Legal

Privacy Policy

Version 2.0 — effective 2026-08-06. Previous versions available on request.

This policy explains what personal information Lumière collects, why, who we share it with, and what you can do about it. We follow South Africa’s Protection of Personal Information Act (POPIA). If you are in the EU, UK or California, the sections marked below give you additional rights.

1. Who we are

Lumière is operated by Eternity Photography (Pty) Ltd (Private company, registration number 2024/675191/07), at 282 Tryall Road, Cape Town, 7441, telephone 061 788 1002, email eternitysoftwaresolutions.16@gmail.com.

We play two different roles:

  • We are the responsible party (controller) for information about photographers who hold accounts with us, and for information we collect directly from gallery visitors, contract signers and invoice recipients — such as IP addresses and download email addresses.
  • We are an operator (processor) for the client records, photographs, contracts, invoices and projects that photographers upload and manage. In that role the photographer decides what happens to that information, and we act on their instructions. Our Operator Agreement sets out those terms.

2. What we collect

If you are a photographer with an account: your name, email address, password (stored as a bcrypt hash — we never see or store your actual password), business name, tagline, logo, brand colour, profile URL, and — if you sign in with Google — your Google profile image and the access tokens that let us verify your sign-in. If you subscribe, we store your Paystack customer and subscription references and a card authorisation code. We never see or store your card number. We also store your default currency, invoice numbering, payment instructions and your saved signature.

Information you upload about your clients: names, email addresses, phone numbers, company names, billing addresses and any notes you enter; the photographs you upload; contracts you create, including signer names, email addresses and signature images; invoices, line items and payment records; and projects.

Photographs and what’s inside them: we store your original files exactly as uploaded. Original photo files usually contain embedded metadata (EXIF) — including GPS coordinates of where the photo was taken, camera serial numbers and exact timestamps. You can strip location data from downloads on a per-gallery basis in gallery settings. The smaller preview images we generate do not contain this metadata.

If you visit a gallery: if you enter a PIN, we record your IP address, your browser’s user-agent string and the time, so we can detect abuse of the PIN gate. We keep this for 30 days. If you download photos, we record the email address you enter, which gallery and which photos, and the time. The photographer can see this. We keep download records for 12 months. We also count gallery views and downloads.

If you sign a contract: your name, email address, the signature you draw or type, your IP address, your browser’s user-agent string and the time. This is kept as evidence that you signed, for as long as the photographer keeps the contract.

Cookies and browser storage. We use only what is necessary to make Lumière work. We do not use analytics, advertising or tracking cookies of any kind, and we do not run any third-party trackers. Specifically:

WhatWherePurposeLifetime
Session cookieCookieKeeps you signed in to the portalSession
gal_{photographer}_{gallery}Cookie (HttpOnly)Records that you entered a valid gallery PIN24 hours
lumiere_fav_{gallery}localStorageYour favourited photos. Never sent to our servers.Until you clear it
lumiere_dl_emailsessionStorageRemembers your download email so we don't ask twiceSession
lumiere_pending_plan, lumiere_pending_intervalsessionStorageCarries a chosen plan through sign-upSession
Gallery view counter keysessionStorageStops one visit counting as many viewsSession

Because all of these are strictly necessary for functions you have asked for, we do not show a cookie banner. If we ever add analytics or advertising, we will ask for your consent first.

3. Why we're allowed to process it

What we doOur legal basis
Run your account, deliver galleries, generate contracts and invoicesNecessary to perform our contract with you
Take subscription paymentsNecessary to perform our contract with you
Send verification, password reset, billing and receipt emailsNecessary to perform our contract with you
Log IP addresses at the PIN gate and on contract signingOur legitimate interest in preventing abuse and evidencing signatures
Record download email addressesOur legitimate interest, and the photographer's, in knowing who received the work
Meet tax, accounting and legal obligationsLegal obligation

We do not use your data, or your clients’ data, or your photographs, to train any AI or machine-learning model, and we do not send any of it to an AI provider.

4. Who we share it with

We do not sell personal information and we do not share it for advertising. We use these service providers:

ProviderWhat they doWhere they process
Vercel Inc.Application hosting, server logsUnited States (confirmed: US East)
Neon Inc.PostgreSQL database[confirm exact region in Neon dashboard — typically US or EU depending on project settings]
Cloudflare, Inc.Photograph storage (R2) and delivery[confirm primary storage region in Cloudflare dashboard; delivered via Cloudflare's global CDN]
Upstash, Inc.Rate limiting[confirm region in Upstash dashboard]
Resend (Plus Five Five, Inc.)Sending our emailsUnited States
Google LLC"Sign in with Google", if you use itUnited States (Google global infrastructure)
Paystack Payments LimitedSubscription billing and card processingSouth Africa

We will publish any change to this list at this page at least 30 days before it takes effect. If you are a photographer and you object to a new provider, email us and we will discuss it with you.

