Your data.
Under your control.

Data controller

Primo-Studio, French Simplified Joint-Stock Company (SAS), registered under SIREN 985 162 924 (head office SIRET: 985 162 924 00015), APE code 5912Z.

Registered office: 5 Allée Belimbi, 97320 Saint-Laurent-du-Maroni, French Guiana (European Union territory 🇫🇷🇪🇺).

President: Palmena Pompeu de Sales Neto (a.k.a. "Néto").

DPO / GDPR contact email: [email protected]

For any question about your personal data, to exercise your rights, or to report an incident, please write to this address.

Our role · your role

You are the data controller (under GDPR article 4-7): you collect image and voice rights authorizations from your signers, you decide how to use them (commercial, press, web, print), and you assume legal responsibility toward your models, talents, extras, employees, students, and their legal representatives.

Primo-Studio is a technical tool (data processor under GDPR article 28). We provide the PixConsent app to generate your documents and store them. We never access their content (end-to-end encryption), we don't read them, we don't exploit them, we don't sell them, we don't train any AI model on them.

Practical consequences:

• Any access, rectification or deletion request from a signer is addressed directly to you (the app user), not to Primo-Studio. You handle it from the app: Settings → My signers → Export / Delete.
• You are the owner and responsible for the generated PDFs, collected signatures, selfies, and signature metadata. You ensure their retention in compliance with the legal obligations of your profession (typically 5 to 10 years depending on country and use).
• If you export your data to your computer, your personal cloud, or another tool, this data leaves the PixConsent ecosystem and becomes entirely under your responsibility — Primo-Studio can no longer protect it or guarantee its confidentiality.

What data we collect

PixConsent collects two categories of data: those of the photographer/videographer (you, the app user) and those of the signer (the model who signs the release form).

What we NEVER collect: your continuous location, your iPhone contacts, your photo library, your browsing history, your IP outside the signature moment.

How long we keep your data

You delete your PixConsent account → all your server data (Team/Agency) is automatically and immediately erased on Firebase Frankfurt. Your local data on iPhone is erased by iOS as soon as you uninstall the app.

You delete a specific data point (a project, a signer, a PDF) → automatic and immediate deletion on all your synced devices (Team/Agency). Hard-delete: no hidden bin, the operation is irreversible.

Inactive account > 12 months → automatic deletion of your server data after 2 reminder emails sent at 11 and 12 months of inactivity. This automatic deletion is a privacy protection measure for signers (GDPR principle of minimization and limited retention duration — article 5-1-e).

Free + Pro plans (local storage): your data is on your iPhone as long as the app is installed. You uninstall = iOS erases everything.

Team + Agency plans (encrypted Frankfurt cloud): retained as long as your subscription is active. On cancellation, we keep the data for 30 days (in case you re-subscribe), then permanent deletion.

Exported signed PDFs: once you export a PDF (share, email, computer backup), it leaves PixConsent. You then own and are responsible for its retention according to the legal obligations of your profession (typically 5 to 10 years).

Your rights

You have the following rights over your personal data, in accordance with GDPR:

• Right of access — get a complete copy of your data (ZIP export with JSON + PDFs)
• Right of rectification — correct incorrect data
• Right to erasure ('right to be forgotten') — delete account + all data
• Right to portability — get your data in a reusable format
• Right to object — refuse certain processing (e.g. marketing emails)
• Right to restriction — freeze processing during a dispute

How to exercise these rights: directly from the app in Settings → Account → My data. Immediate action. Otherwise by email at [email protected] — reply within 30 days max. In case of disagreement, you can refer to the CNIL (cnil.fr) in France, or your local supervisory authority (LGPD in Brazil, CCPA in the USA, etc.).

