This notice explains how BrandPacks Limited, which runs PhotoPostman, handles personal data. It covers:
- customers: the businesses and people who create PhotoPostman accounts;
- recipients: guests, event organisers and other people who open a PhotoPostman gallery or transfer; and
- website visitors: people who visit photopostman.com.
1. Who we are and how to contact us
BrandPacks Limited
Unit 1603, 16/F, The L. Plaza
367-375 Queen's Road Central
Sheung Wan, Hong Kong
Privacy contact: privacy@photopostman.com
General support: support@photopostman.com
Representative in the European Union: To be confirmed EU representative under Article 27 GDPR, to be appointed. Name and contact details will be added here.
Representative in the United Kingdom: To be confirmed UK representative under Article 27 UK GDPR, to be appointed. Name and contact details will be added here.
2. Our role depends on the data
Data protection law distinguishes between a controller, who decides why and how personal data is used, and a processor, who handles data on someone else's behalf. PhotoPostman plays different roles for different data.
| Data | Who is responsible | Our role |
|---|---|---|
| Your account, sign-in, security, support and our service emails | BrandPacks Limited | Controller |
| Subscription and plan records we keep (plan, term, status, provider reference numbers) | BrandPacks Limited | Controller |
| Payment details, tax calculation, receipts and invoices for paid plans | Paddle, our merchant of record | Paddle acts as an independent controller under its own privacy notice. We are a separate controller for the records Paddle shares with us |
| Optional marketing emails to account owners | BrandPacks Limited | Controller |
| Website visits and security logs for our own service | BrandPacks Limited | Controller |
| Event media (photos, videos, audio) and the information that comes with it: file names, embedded metadata, captions, gallery content | The photo booth business or photographer who uses PhotoPostman, or the organiser they work for | Processor for our customer, or sub-processor where our customer acts for an organiser |
| Recipient details that our customer enters or that a gallery generates for them: organiser and transfer recipient email addresses, messages, and download records shown in the dashboard | Our customer | Processor |
| Rate limiting and abuse protection on galleries and transfers (for example blocking repeated wrong passwords) | BrandPacks Limited | Controller, to keep the service secure |
If you are a guest or an organiser, the business that delivered your gallery decides what is shared, with whom and for how long. Please contact that business first about photos, videos or recordings of you. If you contact us, we will pass your request to them and help them deal with it (see section 9).
Our customers' use of event media is governed by our Data Processing Agreement.
3. What we collect
About customers
- Account details: name, email address, password (stored only as a secure hash), language, two-step sign-in settings, and marketing preferences together with a record of when and how you gave them.
- Business details: business name, billing country, branding (logo, cover image, colours), custom domain.
- Usage records: events, transfers, storage and processing used, plan and trial dates.
- Device details for the desktop uploader: device name, operating system and app version, and when it last connected.
- Connected cloud accounts: the provider, the account identifier or email address it reports, the folders you select, file listings of those folders, and access tokens. Tokens are stored encrypted.
- TemplatesBooth link: if you link accounts, the link identifier and a record of actions taken through the integration.
- Billing records: plan, term, renewal and cancellation dates, and Paddle customer and subscription identifiers. We do not receive or store full card numbers.
- Support messages you send us.
- Notices we send: which service email was sent, its language and version, and whether it was delivered. We keep a copy of price-change and other legal notices.
About recipients
- A short-lived gallery session cookie after a correct password is entered (see our Cookie Information).
- Technical and security data: IP address, browser type, time of access and failed password attempts.
- Coarse download records (for example, that a transfer download started or completed). We do not claim to know exactly who downloaded a file.
- Email address, only if the business that delivered the gallery enters it (for example to send an organiser link or a transfer), or if you write to us.
About website visitors
- Technical data needed to deliver the page securely: IP address, browser type, the pages requested and the time.
- Your language choice.
Event media. Photos, videos and audio recordings show or record people, sometimes children, and can occasionally reveal sensitive information. Original files may also contain embedded data such as the date, camera model or location. We remove location and similar data from the previews we generate, but originals are delivered unchanged.
