Privacy and image authorization

Essential information

Who decides

The professional identified in the authorization decides the session and image or voice uses and is controller for that processing. José Irún Sánchez operates ImageConsent as processor for records hosted on the professional’s behalf and as independent controller for accounts, security, purchases, support and ImageConsent’s own compliance.

ImageConsent owner

José Irún Sánchez · Spanish tax ID 37292698S · C/ Gavà 21–23, 4th floor, door 2, 08014 Barcelona, Spain · info@imageconsent.eu.

Data protection officer

No data protection officer has been appointed. Privacy enquiries are handled at info@imageconsent.eu.

Purposes

Provide and protect the platform; manage accounts, access, support and purchases; create and retain on the professional’s behalf evidence of authorizations, signatures, delivery and withdrawal; handle rights, incidents and claims.

ImageConsent legal bases

Contract for the account and service (GDPR Art. 6(1)(b)); legal, tax or consumer duties where applicable (Art. 6(1)(c)); and legitimate interests in security, abuse prevention, continuity and legal claims (Art. 6(1)(f)). The professional must determine and document the bases for their own processing.

Automated decisions

No solely automated decisions with legal or similarly significant effects are made and no profiles are created. Information is not used for behavioural advertising.

1. Allocation of roles

The professional is controller when deciding whom to photograph or record, for what purpose, for how long, in which territory and to which recipients the material is disclosed. The professional must inform people, verify capacity and representation, limit use to what was authorized, handle withdrawals and rights, and decide when the file should be erased.

ImageConsent is processor for authorization data entered and retained by the professional on the platform. Documented instructions consist of the functions requested by the professional, selected settings and the data-processing agreement incorporated into the Terms. ImageConsent does not reuse this data for incompatible purposes of its own.

ImageConsent is independent controller for data required to create and secure accounts, record acceptance of terms, administer licences and purchases, provide support, keep security telemetry and meet its own duties. The parties do not normally act as joint controllers: each remains responsible for the decisions it actually makes.

2. Data, sources and required fields

Account and profile: email, display and professional names, sign-in provider identity, optional logo, language, acceptance of terms and workspace data. Authorization: individual’s name, document type and number if entered, contact details, representative details, session or project, purposes, scope, drawn signature, signing method, language, text version, timestamps, integrity fingerprint, delivery and withdrawal.

Access and security: session identifiers; codes retained only as a digest or HMAC where stated; attempt outcome, action, technical reference, date, limited user agent and an IP-derived fingerprint instead of the plain IP in application telemetry. Purchases: platform, product, transaction, environment, status and dates; ImageConsent does not receive full payment-card details.

Data comes from the professional, signer or representative, sign-in provider and, for purchases or delivery, Apple, Google or the email provider. Fields marked required are needed to provide the requested function; omission prevents account creation, evidence of authorization or delivery of a copy. Optional fields may be left blank.

For productions and groups, the professional creates either a single-use individual invitation or a reusable collective link and chooses how to share it. Each participant enters their own details on their device. Other participants cannot see those details; the organizing professional can view status, the minimum tracking reference and, once completed, the individual authorization. ImageConsent does not send WhatsApp messages and does not need to retain a phone number to distribute the invitation; phone remains optional within the record.

Templates and duplicates reuse professional configuration without copying signatures or participants. If the professional enables reminders, ImageConsent uses the already verified email address to send periodic transactional messages containing a new personal link; the professional can disable them or send them manually. In offline mode, a pending authorization may be stored temporarily on the professional’s device and synchronized when connectivity returns; until then, email delivery and server storage are not considered complete.

The reference photo is optional and may be provided by the professional, participant or representative. It is resized, its location metadata is removed and it is stored encrypted. If accepted before signing, it forms part of the record and its email and PDF copies. It does not perform facial recognition or verify identity. You can continue without a photo. An internal photo added after signing is visible only to the professional, does not change the authorization or its copies, and requires a lawful basis and information to the person. The retention periods and rights described in this notice apply; copies already delivered are not automatically recalled. Other photographs, videos and audio from the session remain under the control of the professional or selected recipients, outside this record.

3. Image, voice, withdrawal and minors

Authorization covers only the selected acts and purposes. It does not cover new purposes, degrading uses or unlawful interference with honour, privacy or image rights. Online distribution may have worldwide reach, and third-party copies may fall outside the professional’s effective control.

An individual may withdraw data-protection consent and revoke image authorization by contacting the professional or info@imageconsent.eu and quoting the reference. Withdrawal does not affect earlier lawful processing. Future uses controlled by the controller will stop and removal, limited evidential retention and, where relevant, consequences under Spanish Organic Law 1/1982 will be assessed; no promise is made to erase copies lawfully controlled by third parties.

Where a minor is involved, the representative must establish their authority, inform the minor in understandable terms, hear the minor according to age and maturity, and put the minor’s best interests first. When the flow records sufficient maturity, the minor personally signs their decision and the representative separately signs the assistance and declaration. The professional records the stated assessment and authority, but ImageConsent does not verify them or automatically determine capacity. Conflict, doubt or possible harm requires the use to pause until applicable requirements have been checked.

