Data processing agreement

The Partner is the controller and Festapix is the processor of the personal data in the albums the Partner creates for its clients. Festapix processes them only to provide the service described in the partner agreement.

This annex forms part of the partner agreement and lasts as long as the Partner has albums online.

Data subjects: the couple or hosts, their guests, and the people who appear in the photos, videos or voice messages.

Data: photos, videos and voice messages, the first name a guest may give, the title, date and place of the event, the host's email address, technical data (such as the time of an upload and the type of device) needed to run and protect the service.

Special categories of data are not requested. If a photo or a recording happens to reveal such data, it is processed only as stored content, on the Partner's instructions.

Festapix stores the content, shows it to the people who have the link or the QR code, lets the host manage and download it, produces previews and keepsake films, sends the host the emails of the service, and deletes the content at the end of its term.

Festapix acts only on the Partner's documented instructions, which are this annex, the partner agreement and the settings the Partner and its clients choose in the service. If it believes an instruction breaks the law, it says so.

Everyone at Festapix who has access to the data is bound by confidentiality. Festapix applies appropriate technical and organisational measures, among them: encryption in transit; storage in a private bucket, where every read uses a short-lived signed address; access to the servers limited to a few people with strong authentication; separation of albums by random codes; regular backups; and the removal of the content when its term ends.

The Partner authorises these sub-processors: Hetzner (servers, European Union); Cloudflare (file storage in the EU jurisdiction and protection of the site); Resend (sending of the service emails).

Festapix chooses processors that give the guarantees required by law and binds them with the same obligations as this annex. It tells the Partner by email of any new sub-processor at least 15 days in advance; the Partner may object on reasonable grounds within that time, and if the matter cannot be resolved it may end the agreement with a refund of unused credits.

Stripe handles payments as an independent controller, under its own terms.

The content stays in the European Union. If a sub-processor needs to transfer other data outside the European Economic Area, it does so only under an adequacy decision or the standard contractual clauses of the European Commission.

The people concerned can exercise their rights (access, deletion, objection and the others) with the Partner. Festapix helps the Partner with the tools of the service: the host can hide or delete any photo and download everything; Festapix deletes an album or an item on the Partner's written request, and tells the Partner promptly if a person contacts it directly, without answering in the Partner's place.

Festapix informs the Partner without undue delay, and within 48 hours at the latest, after it becomes aware of a personal data breach concerning the Partner's albums, with what it knows about the facts, the data involved, the likely consequences and the measures taken, so that the Partner can fulfil its own duties.

Taking into account the nature of the processing, Festapix helps the Partner with security, with notifications of breaches, with impact assessments and with consultations of the authorities, to the extent that the Partner cannot do so without the information Festapix holds.

While an album is online the host can download all its content. When the term of an album ends, or when the Partner asks for it earlier, Festapix permanently deletes the content from its storage; database backups are overwritten within 30 days. Festapix keeps only what the law requires it to keep, such as invoices.

Festapix gives the Partner the information needed to show compliance with this annex. Where that is not enough, the Partner may carry out an audit, once a year, with 30 days' notice, during working hours, without disturbing the service, and at its own cost, subject to confidentiality; the audit may also be carried out by an independent auditor bound by confidentiality.

Questions about data protection: [email protected]. Festapix is a service of CR OU OÜ, Nõmme tee 64-3, 11311 Tallinn, Estonia.