Draft for counsel review. Placeholders marked in [brackets] must be confirmed before production launch.
Legal · DPDP Act 2023

Privacy Policy

Last updated: 25 May 2026 · Effective immediately for all users.
This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and what rights you have under the Digital Personal Data Protection Act, 2023 (the "DPDP Act").

1. Who we are

fotoz.in is operated by [LEGAL ENTITY NAME, CIN], with registered office at [REGISTERED OFFICE ADDRESS, Bengaluru, Karnataka, India]. We are the Data Fiduciary for the personal data of photographers who hold a fotoz.in account.

2. Data we collect

Whose dataWhat we collectWhy
Photographer (account holder)Name, email, phone, studio name, password hash, billing details, watermark text/logo, device fingerprints of helper installationsTo run your account, process payments, and operate the helper desktop app
Client (gallery visitor)Name, WhatsApp phone, IP address, OTP attempts, selections made, comments per photo, timestampsTo verify the client and record the selection for the photographer's records
Photo dataCompressed previews + thumbnails (NOT originals/RAW). EXIF data extracted to support sorting.To display the gallery and provide the selection workflow
OperationalServer logs, error reports (via Sentry), feature-usage analyticsTo debug, secure the platform, and improve the product

3. Legal basis

Under the DPDP Act, we rely on the following grounds:

  • Consent — for account creation, marketing emails, and a client's entry into a gallery
  • Performance of contract — for billing and core product features
  • Legitimate use — for security logs and fraud prevention

4. Who we share it with

We share data only with the processors required to run the Service:

  • Cloudflare R2 — photo and PDF storage
  • Neon — managed PostgreSQL hosting
  • Razorpay — payment processing (subject to their Privacy Policy)
  • MSG91 — WhatsApp message delivery
  • Resend — transactional email delivery
  • Google — only if you sign in with Google OAuth
  • Sentry — error tracking (PII is scrubbed before transmission)

We do not sell personal data. We do not share it for advertising. We will disclose data when compelled by a valid Indian legal process.

5. Where we store data

Account data and database records are stored in [NEON PROJECT REGION — flag to confirm]. Photo previews are stored on Cloudflare R2 in the Asia-Pacific region. Backups are encrypted at rest and retained for 30 days.

6. Retention

DataHow long we keep it
Active account dataFor the life of your account
Cancelled account data60 days after cancellation, then deleted
Client gallery data90 days after gallery expiry
Server logs30 days
Billing records8 years (required by Indian tax law)

7. Your rights under the DPDP Act

  • Right to access a copy of the personal data we hold about you
  • Right to correction of inaccurate data
  • Right to erasure ("Delete my account") — request from Settings → Account → Delete
  • Right to grievance redressal — see Section 10 below
  • Right to nominate someone to exercise your rights in case of death or incapacity

We will respond to any rights request within 30 days. Identity verification may be required.

8. Security

We use industry-standard measures including TLS in transit, encryption at rest, role-based database access, OTP-gated gallery links, opaque tokens, and rate-limited public endpoints. If a personal data breach occurs that is likely to cause harm, we will notify the Data Protection Board of India and affected users within 72 hours.

9. Cookies

We use only essential cookies for authentication, anti-CSRF, and basic analytics. We do not use third-party advertising cookies. A cookie banner is shown on first visit to fotoz.in for explicit consent.

10. Grievance Officer

Under Rule 5(9) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the DPDP Act, 2023:

Grievance Officer
[OFFICER NAME — flag to fill]
Response within 15 days
Data Protection Board
Govt. of India
If unsatisfied with our response, escalate to the DPB.

11. Children

The Service is not intended for users under 18. We do not knowingly collect data from minors. If you become aware that a minor has used the Service, contact us at grievance@fotoz.in and we will delete the data.

12. Changes

Material changes to this policy will be notified by email at least 14 days before they take effect.