Privacy policy

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

StartklarWeb, owner Hasan Mohsen

Brucknerstraße 12, 46325 Borken (Münsterland), Germany

E-mail: info@bildplattform.de

We have not appointed a data protection officer because there is no legal obligation to do so.

Bildplattform is a hosted access point to a tool for AI-assisted image editing, in particular for real estate photos. We process personal data only to the extent necessary to provide the website, your account and to answer your enquiries.

With regard to the photos you upload as a customer, we act as a processor on your behalf. You are the controller for that content. The basis for this is our data processing agreement (DPA) at /en/legal/data-processing. For your own account data (for example registration and billing) we are the controller; this privacy policy applies to that.

The application and its database are operated with Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The server location is in Nuremberg (Germany) and therefore within the European Union.

The provider processes technical access data on our behalf. A data processing agreement under Article 28 GDPR is in place with Hetzner.

The legal basis is our legitimate interest in providing the application securely and reliably under Article 6 (1) (f) GDPR.

When the application is accessed, information transmitted by your browser is recorded automatically and is technically necessary for delivery and security. This includes in particular:

We use technically necessary cookies or comparable storage mechanisms required to operate the service, in particular a session cookie that keeps you signed in and the storage of your language setting. These are based on Section 25 (2) TDDDG in conjunction with Article 6 (1) (f) GDPR and do not require consent.

How long the session cookie lasts is up to you when you sign in, with the "Stay signed in" tick box. When it is ticked, which is the default, the cookie stays stored after you close the browser, and you remain signed in until you sign out or the sign-in expires. Without the tick we set the session cookie without an expiry date, so your browser usually deletes it when you quit it, and on our server such a sign-in ends after a few hours at the latest, whatever the browser does. If you choose "Trust this device" when confirming a new device, your browser additionally stores a cookie with a device identifier so that you can sign in there without a code next time. Of that identifier we store only a cryptographic hash.

We only use non-essential services, in particular reach measurement with Google Analytics (see clause 11), if you have consented via our cookie banner. You can change or withdraw your choice at any time with effect for the future.

In addition we run our own reach measurement that requires no consent. For a page view and for individual interactions (for example a form opened, a button clicked) we store on our server only the type of event, the page path without parameters, one attribute from a fixed list and the hour of access, and we increment a counter from that. We store neither your IP address, not even as a hash, nor cookies, identifiers, device or browser attributes; nothing is stored on or read from your device. This makes it impossible for us to relate the data to you. The legal basis is Article 6 (1) (f) GDPR, our legitimate interest in learning which parts of our service are not understood. We delete the counters after 90 days.

Separately from this count, the site keeps a note in your browser's session storage, for the length of the browser session, of where this visit came from. We set no cookie for this, and the details only reach us if you create an account. Section 6 has the details.

To use the application and to buy credit you create an account. In doing so we process the details you provide, usually name, e-mail address, company name and your access credentials, as well as information about your payment route and the users you set up.

Before you first use the application you confirm your e-mail address through a 6-digit code or a link we send to it. Of the code we store only a cryptographic hash. Without that confirmation the account stays locked.

We store passwords exclusively as a cryptographic hash (argon2) and never in plain text.

The purpose is to provide the account, manage your contract and users and communicate with you. The legal basis is Article 6 (1) (b) GDPR (performance of a contract).

Origin of a registration: the first time our website is opened in a browser session, the site stores in that browser's session storage (sessionStorage, not a cookie) where that visit came from. That is: whether it began with a click on an ad on Google (only yes or no; we do not store the identifier of the ad click), the campaign details from the page address (utm_source, utm_medium and utm_campaign), the domain name of the website you came from (without the path of the individual page), the page you entered on (without parameters), and the date. Further page views in the same session do not change these details. Your browser usually deletes them when you close the tab or the browser. If your browser restores a session and the details are older than 90 days, the next page view replaces them. If you create an account, the registration transmits these details, we store them with your company account, and your browser deletes them. Named staff of ours see them in the operator area next to the company account. If you create no account, we do not receive them. We record no IP address and no browser or device attributes for this, and we do not pass these details on to Google or any other third party. The purpose is to learn which routes bring new customers to us, so that we spend on advertising where it works. The legal basis is our legitimate interest under Article 6 (1) (f) GDPR. We delete the details together with the company account; if you object to the processing (section 14), we delete them earlier.

