Template — requires lawyer review. This notice is a working draft prepared for counsel. It is not legal advice, and its section references must be checked against the official Act and Rules before it is relied on.
Privacy notice and your rights
Snabb is software that wedding and event photography studios in India use to share photos with couples and guests, and to run their bookings. This notice explains what personal data is handled, why, for how long, and how you can exercise your rights under the Digital Personal Data Protection Act, 2023 (“the Act”) and the DPDP Rules, 2025.
Who is responsible for your data
The studio that photographed your event decides why and how its guests’, couples’ and clients’ data is used. It is the Data Fiduciary for that data: its galleries, guest lists, reminders, face-search settings, contracts and invoices.
Snabb runs the service for the studio as its Data Processor, under a written agreement (the Data Processing Addendum), and does not use guests’ data for advertising, for training models or for anything the studio has not asked for. Snabb is itself the Data Fiduciary for studio staff accounts, studio billing, support, platform security logs and this website.
You can contact either. A request about an event goes to that studio when you give the event code in the form below; otherwise it comes to Snabb, and we pass it on or help the studio answer it.
What personal data is handled
- Guests: a selfie, only while your search runs; which event photos you appear in; the favourites, downloads and shares you make; the age answer you give; optionally your name, phone number or email; feedback and video wishes you choose to leave.
- Parents and guardians: name, relationship to the child, and an email address if you verify by code; a record that you consented for the child.
- Couples: the gallery PIN, your selections, comments, feedback and album approvals.
- Studio clients: enquiry, booking, contract, invoice and payment details.
- Studio staff: account, sign-in and activity records.
- Technical: IP address and browser on consent and security records; a private, HttpOnly cookie that keeps a guest signed in to their own photos; your age answer in this browser tab only. No advertising trackers.
Purposes and legal bases
| Purpose | Data | Basis (Act) | Decided by |
|---|---|---|---|
| Finding your photos of an event with a selfie | Selfie (in transit only), which event photos you appear in, a session token | Your consent, asked for before the camera opens (s.6); a parent or guardian’s consent for a child (s.9) | The studio that ran the event |
| Showing you, downloading and sharing your photos | Your matches, favourites, downloads and shares | Your consent (s.6) | The studio |
| Telling you when more photos are ready (reminders) | Phone number or email you gave, whether you opened the gallery | Your consent (s.6); never for children | The studio |
| The couple’s private gallery, selections and album proofs | Gallery PIN, selections, comments, feedback | Contract with the studio; consent where asked | The studio |
| Showing chosen photos on the studio’s public portfolio | Photos the couple agreed to one by one, with their typed name and the notice they saw; for a child, a parent or guardian’s consent reference; for anyone else in a photo, the studio’s statement that they agreed | The couple’s consent per photo, withdrawable at any time (s.6); a parent or guardian’s consent for a child (s.9) | The studio |
| Bookings, contracts, invoices and payments | Name, contact details, billing address, GSTIN, payment references | Contract; legal obligation for tax records (s.7) | The studio |
| Studio accounts, sign-in, billing and support | Staff names, emails, sign-in records | Contract with the studio | Snabb |
| Security, fraud and abuse prevention | IP address, browser, audit records, coded replay signals (never images) | Legitimate uses and legal obligations (s.7) — counsel to confirm | Snabb and the studio |
| Counting how galleries are used | Aggregate counts without identifiers; nothing per child | Legitimate use (s.7) — counsel to confirm | The studio |
Consent is asked for one purpose at a time, in a notice shown before the camera opens, in English, Hindi or Tamil. Each notice has a version and a fingerprint; we record which one you saw and agreed to. The Hindi and Tamil wording is a draft awaiting legal and translator review; the English text prevails until then.
How face search works
- You take three photos of yourself on the event page. They are sent to the service, compared with the faces found in that one event’s photos, and then discarded. Your selfie is never stored, and neither is the face signature computed from it.
- Face signatures are made only from the studio’s own event photos, which may include your face, kept only for that event, and deleted with the event at its deletion date. When you withdraw consent or your data is erased, the signatures of your face that matched you stop being searchable at once and are deleted from the face service. A studio can also delete an event’s whole face index and keep its photos.
- You see only photos matched to you. Uncertain matches are shown to you alone, for you to confirm or reject.
- To stop someone using another person’s photo, the service checks for replayed or identical captures and asks for a random head movement. It keeps only a coded fingerprint of the frames, never the images, for about an hour (one day at the most). These checks are not a full “liveness” test, and we do not claim they are. A studio can mark an event high-risk, in which case every guest also confirms an email address before searching.
- On WhatsApp, face search is for adults only, after you confirm you are 18 or over and have read the notice.
- You can withdraw at any time with the Withdraw consent button on your photos page. It deletes your matches, actions and links at once. Stopping reminders is a separate button.