Who we work with

PixConsent uses carefully selected processors, all covered by a DPA (Data Processing Agreement):

• Apple App Store — App distribution + IAP payments · Ireland 🇮🇪
• Firebase / Google Cloud — Authentication + encrypted cloud storage (Team/Agency) · Frankfurt 🇩🇪 (eur3)
• Resend — Transactional emails (auto-email to signer, exports) · United States 🇺🇸 (EU SCC)
• Sentry — Error monitoring (anonymized) · United States 🇺🇸 (EU SCC)

Note: none of these processors have access to your signatures, selfies or PDFs (encrypted on the app side). Apple only sees the purchase. Firebase only sees project metadata for Team/Agency plans.

Where your data is stored

Free + Pro plans: no cloud storage by default. Data on your iPhone only. You can activate cloud opt-in (500 MB Free / 2 GB Pro) to back up in case of phone loss/theft.

Team + Agency plans: storage on Firebase eur3 (Frankfurt, Germany), end-to-end encrypted. No transfer outside the EU for user data.

US processors (Resend, Sentry) are covered by Standard Contractual Clauses approved by the European Commission (article 46 GDPR) and receive no signer data (signature, selfie, PDF).

Liability limits

PixConsent is a helper tool to secure image and voice rights collected by image professionals. Generated PDFs comply with eIDAS requirements (article 25 of the European regulation) and GDPR 🇪🇺, LGPD 🇧🇷, CCPA 🇺🇸 directives of the main markets.

However, the app is distributed in 175 countries via the App Store, and we cannot guarantee 100% that the generated documents cover all local legal specificities of each jurisdiction (mandatory mentions specific to a country, different legal retention periods, required formats, etc.).

If you identify a particular legal requirement in your country that isn't covered by PixConsent PDFs — flag it to us at [email protected]. We'll analyze it and add it in a future update if it applies to your jurisdiction.

Theft, loss or destruction of your iPhone: data stored locally is under your exclusive control (iOS security, unlock code, Face ID/Touch ID). In case of theft, loss, destruction of the device, or unauthorized access by a third party to your iPhone, Primo-Studio cannot be held responsible for the loss of data or its exploitation by a third party.

To protect against this, activate cloud opt-in storage in Settings → Storage:
- Free: 500 MB cloud opt-in
- Pro: 2 GB cloud opt-in
- Team / Agency: encrypted cloud sync included

This option lets you recover your signatures and PDFs from a new iPhone by simply logging back in with your account.

No AI training, no consultation

We don't train any artificial intelligence model (LLM, vision, etc.) on your PDFs, signatures, selfies, or metadata. We never read them — not even internally, except for explicit manual support intervention if you authorize us (technical debugging).

Your content is end-to-end encrypted and accessible only by you and your team.

Cookies and tracking

On primo-studio.fr/app/pixconsent: no marketing cookies, no advertising tracker. No Google Analytics, no Meta Pixel, no TikTok Pixel.

We only use technical cookies necessary for operation (language preference, session state). No consent required for these cookies (article 82 LIL).

In the iOS app: no advertising tracking SDK. Apple App Tracking Transparency (ATT) is not requested because we don't track the user.

Minors

PixConsent is designed for adult professional use (photographers, videographers, agencies). The app is not intended for minors as users.

However, signers can be minors (typical case: school photography). In this case, PixConsent automatically requests the signature of the legal representative (one or two parents, depending on user settings), in accordance with article 8 GDPR.

Changes

We may update this policy. In case of substantial change, we will notify you by email + in-app notification, with 30 days notice before entry into force.

You always have access to the version history on this page (version number + date displayed at the top).

Contact us

For any question, to exercise a right, or to report an incident:

Email: [email protected] (reply within 7 days, 30 days legal max)

Postal address: Primo-Studio, 5 Allée Belimbi, 97320 Saint-Laurent-du-Maroni, French Guiana, France

For users residing in the EU, you can also refer to the competent supervisory authority (in France: CNIL — cnil.fr; in Germany: BfDI; in Brazil: ANPD; in the USA: FTC depending on the state).