Privacy Policy for Iris Mobile photographers and partners

Version of 15 October 2026

This policy explains how IRIS MOBILE LAB, S.L. processes the personal data of professionals operating in the Iris Mobile network who use its software: the Iris Mobile mobile app, the Iris Mobile Desktop desktop application and the web platform. Together, the "Software". It supplements the Software Terms of Use and does not apply to the clients you photograph: a separate privacy notice applies to them, and a link to it is provided on the photo delivery page.

1. Who is responsible for your data

The controller responsible for processing: IRIS MOBILE LAB, S.L., NIF B05661319, registered office: Calle Otumba, 5, puerta B, 41001 Seville, Spain (the "Company", "we").

For any matters relating to personal data, write to privacy@irismobile.eu. The Company has not appointed a data protection officer.

2. What data we process

2.1. Account and profile: first name and surname, email address, telephone number, language, profile photo, notification settings, login data (password in hashed form, two-factor authentication secret, recovery codes), your organisation and roles.

2.2. Photographer's profile form (self-registration): first name and surname in Latin script, date of birth, type, number, country and expiry date of the identity document, residential address, face photo for the profile form, Telegram and Instagram contacts (optional), emergency contact person (name and telephone number). We use the scan of the document only to verify the profile form and delete it once the form is approved or, for a form that was not submitted, was returned for correction or was left unfinished, after 30 days without activity; only the data from the profile form and a mark that verification has been passed remain in the system. We check automatically, on our own servers, that the document data match the profile form (by reading the MRZ zone) and that the photo contains a face. We do not recognise or compare faces. If the check fails, the profile form is reviewed by a person; the profile form is never rejected automatically.

2.3. Signed documents: the text, version and checksum of the document you signed (confidentiality agreement, Software Terms of Use), the name entered, date, time, IP address, device details, the "shown → read → signed" log, the handwritten signature as an image (if you provided one) and the PDF copy we send to you by email.

2.4. Equipment rental and activity at the points: the cities and points where you operate; bookings of the equipment and of the slot at the point, which you make yourself in the app (the Company does not set any schedule); session reports as the record of the rented equipment and consumables (time, takings, counters of processings, arts and prints); results of the courses required to use the Software; sign-in log (time, method, IP address, device).

2.5. Support chat: your messages and photos sent to the Company's support service, and the support service's replies. The Company's knowledge base is extended only with anonymised questions containing no personal data.

2.6. Billing: consumables for each session at the prices in force on the day of the session, monthly receipts for consumables, their status and payment method, orders in the in-app shop. For payment via Stripe we store the identifier of your customer profile in Stripe, as well as the payment identifier and status. We do not see or store your card details.

2.7. Sales summaries: if you have connected your own payment account (Stripe, SumUp) in the app, the app sends us only daily sales summaries for your statistics. The access key to your payment account is stored only on your phone, and we do not receive it.

2.8. Technical data: the device push token for notifications, device language and type, Software version, time of the last contact from the point's computer.

2.9. Mandatory and optional data. Account data, the profile form (including the face photo) and the identity document are required to conclude the contract: without them it is impossible to conclude the contract and grant you access to the Software. Telegram and Instagram contacts, the handwritten signature and the profile photo are optional: not providing them has no consequences. If you provide the details of an emergency contact person, please inform that person; we use these details only to notify them in the event of an emergency (Article 6(1)(f) GDPR).

2.10. In-app chat. In the Iris Mobile app you can communicate with other users in your organisation through one-to-one and group chats: text, photos and, at a later stage, voice messages. In addition, all chat users receive the Company’s announcement channel “News Iris Mobile”. Use of the chat is voluntary.

*Encryption.* One-to-one and group chats are protected by end-to-end encryption: only the participants in the conversation can read the messages, photos and voice messages, and neither the Company nor our providers have access to their content. The “News Iris Mobile” channel is not end-to-end encrypted: it contains the Company’s announcements, and its messages, as well as reactions and the name of the person reacting, are visible to the Company and to all users of the channel from all organisations. The chat server runs on our servers in Germany (Hetzner), and the encrypted files are stored in Cloudflare R2 with EU jurisdiction.