Children (under 18)
Under the Act a child is anyone under 18, and a child’s data needs the verifiable consent of a parent or lawful guardian (s.9; Rules r.10). Before the camera opens we ask who the search is for. For a child, a parent or guardian must consent first, in one of three ways: by being present and searching on the child’s behalf with a signed declaration; by being verified in person by the studio at the venue; or by a one-time code sent to their email. “I’m not sure” does not allow a search.
We do not keep a child’s selfie or a face signature made from it (signatures from the studio’s event photos, which may include a child, are deleted for the child’s matches on withdrawal), do not send children reminders, do not include children in per-person analytics, and do not track, profile or target advertising at children. A studio can turn off children’s search for an event. A parent or guardian’s consent lasts 24 hours at most and covers one child.
How long data is kept
Data is erased when its purpose ends, when you withdraw consent or when you ask, unless a law requires it to be kept (s.8(7)). Invoices are the main exception: they are kept 8 years from the end of the financial year, as tax law requires, with optional details removed if you ask for erasure.
| Data | What it holds | How long | Kept longer for |
|---|---|---|---|
| Guests | Name, phone, email (when given), access token hash, last seen, age band | Emptied immediately on withdrawal or erasure; deleted with the event at its purge date | Pseudonymous consent evidence only |
| Consent records | Notice wording and hash, IP address, browser | Kept as proof of consent; IP cut to its network and browser hashed after 1 year | Compliance and legal defence |
| Consent ledger | Grant and withdrawal events, notice version, method, IP, browser | Append-only; IP and browser minimised after 1 year; detached from the person on erasure | Compliance and legal defence |
| Guardian consent | Guardian name, relationship, email (OTP route) | Contact deleted when the consent expires (24 h) or the child’s data is erased; name removed after the event purge | Hashed proof that a guardian consented |
| Photo matches | Which event photos a guest appears in | Deleted immediately on withdrawal; deleted with the event | None |
| Guest actions | Downloads, shares, favourites, selections | Deleted on withdrawal; a child’s downloads and shares are never recorded and a child is never counted in analytics | None |
| Face vectors | Face signatures from the studio’s own photos (never the selfie) | Deleted remote-first at the event purge date. A guest’s own matched faces stop resolving at once on withdrawal or erasure and are deleted at the provider by a retried job (re-queued hourly). The studio can delete an event’s whole face index and keep the photos | The studio’s photo purpose until purge |
| Face suppressions | Provider face ids and face boxes of an erased guest (no template, no image, no name) | Pending until the provider confirms the delete, then kept so a re-index of the same photo cannot bring the face back; deleted with the event | None |
| Event people | Event-local face clusters | Face-derived clusters deleted with the event or at the face-index purge; never shown to guests; not grouped or shown while the couple has withdrawn face features. People the studio or couple named keep their name (no faces, counts or cover) until the gallery itself is deleted | Names of people the studio or couple named |
| Registrations | Name, email, phone given before the photos were ready | Erased once told or at the purge date; never used for reminders to children. A guest’s erasure or export covers only sign-ups under an email proven to be theirs; the studio confirms any other | An empty count row |
| Guest links | Token hashes only | Revoked on withdrawal; deleted with the guest | History until the guest is purged |
| Messages sent | Phone number or email a message went to, status | Address emptied on withdrawal; children never receive reminders | Provider status without the address |
| Feedback | Guest rating and comment | Guest feedback deleted on withdrawal and at purge | The couple’s own feedback stays with the gallery |
| Video wishes | A guest’s recorded video | Video deleted first, then the row, at the purge date or on request | Until the event purpose ends |
| Couple galleries | The event photographs and films; the couple’s name and email on the gallery | Open for the studio’s validity period (12 months by default), which the couple can pay to extend; if not extended, the photographs, films, video wishes, download archives and face data are deleted after a grace period (90 days by default), with reminders first. The gallery record (names and dates), the names of people the studio or couple named, the album/category structure and the gallery design stay for reuse until the studio deletes the gallery | Galleries created before this rule, or that the studio keeps, are not deleted automatically; nothing is deleted while an extension payment is pending |
| Public portfolio | Public copies of photos the couple approved (no metadata); the couple’s per-photo decisions with typed name, notice hash, IP network and hashed browser; guardian consent references | Hidden at once when the couple or a guest in the photo withdraws, a guest is erased, a child is marked without a guardian’s consent or the gallery is archived; the public copy is deleted at once on the couple’s withdrawal, otherwise at the gallery’s next re-check | Decisions kept as proof of consent until the studio is deleted |
| Analytics | Aggregate gallery events (no identifiers) | No identifiers; no behavioural rows for children; 25 months | Aggregate only |
| CRM clients | Client contact and project details | Erased or corrected on request when no legal need remains | Contracts and legal claims |
