Privacy policy
Last updated: 14 October 2026
Who is responsible
Foto2Pass is a trading name of Twilper.com, Merelstraat 64, 8916 AX Leeuwarden, Nederland (Chamber of Commerce 98440217, VAT NL005332508B94). Twilper.com is the controller for the personal data described here. Questions about privacy go to support@foto2pass.com.
What we process and why
- Your photo: you take or upload it in the browser. It is sent to our server and to our AI processors (see below) to check it against your country's rules, replace the background and crop it. We store the finished photo files to deliver them and for your download link.
- Face measurements: the positions and sizes of your face that the check computes (for example eye line and head height). They are stored with your order at Stripe so we can check and regenerate your files.
- Contact and order details: your email address, the product, the country, the language, the amount and the payment status. For printed photos also your name, address and, if you give it, your phone number.
- Payment details: handled by Stripe on Stripe's checkout page. We never see your full card number.
- Ad and referral data: if you arrive through an ad and accept cookies, the click IDs (gclid, fbclid) and the UTM campaign values are kept in your browser and sent with your order to Stripe. A promo or referral code from a link is kept and sent either way, so the discount works. Your cookie choice for ads is stored with your order too.
- Usage and device data: your IP address, browser and the pages you visit reach our host Vercel with every request. We use the country derived from your IP address to pick your language and currency.
- Messages: what you send us by email, and what you type into the chat widget.
- Reviews: if you leave a review, your rating, text and the name you give. On the site we show approved reviews with 4 or 5 stars; reviews saved before we added approval count as approved. The average rating we give search engines counts every approved review, also those with 1 to 3 stars.
We do not sell your data. We do not use your photos to train AI models.
Legal bases
- Contract (Article 6(1)(b) GDPR): processing your photo, your order, payment, printing and delivery, and the emails that belong to your order.
- Legal obligation (Article 6(1)(c)): keeping order and payment records for tax purposes.
- Consent (Article 6(1)(a)): Google Analytics and Google Ads cookies, Enhanced Conversions, the Meta Pixel, the Meta Conversions API and storing ad click IDs from a link (foto2pass-attr), all through the cookie banner; the newsletter; and the single reminder email for an unfinished checkout, which we only send if you ticked the box for it. You can withdraw consent at any time; that does not affect processing before the withdrawal.
- Legitimate interest (Article 6(1)(f)): security and error monitoring (Sentry), choosing your language and currency, answering chat messages, and asking customers for a review after their order. You can object at any time.
- The chat widget and Sentry load without asking for consent, on the basis of legitimate interest (above): the chat answers your questions and Sentry keeps the site working. You can object by emailing us, or block them in your browser.
Who receives your data
We use the following companies. They process data for us (as processors), or, for Google and Meta advertising measurement, also for their own purposes under their own privacy terms.
| Company | What they receive | Why |
|---|---|---|
| Vercel | Every request (IP address, browser), your photo files, review, newsletter and unsubscribe records | Hosting, file storage, scheduled jobs |
| Replicate | Your photo | Background removal (Bria model), the AI check of the photo rules (an OpenAI model run on Replicate) and optional photo enhancement |
| remove.bg | Your photo, only when Replicate fails | Fallback background removal |
| Anthropic | Your photo, only when the Replicate check fails | Fallback AI check of the photo rules |
| Stripe | Email address, name, billing address, payment details, product, country, language, face measurements, links to your photo files, your cookie choice for ads, ad click IDs and UTM values (only if you accepted cookies), promo and referral code | Payment, tax calculation, order records |
| Gelato or Prodigi | Name, address, email address, phone number if given, the print sheet with your photos | Printing and shipping, printed orders only |
| Resend | Email address, name, order details and links | Sending order, download, delivery, review request, reminder and newsletter emails |
| Google (Analytics, Ads) | Page views and order steps (for example wizard started, photo uploaded, checkout, purchase with order value), and at purchase, only if you accepted cookies, your email address, which Google's tag hashes before sending (Enhanced Conversions) | Measuring visits and ad results, under Google Consent Mode (see below) |
| Meta (Pixel) | Page views with Meta's browser cookie, from your browser | Measuring Meta ads; loads only after you accept cookies |
| Meta (Conversions API) | From our server: at checkout your email address and country (hashed), IP address, browser and order value; at purchase your email address, first and last name, city and country (hashed) and order value | Measuring Meta ads; sent only if you accepted cookies before the checkout |
| Sentry | Error reports and a sample of performance traces from your browser and our server: page, browser, error details; this can include your IP address | Finding and fixing errors |
| CheckShop | Order number and email address (sent from your browser on the success page and the order page), or email address and name (sent from our server after delivery of a printed order); the browser also loads CheckShop's badge there | Sending you a review invitation |
| TwilperChat (run by Twilper.com on api.twilper.com) | What you type into the chat, and the technical data any request carries | Answering your questions |
| Google (storage.googleapis.com) and jsDelivr | Your IP address and browser, when your browser downloads the face detection model and code | Face detection runs on your device; your photo is not sent there |
| Trustpilot | Your IP address and browser, when its widget loads | Showing reviews; only loads when the reviews section is shown and the widget is configured |
Several of these companies are based outside the European Economic Area, for example in the United States, so your data can be processed there.
How long we keep data
- Photo files in our storage (single photos, print sheets, family sheets): deleted automatically once they are older than 30 days. The cleanup runs once a week, so a file can stay up to 37 days.
- The copy of your processed photo in your browser stays until you clear the site data.
- Order records at Stripe, including the face measurements and the links to your photo files: our code does not delete them. Tax law requires us to keep order and payment records for 7 years. The links stop working once the files are deleted.
- Reviews, newsletter subscriptions and unsubscribe markers: kept until you ask us to delete them. We keep an unsubscribe marker so we do not email you again.
- Data at our processors, such as error reports, server logs, AI processing and analytics: kept for the periods those companies set.
Your rights
You have the right to access your data, to have it corrected or deleted, to restrict or object to processing, to receive your data in a portable form, and to withdraw consent. Email support@foto2pass.com. We reply within 2 business days and handle your request within one month, as the GDPR requires.
You can also complain to a data protection authority. In the Netherlands that is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl); you can also go to the authority in the EU country where you live.
Contact
Privacy questions: support@foto2pass.com. Post: Twilper.com, Merelstraat 64, 8916 AX Leeuwarden, Nederland.