*What data we process to operate the chat:* your chat identifier (a pseudonym generated from the internal number of your account); your name and profile photo; your organisation and the points at which you book the equipment (visible to the other users in your organisation; in addition, your name and photo are visible to all users of the “News Iris Mobile” channel if you react to its messages); the list of your chats and their participants; the date and time of messages; and details of your devices (device name and IP address of the last sign-in). Your telephone number and email address are not shown to other users. Notifications are sent via Apple without the text of the message or the sender's name.

*Encryption keys.* If you enable key backup, the keys are stored in encrypted form on our server, and the recovery key is stored in your iCloud Keychain. Without the recovery key, neither we nor anyone else can decrypt your history.

*Reports and blocking.* You can block another user and report a message. When you make a report, your phone sends the Company only the reported message (in decrypted form), the reason and your comment. We use them only to handle the report. The person reported will receive an explanation of the decision if a decision affecting them is taken.

*Requests and deletion.* Messages from a person you have not yet chatted with arrive as a request, which you can accept, decline or block. Either participant in a one-to-one chat can delete it for both: the chat is erased from the server and from the devices of both participants. It cannot be deleted while there is an open report about that chat. For each deletion we keep a record (who, with whom and when), without the content, so that we can handle reports.

*Requests from authorities.* We disclose chat data to authorities only where there is a legal obligation and a lawful request. Because of end-to-end encryption, we cannot provide the content of messages in one-to-one and group chats, only the data we retain for the periods set out in section 7.

*Legal bases:* operation of the chat — performance of the contract (Article 6(1)(b) GDPR); handling of reports and measures against abuse — our legitimate interest in secure communication (Article 6(1)(f) GDPR) and compliance with content moderation obligations (Article 6(1)(c) GDPR and Regulation (EU) 2022/2065).

3. What we do not collect

• Geolocation: the app calculates the distance to the point on your phone, and the coordinates are not transmitted to us.
• Face ID, Touch ID and the app PIN code: they work on your phone and never leave it.
• The access key to your payment account (Stripe, SumUp): it is stored only on your phone.
• Data for advertising, analytics or tracking: the Software contains no third-party advertising or analytics trackers.
• Clients' iris photographs are used exclusively to create artistic images; they are not used to identify or authenticate anyone.

4. Why and on what legal basis

4.1. Conclusion and performance of the contract with you and activity at the points: account, profile form, calendar, sessions, training, documents, support chat, chat between users, billing and receipts — Article 6(1)(b) GDPR.

4.2. Compliance with legal obligations: accounting and tax records, retention of receipts and signed documents, responses to requests from public authorities, compliance with content moderation obligations (Regulation (EU) 2022/2065) — Article 6(1)(c) GDPR.

4.3. The Company's legitimate interest — Article 6(1)(f) GDPR: security of accounts and of the system (login log, two-factor authentication, protection against abuse), handling of chat reports, operation of the network (reconciliation of consumables and paper at the points), improvement of the Software and extension of the knowledge base on the basis of anonymised support questions, protection of the Company's rights in disputes. You may object to such processing (section 9).

4.4. We verify identity in order to know with whom we are concluding the contract and to whom we are granting access to the client data processed in the Software — Article 6(1)(b) and Article 6(1)(f) GDPR, having regard to the security-of-processing requirements of Article 32 GDPR.

4.5. We do not make automated decisions that have legal effects for you. The restriction on new bookings until you have completed a course required to use the Software or signed the Terms of Use is a contractual rule applied by the system, and you may contest it by contacting us.

5. To whom we disclose data

The following providers (processors) process data on our behalf and on our instructions:

• Hetzner Online GmbH (Germany) — the servers on which the Software runs and the database is stored, and the chat server; data centres in the EU.
• Cloudflare, Inc. — R2 file storage with EU jurisdiction: support chat photos, profile photos, encrypted chat files and other Software files.
• Stripe Payments Europe, Ltd. (Ireland) — payment of receipts; Stripe receives the amount, the receipt number and your email and name to create a customer profile.
• Apple Inc. — push notifications: Apple receives the device token and the text of the notification.
• Google Ireland Limited (Google Workspace) — the email service through which we send messages (invitations, password resets, copies of signed documents).
• Anthropic PBC / OpenAI — only when the Company connects an AI assistant to the platform for managing the platform: the assistant receives the data needed for the query (name, roles, cities, training and document status), without contact details and without identity documents.