4. Why we use personal data, and our legal basis
Where we are the controller, we rely on the following legal bases under the EU and UK GDPR. Equivalent principles apply under Hong Kong's Personal Data (Privacy) Ordinance.
| Purpose | Legal basis |
|---|---|
| Creating and running your account, providing galleries, transfers, QR links, uploads, connections and exports | Performing our contract with you |
| Service emails: verification, sign-in and recovery, upload problems, delivery and transfer notices, expiry, export and deletion reminders, billing and access changes, price-change notices | Performing our contract. Some notices are also legally required |
| Keeping the service secure: sign-in protection, rate limits, abuse and fraud prevention, stopping repeated trials, audit logs | Our legitimate interest in protecting the service, our customers and recipients. We use limited signals such as verified email, account history and rate limits, and we do not use invasive device fingerprinting |
| Billing, accounting and tax records | Performing our contract and complying with our legal obligations |
| Answering support requests | Performing our contract, or our legitimate interest in helping people who contact us |
| Understanding how much storage and processing the service uses, to plan capacity and pricing (aggregated, never by looking at your media) | Our legitimate interest in running a sustainable service |
| Optional marketing emails about PhotoPostman | Your consent, which you can withdraw at any time |
| Handling content reports, legal requests and claims | Complying with legal obligations, and our legitimate interest in defending legal claims and protecting rights |
Event media and recipient details are processed on our customer's instructions. Our customer is responsible for having a valid legal basis, for example for photographing guests, and for giving guests suitable information. An upload does not by itself mean that everyone pictured has consented.
What we never do with your data: we do not use face recognition or biometric matching, we do not build advertising profiles, we do not train AI models on customer media, and we do not sell personal data.
Required and optional information. You must give us an email address and business name to use PhotoPostman. Everything else, including marketing consent, is optional.
5. Marketing
We send marketing and onboarding emails (tips, product news, offers about PhotoPostman) only to account owners who have opted in. These emails may be personalised using your name, email address, language, plan, trial dates and setup progress. This is the data we use for direct marketing under Hong Kong law. Every marketing email has an unsubscribe link, and you can also change your choice in your account settings. Unsubscribing never stops necessary service emails, and you never need to agree to marketing to export your files.
We never add guests, organisers, transfer recipients or other people in your galleries to any PhotoPostman or TemplatesBooth mailing list.
6. Who we share data with
- Service providers who host and run PhotoPostman for us under contract. They are listed on our Subprocessors page.
- Paddle, when you buy a paid plan. Paddle handles checkout, payment, tax and invoices as merchant of record, under its own privacy notice.
- Services you choose to connect, such as Dropbox, Google Drive, OneDrive or TemplatesBooth, only as needed to do what you asked.
- People you share with. Recipients of your galleries and transfers see what your settings allow.
- Authorities, courts or advisers, when the law requires it, or when it is needed to protect rights, safety or the security of the service.
- A buyer or successor, if PhotoPostman or BrandPacks Limited is reorganised or sold. This notice will continue to protect your data.
7. Where your data is stored and processed
- Storage in the EU. Our main database and file storage use Cloudflare's EU jurisdiction option, so data at rest stays in the European Union. Media processing runs on a server in Frankfurt, Germany. The recovery archive is stored with DigitalOcean in To be confirmed confirm EU region of DigitalOcean Cold Storage, for example Amsterdam or Frankfurt.
- Global network. Cloudflare's network handles requests at the data centre nearest to the person using the service, which may be outside the EU. This means data passing through, including temporary image previews made while our EU processing server is being set up, can be processed briefly in other countries.
- Hong Kong. BrandPacks Limited is based in Hong Kong. Our team administers the service and handles support from Hong Kong and other locations, which can involve remote access to account data and, when strictly necessary, to media.
- Email and payments. Service emails are sent through Twilio SendGrid To be confirmed confirm whether SendGrid EU data residency is enabled; if not, processing takes place in the United States. Marketing emails are sent through Mailcoach (Spatie, Belgium). Paddle is based in the United Kingdom.
