking details, invoices: kept for 6 years from the date of the invoice, as required under Spanish commercial and tax law (Código de Comercio / Ley General Tributaria) — we're not able to delete this sooner even on request.
Delivered photos on Google Drive: kept as part of our professional archive (backup, reprints, potential future orders) for as long as that serves a legitimate business purpose. If you ask us to delete your gallery, we'll do so within 30 days, except for anything we're legally required to keep (see invoices, above). This is separate from portfolio/marketing use, which requires your separate consent via the image release.
Website analytics data: as set by Google Analytics' default retention (currently 14 months), or shorter if configured.
Photos of children
For family sessions, a parent or guardian gives consent on behalf of any child under 14. By booking a family session, the booking parent confirms they have authority to do so for all minors included in the session.
Your rights
You have the right to access, correct, delete, restrict, or object to the processing of your data, and to data portability. To exercise any of these, contact info@photo-tenerife.com. You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
Cookies
This site uses Google Analytics, which sets cookies to measure site usage — only after you accept them via the cookie banner. See our Cookie Policy for details.
Security
We take reasonable technical and organizational measures to protect your data, appropriate to a small business of this size — including keeping client galleries on Drive restricted to private, named-access sharing rather than "anyone with the link".
Changes to this policy
We may update this policy as the business evolves (e.g. when new tools like paid advertising or a professional photo-delivery platform are introduced). The date of the latest version is shown at the top of this page.
Contact
Questions about this policy? Reach out via WhatsApp or email info@photo-tenerife.com.