The photo-processing service Eye.Photo (EYEPIC, S.L., Spain) receives clients' photographs for processing; it does not receive photographers' data.

We do not sell personal data and do not disclose it to third parties for their own purposes. Data are disclosed to public authorities only on a lawful basis.

6. Transfers outside the European Economic Area (EEA)

The servers and the database are located in the EU. Transfers of data to providers in the United States — Apple Inc., Cloudflare, Inc., Stripe, Inc., Google LLC, Anthropic PBC and OpenAI — take place on the basis of the European Commission's adequacy decision for organisations certified under the EU-U.S. Data Privacy Framework, or of the standard contractual clauses approved by the European Commission, with supplementary safeguards.

7. How long we keep data

• Scan of the identity document: until the profile form is approved, after which it is deleted; for a form not submitted, returned or left unfinished, 30 days without activity.
• Face photo for the profile form: until the account is deleted.
• Support chat: 12 months from the date of the message.
• Encrypted chat messages and files: for as long as the chat exists and at least one of its participants has an active account.
• Chat after account deletion: deleted together with the account. Access is disabled immediately; the chat profile (name, photo, devices), the key backup and the chats in which you were the only participant are deleted within 3 days, and from the server backups within 30 days. Messages you have already sent may remain on the other participants' devices and are shown as sent by a "deleted user". Reports are kept for the period set out below.
• Chat reports: 12 months from the closure of the report, or longer if they are needed for ongoing proceedings.
• Messages in the “News Iris Mobile” channel: 12 months.
• Record of chat deletions: 12 months.
• Chat server technical logs (IP addresses, devices): 30 days.
• Chat server backups: 30 days.
• Login log: 180 days. Notifications: 90 days.
• Account after deletion: the account is deactivated immediately and is not used; the data needed for record-keeping and the protection of rights (sessions, receipts, signatures, course results) are kept for 4 years (Article 66 of the Spanish General Tax Act), after which the account data are anonymised; accounting documents, receipts and signed documents are kept for up to 6 years, as set out below.
• Accounting records, receipts and signed documents: 6 years (Article 30 of the Spanish Commercial Code).
• All other data: for the term of the contract with you and, after its termination, for up to 5 years (the limitation period, Article 1964 of the Spanish Civil Code).

8. Security

Access to the Software is protected by a password and mandatory two-factor authentication. Data are transmitted only over secure connections. Particularly sensitive data (profile form, documents, chat messages) are stored in the database in encrypted form. Within the Company, access to your data is limited by roles, and actions in the system are recorded in a change log. Database backups are encrypted.

9. Your rights

You have the right of access to your data, and the rights to rectification, erasure, restriction of processing and data portability, as well as the right to object to processing based on legitimate interest. You can change your name, contact details, language and profile photo yourself in the app or on the web platform. You can delete your account in the app (Profile → Delete account): access ends immediately, and the data we are obliged to retain are kept for the periods set out in section 7.

To exercise your rights, write to privacy@irismobile.eu. We respond within one month. If you believe your rights have been infringed, you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es).

10. Age

The Software is intended solely for professional use by persons who have reached the age of 18.

11. Changes to this policy

We may update this policy. We give notice of material changes in the app or on the web platform and by email. The current version is always available at the permanent address app.irismobile.eu/privacy.

12. Languages

This policy is available in Ukrainian, Russian, English, Spanish and Polish. In the event of any discrepancy between the versions, the Spanish text prevails.

13. Contacts

IRIS MOBILE LAB, S.L.
NIF: B05661319
Registered office: Calle Otumba, 5, puerta B, 41001 Seville, Spain.
Personal data enquiries: privacy@irismobile.eu. Technical support: support@irismobile.eu.