| Enquiries | Lead name, phone, email, message | 12 months; spam 30 days | Dispute or legal hold |
| Proposals and contracts | Signer names, emails, IP, OTP evidence | Acceptance record kept for the period counsel sets (default 8 years) | Contract evidence, stamp duty, tax |
| Invoices and payments | Billing name, address, GSTIN, amounts | Kept 8 years from the end of the financial year (31 March); on erasure the email, phone and notes are removed | GST and tax law — the statutory exception to erasure |
| WhatsApp contacts | WhatsApp number, conversation window, adult declaration | Number scrubbed on erasure and the row deleted a day later; any other contact deleted 30 days after its last message; webhook receipts deleted after 30 days; message text in finished inbound jobs scrubbed after a day | Message compliance |
| Studio staff | Staff names, emails, sign-ins | Snabb is the fiduciary; deactivated or deleted on request subject to audit needs | Security and accounting |
| Studio notifications | A staff device’s push address and keys (encrypted), device name, browser kind, chosen notifications, last check-in; delivery log (no content) | Opt-in per device; push address erased at once when the device is removed or signed out, or its person leaves the studio or resets their password, and after 90 days unseen; removed devices deleted after 30 days; delivery log 30 days; minute counters 1 day | None |
| Audit log | Actor, action, IP (no content) | No content; IP cut to its network after 1 year | Security and legal defence |
| Rights requests | Requester name, email, request details | Pseudonymised 3 years after closure; event notes redacted after 3 years | Compliance evidence |
| One-time codes | Hashes of codes and addresses | Deleted 24 hours after creation | None |
| Replay signals | Keyed digest of selfie frames (never the image) | Removed after 1 hour (at the event's next search, and by the daily purge at the latest); never kept for children | None |
| Breach incidents | Incident facts, affected categories and estimates | Kept 6 years, then deleted whole | Compliance and security |
Your rights and how to use them
- Access (s.11): a summary of your data and how it is used. Guests can download their own data from their photos page at any time.
- Correction and erasure (s.12): correct, complete or update your data, or have it erased. Send the request with the form below (or write to the grievance officer); the studio acts on it and you get a reply.
- Withdraw consent (s.6(4)): use the same form, naming the event, or write to the grievance officer. Withdrawal stops the processing from then on.
- Grievance redressal (s.13): complain to the grievance officer below. If you are not satisfied, you may complain to the Data Protection Board of India.
- Nominate (s.14): name someone to exercise your rights if you die or cannot.
Use the form below. We check your email with a one-time code first, so no one else can make a request in your name. We aim to answer within 30 days; the Rules allow up to 90 days for grievances (r.14). You may be asked for more detail to find your records — for a guest, the event code and the email or phone you used.
Grievance officer and privacy contact
dhachina
Email: dhachina46@gmail.com
A studio may also show its own contact details on its event pages. Requests about an event are passed to that studio.
Where data is processed
Data may be processed outside India. Our database is hosted by Neon in Singapore, and some of the services below run in other countries. The Act allows this except to countries the Central Government restricts by notification (s.16; Rules r.15); we will stop any transfer to a restricted country. These services process data for Snabb:
| Service | Used for | Data | Location |
|---|---|---|---|
| Vercel | Application hosting and serverless functions | All request data in transit | Global edge; functions in the configured region |
| Neon | Postgres database | Studio, guest, consent and CRM records | Singapore (ap-southeast-1) |
| Cloudflare R2 | Private photo and video storage | Photographs, video wishes, watermark assets | Per bucket configuration |
| Resend | Transactional email | Recipient email, message content | United States |
| Razorpay | Payments | Payer details and payment references | India |
| Meta (WhatsApp Business) | WhatsApp messages and selfie channel | WhatsApp number, messages, selfie in transit | Global |
| Face service host | Face matching (AWS Rekognition or the self-hosted service) | Face vectors from studio photos; selfie in transit only | Per deployment region |
| Cloudinary (if retained) | Marketing-site images | Studio portfolio images | Global |
| Google (if OAuth sign-in is enabled) | Staff sign-in | Staff name and email | Global |
| Browser push services (if studio push is enabled) | Delivering studio notifications to staff devices (Google FCM, Apple, Mozilla, Microsoft) | Device push address; encrypted notification with an event type and dashboard link only | Global |
Security and personal data breaches
Photos are stored privately and shown only through short-lived signed links. Access is limited by role, every sensitive action is logged, one-time codes and tokens are stored only as hashes, and the consent record cannot be altered after it is written (s.8(5); Rules r.6).
If a breach affects your data, the responsible studio or Snabb will tell you without delay: what happened, the likely consequences, what is being done and what you can do. The Data Protection Board is told without delay, with a detailed report within 72 hours (s.8(6); Rules r.7). There is no automated Board interface; reports are made through the Board’s own channels.
Make a request
Changes to this notice are versioned; the consent notice you agreed to is recorded with its version. Template prepared for counsel review — not legal advice.