We will also disclose information if the law requires it, or to establish or defend a legal claim.

5. Sending information outside South Africa

Most of the providers above process data outside South Africa, mainly in the United States. We rely on section 72 of POPIA:

  • Section 72(1)(b) — necessary to perform our contract with you. Lumière is a hosted service. We cannot deliver it without hosting your data with these providers.
  • Section 72(1)(a) — binding agreements. We rely on each provider’s data processing agreement, which requires them to protect personal information to a standard comparable to POPIA. Where a provider processes EU or UK personal data, their agreements include the European Commission’s Standard Contractual Clauses.

If you are in the EU or UK, the same agreements are our Chapter V transfer mechanism.

6. How long we keep things

DataHow long
Photographer account and its contentsWhile your account is open, and until you delete it
PhotographsUntil you delete the photo or the gallery
Client records, contracts, invoices, projectsUntil you delete them, or you close your account
PIN-gate IP and user-agent logs30 days
Gallery download records12 months
Contract signature evidenceAs long as the photographer keeps the contract
Billing records5 years, to meet South African tax record-keeping requirements

7. Your rights

You can ask us to: tell you what personal information we hold about you and why; correct anything wrong; delete it; give you a copy in a common machine-readable format; or stop processing it where we rely on legitimate interests. You can also complain to us, and to the Information Regulator.

Self-service: you can deactivate your account, delete your account entirely, and download a copy of your data at any time from Settings → Security.

For anything else: email eternitysoftwaresolutions.16@gmail.com with “Privacy request” in the subject. We will respond within 30 days. We may ask you to confirm your identity first.

If you are a client of a photographer and you want your details or your photographs corrected or removed, contact the photographer first — they control that information. If you cannot reach them, contact us and we will help.

If you are in the EU or UK: you also have the right to object to processing, to restrict processing, and to lodge a complaint with your national supervisory authority. We do not carry out automated decision-making that produces legal effects.

If you are in California: we have not sold or shared personal information for cross-context behavioural advertising in the preceding 12 months, and we do not do so now. We do not process sensitive personal information for the purpose of inferring characteristics. You have the right to know, delete, correct and to non-discrimination — use the same email above. Because we do not sell or share, we do not need a “Do Not Sell or Share My Personal Information” link, and there is nothing for a Global Privacy Control signal to act on.

8. Security

Passwords are hashed with bcrypt (cost factor 12) and never stored in readable form. Gallery PINs are hashed with bcrypt. Session and PIN cookies are HttpOnly, Secure and SameSite. Sign-in, PIN entry, uploads, downloads and contract signing are all rate-limited. All traffic is over HTTPS and stored data is encrypted at rest by our providers.

Please read this carefully: photograph files are served from a content delivery network using long, random, unlisted URLs. A gallery PIN protects the gallery page — it does not protect an individual photo file if someone has that file’s direct URL. Do not treat Lumière as the only safeguard for highly sensitive photographs.

No online service is completely secure, and we cannot guarantee absolute security.

9. If something goes wrong

If personal information under our control is accessed by someone unauthorised, we will notify the Information Regulator and the people affected as soon as reasonably possible after we establish what happened. Where GDPR applies, we will notify the relevant supervisory authority within 72 hours. If you think there has been a breach, email eternitysoftwaresolutions.16@gmail.com immediately with “Security” in the subject.

10. Children

Lumière is for professional photographers and you must be 18 or older to hold an account. We do not knowingly collect information directly from children. Photographers may upload photographs of children, and when they do it is the photographer’s responsibility to hold the guardian’s consent. If you believe a photograph of a child has been uploaded without proper consent, email eternitysoftwaresolutions.16@gmail.com and we will act promptly.

11. Our Information Officer

Our Information Officer is Emilio Chanderdutt, reachable at eternitysoftwaresolutions.16@gmail.com / 061 788 1002. You may also complain to the Information Regulator (South Africa) at complaints.IR@inforegulator.org.za, or at inforegulator.org.za.

12. Changes

We will post any change here and update the version and effective date. If a change materially affects your rights we will email account holders at least 30 days beforehand.