Privacy Policy
Last updated: 16 March 2026
1. Introduction
This Privacy Policy explains how EasyPassportPhoto Ltd (“we”, “us”, or “our”) collects, uses, and protects your personal data when you use our passport photo service at easypassportphoto.com (the “Service”).
We are committed to protecting your privacy and handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Data Controller
EasyPassportPhoto Ltd is the data controller responsible for your personal data.
Contact details:
Email: privacy@easypassportphoto.com
Address: [Registered Address to be added]
3. Personal Data We Collect
We collect the following categories of personal data:
| Category | Data |
|---|---|
| Photographs (including face data) | Photos you upload or capture, including the original image and processed passport photo. We use face detection to verify a face is present and to crop the image correctly. We do not extract or store facial geometry, embeddings, or biometric templates separately from the photograph itself. |
| Contact Information | Email address (optional, provided when you request a dashboard link) |
| Transaction Data | Records of purchases, payment status, and package type (payment details are processed by Stripe and not stored by us) |
| Technical Data | Anonymous session identifier stored in your browser to link you to your photos |
Special Category Data: Photographs may constitute biometric data. We process this data solely for the purpose of creating your passport photo and rely on your explicit consent when you upload or capture a photo.
4. Legal Basis for Processing
We process your personal data on the following legal bases:
- Contract Performance (Article 6(1)(b)): Processing your photos and fulfilling your order is necessary to provide the Service you have requested.
- Explicit Consent (Article 9(2)(a)): For processing photographs which may constitute special category data, we rely on your explicit consent given when you upload or capture a photo.
- Legitimate Interests (Article 6(1)(f)): For fraud prevention and maintaining the security of our Service.
5. How We Use Your Data
We use your personal data to:
- Process your photographs to create compliant passport photos
- Provide access to your photos via your personal dashboard
- Send you dashboard access links via email (if you provide your email)
- Process payments through our payment provider
- Respond to your enquiries and provide customer support
- Comply with legal obligations
6. Data Sharing and Third Parties
We share your data with the following third parties:
- Stripe, Inc. – Payment processing. Stripe processes your payment card details directly; we do not have access to your full card number. See Stripe's Privacy Policy.
- Cloud Infrastructure Providers – For secure storage and hosting of the Service.
- Google LLC (Gemini API) – For AI-powered photo processing including background removal, lighting correction, and compliance checking. Google processes images on our behalf and does not retain them after processing. See Google's Data Processing Terms.
We do not sell, rent, or trade your personal data to any third parties for marketing purposes.
7. International Data Transfers
Some of our third-party service providers are located outside the United Kingdom. Where we transfer your data internationally, we ensure appropriate safeguards are in place, including:
- Transfers to countries with an adequacy decision from the UK Secretary of State
- Standard Contractual Clauses approved by the UK Information Commissioner
- Other legally recognised transfer mechanisms
8. Data Retention
We retain your personal data as follows:
| Data Type | Retention Period |
|---|---|
| Unpaid photos | Automatically deleted after 24 hours |
| Paid photos | Retained for 12 months from purchase to allow re-download, then deleted |
| Transaction records | 6 years (for legal and accounting purposes) |
| Email addresses | Until you request deletion or 12 months after last activity |
9. Automated Decision-Making
Our Service uses automated processing, including artificial intelligence, to analyse and transform your photos into passport-compliant images. This includes:
- Face detection to verify a face is present
- Automatic cropping and sizing to meet passport requirements
- Background replacement and lighting correction
- Compliance checking against official requirements
This automated processing is necessary for the performance of our contract with you. If our automated system cannot process your photo, you will be notified and given the opportunity to upload a different image.
10. Your Rights
Under UK data protection law, you have the following rights:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data in certain circumstances.
- Right to Restrict Processing: Request that we limit how we use your data.
- Right to Data Portability: Request a copy of your data in a machine-readable format.
- Right to Object: Object to processing based on legitimate interests.
- Right to Withdraw Consent: Where we rely on consent, you may withdraw it at any time.
To exercise any of these rights, please contact us at privacy@easypassportphoto.com.
You can delete your unpaid photos directly from your dashboard at any time.
11. Cookies and Local Storage
We use browser local storage to maintain your session and link you to your photos. This is essential for the Service to function and does not track you across other websites.
We may use essential cookies for security and functionality. We do not use advertising or third-party tracking cookies.
12. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of data in transit using HTTPS/TLS
- Secure cloud storage with access controls
- Regular security reviews and updates
13. Complaints
If you have concerns about how we handle your personal data, please contact us first and we will do our best to resolve the issue.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:
Information Commissioner's Office
Website: ico.org.uk
Telephone: 0303 123 1113
14. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.
15. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us: