Art Persona · Privacy Policy · v1.0 · Effective 30 July 2026
| Field | Value |
| Operator | GromeFeet OÜ |
| Company number | 17348635 |
| Registered office | Pärnu mnt 12, Kesklinna linnaosa, 10148 Tallinn, Harju maakond |
| Trading name / brand | Art Persona |
| Website | https://art-persona.com |
| Contact email | info@art-persona.com |
| Support / complaints | info@art-persona.com (Monday-Friday, 09:00-17:00 Estonia time, excluding public holidays) |
| Governing law | Estonia, subject to mandatory consumer protections |
| Document version | v1.0 |
| Effective date | 30 July 2026 |
| Who this policy applies to: This policy applies to visitors, customers and identifiable people shown in submitted images. Art Persona processes facial images to create the requested avatar, not to identify a person biometrically across services, and does not intentionally store full payment-card details. |
1. Introduction and scope
GromeFeet OÜ is committed to fair, transparent and proportionate processing. This policy applies to visitors, customers, support contacts and people depicted in submitted images. It covers the website, checkout, production of custom avatars, download delivery, complaints and related fraud-prevention activity.
2. Data controller and contact
GromeFeet OÜ is the controller for decisions about customer, website and order data. Privacy questions and data-subject requests may be sent to info@art-persona.com or the registered office. No separate data protection officer has been appointed because the current processing model does not require one; requests are handled under management responsibility.
3. Age position
The Service is intended for adults aged 18 or over. GromeFeet OÜ does not knowingly contract directly with children or invite children to upload images. A parent or legal guardian must place and control an order involving a minor, confirm authority over the image and ensure that the requested Output is appropriate and lawful.
4. Categories of personal data
Data may include identification and contact details, account credentials, order selections, payment references, Customer Materials, generated Outputs, production metadata, device and log data, consent records, support correspondence, fraud indicators and legal-claim information. Full payment-card credentials are handled by the payment provider and are not intentionally stored by GromeFeet OÜ.
| Category | Examples | Source | Purpose |
| Account and contact | Name, email, credentials, country | Customer | Account administration, delivery and communications |
| Customer Materials and Output | Photos, prompts, selected style, generated avatar files | Customer and production workflow | Create, review, deliver and support the custom avatar |
| Transaction and payment | Amount, currency, provider reference, card brand, partial digits, refund status | Customer and payment provider | Authorisation, reconciliation, refunds and disputes |
| Technical and usage | IP address, device, browser, logs, cookie choices, access events | Device and Service | Security, diagnostics, consent and performance |
| Support and compliance | Messages, complaints, consent evidence, fraud or rights indicators | Customer, depicted person, providers or public sources | Support, safeguarding, legal compliance and claims |
5. Sources of personal data
Most data comes directly from the customer through forms, uploads, checkout and communications. Additional data may come from a payment provider, fraud-prevention service, hosting logs, cookie choices, an authorised representative, a person depicted in an image, or public sources used only to assess a rights, safety or impersonation concern.
Individuals retain the rights and complaint routes provided by applicable data-protection law.
6. How we use personal data
Data is used to create and deliver avatars, administer accounts, take payment, communicate about orders, prevent misuse, secure the Service, honour consent choices, improve reliability, comply with accounting and legal duties, establish or defend claims and respond to rights requests. GromeFeet OÜ does not use uploaded face images to identify people across services or build biometric identity profiles.
7. Lawful bases for processing
Contract is the principal basis for order fulfilment, customer support and delivery. Legal obligation supports tax, accounting and regulatory records. Legitimate interests support proportionate security, fraud prevention, service diagnostics and defence of claims. Consent supports non-essential cookies, optional marketing and any processing that legally requires explicit permission, and may be withdrawn for future processing.
| Processing activity | Lawful basis | Notes |
| Create and deliver an ordered avatar | Contract | Necessary to perform the paid Order and requested revisions |
| Payment, tax and accounting records | Contract and legal obligation | Includes transaction references but not full card credentials |
| Security, fraud and abuse prevention | Legitimate interests and legal obligation where applicable | Balanced against customer rights; high-impact restrictions can receive human review |
| Non-essential analytics and marketing cookies | Consent | Not activated before valid consent where European rules require it |
| Optional promotional email | Consent or another lawful basis permitted by applicable law | Unsubscribe is available in each marketing message |
| Legal claims and authority requests | Legal obligation and legitimate interests | Limited to necessary, proportionate information |
8. Payments and checkout
The payment provider receives card and authentication information directly through its secure interface. GromeFeet OÜ normally receives the payer name, billing result, tokenised reference, card brand, partial card digits, amount, currency, risk signals and refund status. These records support fulfilment, reconciliation, fraud prevention, customer service and payment disputes.
9. Cookies and similar technologies
Cookies and browser storage are used for security, session continuity, language or preference settings, consent management, analytics and marketing where enabled. Details of categories, providers and retention are contained in the Cookie Policy. Non-essential technology is controlled through the consent interface where required by applicable law.
10. Sharing of personal data
Data may be shared with payment processors, hosting and cloud-storage providers, email and support services, image-processing or artificial-intelligence infrastructure, analytics and consent tools, professional advisers, insurers, auditors, authorities and prospective corporate transaction counterparties. Each recipient receives only the data reasonably needed for its function and is subject to contractual or legal safeguards.
Consent can be withdrawn for future processing without affecting prior lawful processing.
11. International transfers
Some service providers may process data outside Estonia or the European Economic Area. Where the destination does not benefit from an adequacy decision, GromeFeet OÜ uses an approved transfer mechanism such as standard contractual clauses and applies supplementary technical or organisational measures appropriate to the risk. Transfer information may be requested through the privacy contact.