To edit them, you upload photos into the application. These photos can contain personal data, for example depicted persons or details contained in the metadata.

With regard to the uploaded photos, you as the customer are the controller under data protection law and we are the processor. We process this content solely on your instructions and for the purpose of enabling you to edit it. Details, in particular on the technical and organisational measures and on deletion, are set out in our data processing agreement (DPA) at /en/legal/data-processing.

For troubleshooting and support, named staff of ours may view your projects, images and results inside the application. We start no editing, change nothing and delete nothing in doing so, and every one of these accesses is logged.

You are responsible for ensuring that you are entitled to process the persons depicted in the photos and for observing any labelling obligations for AI-edited images.

At /en/free-trial you can have a few photos edited without an account. For that processing we are the controller and not a processor: you give us no instructions, and the editing runs on our own AI access (section 12).

The uploaded photo and the result are stored on our server in Germany and deleted automatically after 24 hours, unless you move them into an account (see below). We keep the photo only in a reduced version of at most 2000 pixels on its long edge; the uploaded original file is deleted as soon as the edit has finished. The result exists in two versions: one with the demo mark for display, and one without it solely for moving into an account. The version without the demo mark is never delivered through the test and is deleted with the run. To keep the free amount per visitor limited we also store a count: your IP address as a cryptographic hash and a signed identifier in a cookie, neither of them tied to an account. The legal basis is our legitimate interest in an abuse-proof trial under Article 6 (1) (f) GDPR.

The settings you choose for a photo and the texts you enter as your wish and as what must not be changed are stored together with the run and deleted with it after 24 hours. Within that time we can view the uploaded photo, the result, the settings and those texts in order to check quality and to look into a failed edit. Every look at one of those images is logged.

If you answer whether the image works for you, we store your answer, the reasons you ticked and your optional text with the run and delete them with it. Permanently we only count how often "Yes, it works" and "Not quite" were chosen, with no link to you.

The test requires an e-mail address; without one no edit can be started. You see the result in your browser in any case. We use the address for four purposes and for nothing else. First, it keeps the free images fairly distributed and protects the offer from abuse. Second, if we also send you the result by e-mail, we use it for messages about this one run: to deliver the finished image, and to tell you if the edit failed. The page tells you before the start whether such a message will be sent. Third, we compare the hash of the address when you create an account with the same address after the test and ask for your results to be moved into it. Fourth, named staff of ours can see the address in our operator area together with the run, for as long as the run is stored, in order to detect abuse, check the quality of the results and look into a failed edit. We do not use the address for advertising, including newsletters; no account is created unless you create one, and we do not write to you again later because of the test. The address goes further only when we send you a message, and then only to the dispatch provider named in section 10, which delivers the message with the attached image.

In the counts for the fair distribution the address is not stored in plain text, only as a cryptographic hash from which it cannot be recovered. With it we limit how many free edits are possible with one address and how many different addresses can be used from one internet connection and from one browser. Those counts are deleted after 30 days. The same hash is also stored on the row of the run and deleted with it. The address itself is stored encrypted on the row of the run as well and is only deleted with that row, that is after 24 hours or, if we keep the results for a new account (see below), when that retention ends. It is decrypted only to send you a message about this run and for the view in the operator area described in the previous paragraph. We do not write the address to log files. The backups of our server, which we make mainly before every software update, contain the run rows stored at that moment, including the encrypted address; we keep only the most recent backups and delete the oldest as soon as a new one is added. We also keep a suppression list: if the dispatch provider reports a complaint or a permanently undeliverable address, or if somebody asks us to, that address can no longer start a test and no further result goes to it. The suppression list holds nothing but the hash and the reason, and it is not deleted after a period, because a list that forgets would allow exactly what it exists to prevent.

The legal basis for requiring the address, for the counts, for the suppression list and for keeping the address encrypted with the run, including our view of it, is our legitimate interest under Article 6 (1) (f) GDPR in distributing the free images fairly, in protecting the offer from abuse, in checking the quality of our results, in nobody being able to have strangers written to through this form, and in nobody receiving a message they have refused. The legal basis for sending the result by e-mail is Article 6 (1) (b) GDPR: by starting the run you request the edit, and delivering its result is part of that service.

