1p-photo Data Processing Agreement (DPA)

Effective Date: 1 June 2025

1. Introduction

This Data Processing Agreement (“DPA”) forms part of the agreement between you (“User” or “Data Controller”) and 1p-photo (“we”, “us”, “our”, “Data Processor”) regarding the processing of personal data in connection with your use of the 1p-photo app and related services.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person processed through 1p-photo.
• Processing: Any operation performed on personal data, such as collection, storage, use, modification, or deletion.
• Data Controller: The person or entity that determines the purposes and means of processing personal data (you, the user).
• Data Processor: The person or entity that processes personal data on behalf of the Data Controller (1p-photo).
• Sub-processor: A third party engaged by 1p-photo to process personal data as part of providing the service.

3. Subject Matter and Duration

This DPA governs the processing of personal data as long as you use 1p-photo and until all personal data has been deleted or returned as requested.

4. Nature and Purpose of Processing

1p-photo processes personal data (including uploaded images and related metadata) solely for the purpose of providing, maintaining, and improving the photo enhancement service, as described in the Terms of Use and Privacy Policy.

5. Types of Personal Data and Data Subjects

• Types of Data: Uploaded images, email addresses, usage data, and other information provided by the user.
• Data Subjects: Individuals depicted in uploaded images, account holders, and users of the app.

6. Obligations of 1p-photo (Data Processor)

• Process personal data only on documented instructions from the User, unless required by law.
• Ensure that persons authorized to process personal data are bound by confidentiality obligations.
• Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
• Assist the User in fulfilling their data protection obligations, including responding to data subject rights requests.
• At the User’s choice, delete or return all personal data after the end of the provision of services, unless retention is required by law.
• Make available all information necessary to demonstrate compliance with applicable data protection laws and allow for audits, as required.

7. Sub-processors

• 1p-photo may engage third-party sub-processors (such as cloud storage or image enhancement API providers) to process personal data for the purposes of delivering the service.
• 1p-photo will ensure sub-processors are bound by data protection obligations compatible with this DPA.
• A list of current sub-processors is available upon request. Users will be notified of any intended changes to sub-processors, giving them the opportunity to object.

8. International Data Transfers

Where personal data is transferred outside the user’s jurisdiction, 1p-photo will ensure appropriate safeguards are in place, such as standard contractual clauses or equivalent mechanisms, as required by applicable law.

9. Data Subject Rights

1p-photo will assist the User in responding to requests from data subjects exercising their rights (access, rectification, erasure, restriction, portability, objection) under applicable data protection laws.

10. Security Measures

1p-photo maintains appropriate technical and organizational security measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage.

11. Data Breach Notification

In the event of a personal data breach, 1p-photo will notify the User without undue delay and provide information regarding the nature of the breach and mitigation steps taken.

12. Termination

Upon termination of the service, 1p-photo will, at the User’s choice, delete or return all personal data, except where retention is required by law.

13. Governing Law

This DPA is governed by the laws applicable to the main agreement between the User and 1p-photo.

14. Contact

For questions about this DPA or data processing, contact:
Email: team.1pphoto@gmail.com