12. Data retention
Customer Materials and working production files are retained only for the production, revision and support period, normally no longer than 30 days after final delivery unless a dispute or explicit storage feature requires longer. Delivered Outputs and account records may be kept while the account remains active. Transaction and accounting data is generally retained for seven years; security logs are normally retained for up to twelve months.
| Data category | Retention period | Trigger / criterion |
| Raw Customer Materials and working files | Normally up to 30 days after final delivery | Longer only for requested revisions, dispute, security or legal necessity |
| Delivered Outputs and account library | While the account is active, plus a short closure retrieval period | May be removed after closure; customer should keep a lawful backup |
| Transaction, invoice and tax records | Generally 7 years | Measured from the end of the relevant financial year or longer if legally required |
| Support correspondence | Normally 3 years after resolution | Extended where needed for an active claim, fraud matter or safeguarding issue |
| Security and access logs | Normally up to 12 months | Shorter where practical; longer only for incident investigation or legal defence |
| Consent and preference records | For the life of the choice plus 3 years | Demonstrates consent, withdrawal and the notice version shown |
13. Data security
Controls include encrypted transport, access restrictions, role separation, strong authentication, logging, backups, vulnerability management, processor due diligence and deletion routines. No system is risk-free, but GromeFeet OÜ assesses incidents and, where legally required, notifies the Estonian Data Protection Inspectorate and affected individuals without undue delay.
14. Your privacy rights
Subject to legal conditions, individuals may request access, correction, deletion, restriction, portability and objection, and may withdraw consent. They may also object to direct marketing and lodge a complaint with the Estonian Data Protection Inspectorate or another competent supervisory authority. Rights can be limited where identity cannot be reasonably verified, another person’s rights would be harmed, or retention is legally required.
15. Marketing communications
Art Persona sends promotional email only with a valid legal basis and includes a functioning unsubscribe method. Transactional messages about an Order are not marketing and may continue where needed to perform the contract. GromeFeet OÜ does not sell personal data and does not use Customer Materials for third-party advertising without separate, specific permission.
Individuals retain the rights and complaint routes provided by applicable data-protection law.
16. Automated decision-making and profiling
Automated tools may flag payment risk, malware, prohibited content or unusual account activity, but Art Persona does not make solely automated decisions that produce legal or similarly significant effects without safeguards required by law. A customer may request human review of a material restriction where the decision was substantially automated.
17. Third-party services and links
Links, payment interfaces and embedded services may be operated by independent controllers with their own notices. GromeFeet OÜ is not responsible for their unrelated processing, but selects processors with regard to security and data-protection capability. Customers should review the notice presented by a payment or external platform before submitting data directly to it.
18. Changes to this policy
This policy may be updated to reflect legal developments, new processors, changed retention or service functions. The effective date identifies the current version. Material changes affecting existing customers will be communicated by a proportionate method, such as an account notice or email, before the new processing begins where law requires advance notice or renewed consent.
19. How to contact us or submit a request
Requests should be concise, identify the relevant order or account and describe the right being exercised. GromeFeet OÜ may ask for proportionate verification and normally responds within one month, subject to lawful extension for complex or multiple requests. Complaints may also be sent to the registered office or raised with the competent supervisory authority.
Schedule 1. Practical Retention Guide
Art Persona applies deletion by data lifecycle rather than by a single blanket date. Production files are short-lived, transaction records follow accounting duties, and evidence linked to a complaint or fraud review is isolated until the matter is resolved. When a lawful hold ends, the ordinary retention rule resumes.
• Before delivery: source images and working files remain available to the limited production team and approved processing infrastructure.
• After delivery: working files enter the 30-day deletion cycle unless a revision, complaint or lawful hold remains active.
• After account closure: hosted Output access ends after the communicated retrieval period; essential transaction and claim records remain segregated.
• After a valid erasure request: data not required for contract, accounting, security, rights of others or legal claims is deleted or irreversibly anonymised.
• After a provider change: data is exported or deleted under the provider contract and access credentials are revoked.
20. Governing law and mandatory rights
This Privacy Policy is governed by Estonian law and the General Data Protection Regulation, without limiting mandatory rights available under another applicable law. Individuals may complain to the Estonian Data Protection Inspectorate or another competent supervisory authority, and may seek a judicial remedy where provided by law.
Privacy controls in practice
Privacy compliance is implemented through minimisation at upload, purpose-limited processor access, deletion schedules, consent evidence, security review and a documented rights-request channel. Production personnel access only files assigned to the Order, and credentials are revoked when no longer required. Portfolio display, model improvement or promotion requires a separate assessment and, where applicable, specific consent rather than reliance on fulfilment.
• Ownership and approval: The named operational owner confirms that the customer-facing rule, production workflow and support script describe the same outcome before publication.
• Change control: A material product, provider or checkout change is assessed for legal impact and deployed only after the affected wording, controls and training have been updated.
• Customer evidence: Staff rely on the minimum relevant Order, communication, delivery and payment evidence and do not request unrelated identity, image or card information.
• Exception handling: An unusual case is escalated to a competent reviewer rather than resolved through an undocumented promise that conflicts with the published terms or mandatory law.
• Quality assurance: Sample cases are tested from customer request through final outcome, including the status visible to support and the records needed to explain the decision.
• Access control: Systems and provider dashboards use role-based access, strong authentication and prompt removal of credentials when responsibilities change.
Art Persona · Privacy Policy · v1.0 · Effective 30 July 2026. Published on the website; subject to update; the current published version governs.