Moving results into an account: if you choose "Move images into my account" and then create an account or sign in, we transfer the results your browser hands over for this into your account. These are the photo in the reduced version of at most 2000 pixels on its long edge, the edited result without the demo mark, the chosen settings including the wish text, and your rating. They are matched only through the hash of the address you create or created the account with, or through the identifier in this browser's cookie. Nothing is transferred without your request. If you create a new account with the same address as in the test, we keep the selected results until you have confirmed your address, at most 48 hours after registering. With a different address they are still deleted after 24 hours. They only reach the account after the confirmation; without it we delete them when that period ends. After the transfer we delete the files of the test. The legal basis is Article 6 (1) (b) GDPR: you request the transfer. From the transfer on, the images are content of your account; section 7 and the data processing agreement apply to them.

Please do not upload photos in this test on which people are recognisable.

With credit and for the trial images the editing runs on our own access to the AI provider (section 12); you store no access credentials for it.

If your contract provides for your own API key for an AI provider and you have stored it in the application, we store that key in encrypted form so that the application can trigger the AI editing in your name and at your expense. The key is used solely for this purpose and is not passed on to third parties. The legal basis is Article 6 (1) (b) GDPR (performance of a contract).

Credit is bought inside your account through the payment service provider Stripe. Which payment methods are available is shown in the checkout; card payment is always among them.

For payment via Stripe, the payment data is processed directly by Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. Stripe's privacy information applies in addition. Where data is transferred to the USA, we base this on the EU standard contractual clauses or a valid adequacy instrument.

The legal basis is Article 6 (1) (b) GDPR (performance of a contract); for the statutory retention of invoice records additionally Article 6 (1) (c) GDPR.

For our e-mail dispatch we use the Resend service provided by Resend, Inc., USA. This covers system and account e-mails (for example confirmations, password resets and invitations) and, if we send you the result of the free test by e-mail, its delivery (section 7a). Resend processes the data required for sending as a processor on our behalf, in particular your e-mail address and the content of the message; for the result from the free test that includes the edited photo as a file attachment.

The service reports back to us whether a message could be delivered and whether a recipient complained. From those reports we maintain the suppression list of the free test (section 7a).

Where data is transferred to the USA, we base this on the EU standard contractual clauses or a valid adequacy instrument. The legal basis is Article 6 (1) (b) GDPR (performance of a contract) and our legitimate interest in reliable e-mail delivery under Article 6 (1) (f) GDPR.

For reach measurement we use Google Analytics, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies and similar technologies to analyse the use of the website.

With the same consent we use the conversion measurement of Google Ads, also a service of Google Ireland Limited. It tells us whether an account was created after a click on one of our ads on Google. For this Google sets cookies that contain, among other things, the identifier of the ad click, and we report the completion of a registration to Google without transmitting your name or your e-mail address.

This is used exclusively on the basis of your consent under Article 6 (1) (a) GDPR, which you give via our cookie banner. You can withdraw your consent at any time with effect for the future; the lawfulness of the processing carried out until the withdrawal remains unaffected.

When using Google Analytics and Google Ads, data may be transferred to Google LLC in the USA. Access to this data by US authorities cannot be entirely ruled out. We base the transfer on the EU standard contractual clauses or a valid adequacy instrument.

The actual AI image editing is computed by an external AI provider.

With credit and for the free test images the editing runs on our own access at OpenAI, L.L.C., USA. We then instruct that provider as a processor on your behalf; the image and the editing instructions are transmitted there and come back edited. For the transfer to the USA we rely on the EU standard contractual clauses or a valid adequacy instrument.

If your contract provides for your own API key (section 8), the editing runs instead on the provider of that key, which you pay yourself. That provider's privacy and contractual terms apply to this processing. The provider of that key, or you yourself as its contractual partner, is then responsible.

We only pass on personal data to the extent necessary. Recipients are in particular:

Under the GDPR you have in particular the following rights in relation to us:

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen), Kavalleriestraße 2 to 4, 40213 Düsseldorf.

We process and store personal data only for as long as necessary for the respective purposes or as required by statutory retention periods. Invoice and accounting records are retained for the statutory periods. After that the data is deleted. The rules of the DPA apply to the deletion of the photos you upload.

There is no decision based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.

We update this privacy policy whenever changes to our processing or to the legal situation make it necessary. The version published on this page applies in each case.