4. Signature and evidential value

The drawn signature, express acceptance, versioned content and audit trail form electronic evidence. In remote signing, the code sent by email evidences access to that address at that time; it does not by itself prove civil identity.

ImageConsent does not currently provide a qualified trust service, issue qualified certificates, perform documentary identity verification or claim that its signature is advanced or qualified. Under eIDAS Article 25, an electronic signature cannot be denied effect solely because it is electronic, but only a qualified signature receives automatic equivalence to a handwritten signature under that Regulation. Evidential weight depends on the complete record and circumstances.

5. Recipients, providers and transfers

Strictly necessary access may be given to technical providers and competent authorities. The brands below describe services used or planned in the technical configuration; they are not a claim that a certification, signed DPA or exclusively EU-based processing has been verified. The contracting entity, locations, subprocessors and transfer mechanism must be checked and recorded before they are relied on for production.

Where processing involves a transfer outside the EEA, the responsible party must identify and document a valid Chapter V GDPR mechanism—such as an adequacy decision or the applicable 2021 Standard Contractual Clauses—plus any required transfer assessment and supplementary measures. The existence of those safeguards is not assumed merely because a provider is named here.

6. Retention

Expiry prevents reuse of a code but does not necessarily erase all technical evidence at that instant. The category-based policy is:

• Account, profile, workspaces, purchases and sign-in methods: while the account is active; removed from active systems when account deletion is completed, except separate information that must be restricted due to a legal duty or claim.
• Authorizations, signatures and withdrawals: until the professional deletes the record or account. Withdrawal changes the status and evidence remains until that deletion; the professional must apply their own schedule and not keep files indefinitely for convenience.
• Remote-signing link: valid for 20 minutes. Verification or access code: valid for 10 minutes and one use. Email-account session: maximum validity of 90 days. Expired records may remain temporarily for audit and operational cleanup and never regain validity because they are retained.
• Application security telemetry: 180 days; when an account is deleted, user and resource references are detached. Rate-limit counters remain for their window and technical cleanup period.
• Support, rights and incidents: for the handling period and afterwards only as long as needed to evidence the response or address liability. The specific duration is recorded in the internal case file.
• Copies and providers: deletion removes the active independent copy when the service can verify this. Provider recovery snapshots and provider-level logs follow contractual cycles; exact periods must be recorded in the provider register and instant erasure is not presumed without evidence.
• Copies downloaded by the professional, session media and external publications are not controlled by ImageConsent and follow the schedule of the professional or third party holding them.

7. Individual rights

• Access to data and a copy; rectification of inaccurate data; erasure where applicable; restriction; objection to processing based on legitimate interests; and portability where its conditions are met.
• Withdrawal of consent at any time without affecting earlier lawfulness and a request to record revocation of image authorization.
• The right not to be subject to a solely automated decision with the effects described in GDPR Article 22; ImageConsent does not currently make such decisions.
• A complaint to the supervisory authority, without prejudice to other administrative or judicial remedies.

For session data or use of images, first contact the professional identified in the authorization. You may also write free of charge to info@imageconsent.eu, quoting the reference and right requested; ImageConsent will respond as controller or route/assist the professional where it acts as processor. Proportionate additional information may be requested to avoid disclosing data to another person.

The general response period is one month from receipt and may be extended by two further months for complex requests, with notice during the first month. You may complain to the Spanish Data Protection Agency.

8. Security and telemetry

Controls proportionate to risk include HTTPS, authenticated access, account/workspace separation, application-level encryption for identity fields and signatures, integrity fingerprints, secrets outside source code, temporary links, one-time codes, attempt limits, independent encrypted copies and logging of relevant operations.

First-party telemetry records action, outcome, date, technical reference, limited user agent and an IP-derived fingerprint; it is used to detect abuse, investigate incidents and evidence operations, not for advertising or cross-app tracking.

No measure removes all risk. These descriptions are not a certification, a guarantee of invulnerability or a claim of independent audit. Measures and effectiveness are reviewed following material changes and incidents.

9. Incidents and personal-data breaches

Immediately report unrecognized access, links or messages to info@imageconsent.eu and do not reuse the affected link or code.

Where ImageConsent acts as processor, it will notify the professional controller without undue delay and provide available information for the risk assessment. Where it acts as controller, it will document every breach and, where required, notify the Spanish Data Protection Agency without undue delay and no later than 72 hours after becoming aware.

Where a high risk is likely, affected people will receive a clear communication without undue delay unless a legal exception applies. It will explain the nature, likely consequences, measures and contact; no promises will be made before the facts are known.

Official sources

• Regulation (EU) 2016/679 (GDPR)
• Spanish Organic Law 3/2018 (LOPDGDD)
• Spanish Organic Law 1/1982 on honour, privacy and image rights
• Spanish Organic Law 1/1996 on legal protection of minors
• Consolidated eIDAS Regulation
• AEPD: personal-data breach notification