Where personal data protected by EU or UK law is transferred to a country without an adequacy decision, we use the safeguards the law provides, such as the European Commission's Standard Contractual Clauses and the UK's equivalent. To be confirmed transfer mechanisms to be confirmed by counsel, including the arrangement for access from Hong Kong. You can ask us for more information at privacy@photopostman.com.
Storing data in the EU is a design choice to keep data close to most of our customers. It does not mean that every part of the service runs only in the EU.
8. How long we keep data
| Data | How long |
|---|---|
| Hosted event media while active | Until you delete it or its gallery or transfer expires |
| Hosted media after expiry or closing (paid plans) | Up to 90 days in the recovery archive, then permanently deleted |
| Trial media | Permanently deleted 14 days after the trial ends, unless you move to a paid plan |
| Temporary ZIP files | Deleted within 24 hours |
| Previews from connected cloud sources | Deleted when the item, connection or gallery is removed or expires |
| Cloud connection tokens | Deleted when you disconnect |
| Operational logs | 14 days, without media content, passwords or tokens |
| Security and audit records | 90 days, longer only while needed for an open investigation or legal claim |
| Account details | While your account is open, then deleted after closure as described in our Retention and Recovery Policy |
| Billing and tax records | As long as tax and accounting law requires To be confirmed currently planned as 7 years under Hong Kong record-keeping rules, to be confirmed |
| Marketing unsubscribe records | Kept in minimal form so we never email you again by mistake |
Full details, including how backups are handled, are in our Retention and Recovery Policy.
9. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you and get a copy;
- correct inaccurate data;
- delete data;
- restrict or object to how we use it, including objecting to processing based on legitimate interests;
- receive your data in a portable format; and
- withdraw consent at any time, for example to marketing, without affecting earlier processing.
Under Hong Kong law you may request access to and correction of your personal data.
To make a request, email privacy@photopostman.com. We may ask you to confirm your identity in a proportionate way. We reply within one month. If a request is complex, we may extend this by up to two further months where the law allows, and we will tell you why within the first month. We respond to Hong Kong data access requests within 40 days. Customers can also download their files and account data directly from the dashboard.
Requests about event media. If you are a guest or organiser and want a photo or recording of you removed, the business that delivered the gallery is responsible. Please contact them. If you contact us instead, we will forward your request to them, help them find and act on the media, and tell you we have done so. We will not show you the contents of other people's events.
Deletion and connected cloud accounts. Deletion in PhotoPostman removes our copies, including recovery copies, previews and temporary files. It does not delete originals in someone's own Dropbox, Google Drive or OneDrive. Those must be deleted there.
10. Complaints
Please contact us first at privacy@photopostman.com so we can try to help. You also have the right to complain to a data protection authority:
- in the EU or EEA, the authority in the country where you live, work or where you think the problem happened;
- in the UK, the Information Commissioner's Office (ico.org.uk); or
- in Hong Kong, the Office of the Privacy Commissioner for Personal Data (pcpd.org.hk).
11. Security
We protect personal data with technical and organisational measures appropriate to the risk. Our Security page describes them. No system is perfectly secure. If a personal data breach occurs, we follow our incident procedure: we assess it, notify affected customers without undue delay, and, where we are the controller, notify the authorities and affected people when the law requires it.
12. Cookies
We use only essential cookies, for sign-in, gallery access, language and security. We use no analytics or advertising cookies. See our Cookie Information.
13. Children
PhotoPostman accounts are for adults acting for a business. Galleries may contain photos or recordings of children taken at events. The business that delivers the gallery is responsible for having the right permissions. We do not knowingly collect personal data directly from children.
14. Automated decisions
We do not make decisions with legal or similarly significant effects about you based solely on automated processing. Automated limits (such as storage allowances or blocking repeated wrong passwords) apply the published rules, and you can always contact us to have a person review a decision.
15. Changes to this notice
We will update this notice when our practices change and show the date at the top. We tell customers about significant changes by email before they apply.