Privacy Policy

Privacy Policy

Effective date: 13 September 2026
Last updated: 13 September 2026

This Privacy Policy explains how [FULL LEGAL NAME OF THE OPERATOR] ("fotoclub.md", "we", "us" or "our") collects, uses, discloses and protects personal data when you use fotoclub.md, its temporary deployment at fotoclub.vercel.app, and related services (together, the "Service").

1. Who is responsible for your data?

The data controller is:

• Legal name: [FULL LEGAL NAME]
• Registration/ID number, if applicable: [NUMBER]
• Registered address: [FULL POSTAL ADDRESS, COUNTRY]
• Privacy contact: [PRIVACY EMAIL]
• Data Protection Officer or representative, if applicable: [NAME AND CONTACT, OR “NOT APPLICABLE”]

Please use the privacy contact above for questions or to exercise your rights.

2. Scope and nature of the Service

fotoclub.md is a public photography community. It enables members to create photographer profiles; upload and organize photographs; publish galleries, comments, forum posts and other materials; rate and save photographs; participate in contests; and publish or respond to events, photo trips, classes, recommendations and classified listings. It also publishes photography news and digests, including material collected from public sources, and offers optional AI-assisted features.

Most profile and community content is deliberately public. Public information may be viewed without an account, shared by other users, copied or indexed by search engines. Do not publish information or photographs that you want to keep private.

This Policy does not cover third-party websites, applications or social networks reached through links or sharing controls on the Service.

3. Personal data we process

Depending on how you use the Service, we process the following categories.

3.1 Account and authentication data

• username or display name;
• email address;
• password hash—we do not store your password in readable form;
• email-verification and password-reset records;
• account role, status, preferred language, membership level and timestamps;
• session and authentication identifiers; and
• if Google sign-in is enabled and you choose it, your Google account identifier, basic profile information made available under the requested permissions, and authentication tokens needed to maintain the connection.

An email address and authentication credential are required to create and secure an account. If you do not provide them, we cannot provide account features.

3.2 Profile and professional data

You may choose to publish your name, profile image, biography, date of birth, country, city, languages, honours, website, links or contact details for Facebook, Instagram, Telegram and WhatsApp, studio/on-location availability, services, prices, portfolio samples and other professional information.

Unless a field is clearly marked otherwise, information added to a photographer profile should be treated as public. A date of birth is used for account or community purposes and should not be displayed publicly unless the interface expressly says that it will be.

3.3 Photographs, metadata and other content

We process photographs and thumbnails, titles, descriptions, tags, gallery or series assignments, watermark choices and upload dates. During upload, the Service may extract and retain limited technical EXIF information such as camera and lens model, aperture, exposure time, ISO, focal length and original capture time. The current Service does not intentionally retain GPS coordinates as part of the displayed EXIF record.

Photographs may contain the image or other personal data of people other than the uploader. You must have an appropriate legal basis and any permissions required to upload and publicly display such material. If you appear in content uploaded by someone else and wish to raise a privacy concern, contact us at [PRIVACY EMAIL] and identify the relevant URL.

Free-text fields and images can reveal sensitive information—for example health, religion, political views, ethnicity, sexual orientation or intimate life. Do not upload sensitive personal data unless it is necessary, lawful and suitable for public display. We do not use facial recognition and do not intentionally create biometric identification profiles from photographs.

3.4 Community activity

We process ratings, favourites, votes, comments, comment translations, forum threads and posts, contest submissions and jury activity, event responses, reports, moderation actions, and related timestamps. Your username and the content of most contributions are public. Some activity, such as your own favourites or administrative records, may be visible only to you or authorized staff.

The names of signed-in members who were recently active may appear in the "online" area. Visitors who are not signed in are shown only as an aggregate guest count.

3.5 Events, trips, education, recommendations and listings

If you create or submit these materials, we may process titles, descriptions, dates, locations, organizer details, prices, contact information, registration links, images and your relationship to the listing. Classified advertisements may include a description, price, image and contact route. Information intentionally included in a published listing is public.

3.6 AI feature data

When a photo owner requests an AI critique, we send a thumbnail of that photo together with its title, description or photographer note and an instructional prompt to Anthropic's API. We store the returned critique, scores, language versions, model identifier and generation date. The critique may be viewed by the photo owner and by signed-in members who have rated that photo.

We may also use Anthropic's API to translate public profile or community text and to assist editors with collecting, summarizing, translating or drafting photography news, contests, events, trips, articles and digests. In those workflows, relevant source text, URLs or editorial prompts may be sent to Anthropic. Do not place private or unnecessary personal data in text submitted for translation or generation.

AI output is automated, may be inaccurate and is intended as creative or editorial assistance. It is not used to make decisions that produce legal or similarly significant effects about you. Community ratings are submitted by members, not generated by the AI critique.

3.7 Device, usage and security data

When you use the Service, our systems and hosting providers may process:

• IP address, request time, requested URL, referrer, browser and device information, and server or security logs;
• a salted one-way hash derived from the visitor IP address, used to count a photo view once per visitor without storing the raw IP in the photo-view record;
• a random browser identifier stored locally as fc_visitor_id, recent-activity timestamps and, while signed in, the associated account identifier, used to provide online-presence information;
• authentication cookies, anti-abuse or security signals; and
• a locally stored theme preference.

The Service does not currently use third-party advertising or behavioral-analytics cookies. If we introduce non-essential analytics, advertising pixels or similar tracking, we will update this Policy and request consent where the law requires it.

3.8 Communications

We process your email address and the contents and delivery status of account-verification, password-reset, service, moderation and privacy correspondence. We do not currently send promotional email unless you separately request or consent to it.

3.9 Information collected from public sources

Our editors and automated collection agents retrieve photography-related news, contests, events and trips from public websites, feeds and search results. We may retain the source URL, publication details, organizer or contact information contained in the source, summaries and review status. We use this material to produce attributed listings and editorial digests. If a listing contains your personal data and you want it corrected or removed, contact [PRIVACY EMAIL].

4. Why we process data and our legal bases

Where Moldovan data-protection law, the EU General Data Protection Regulation (GDPR), or similar law requires a legal basis, we rely on the following:

Where we rely on legitimate interests, we consider the purpose, necessity and impact on individuals. You may object as explained in section 10.

5. What is public

The Service is designed for public sharing. The following may be public: your username; profile and professional details you enter; profile image; photographs and their titles, descriptions, tags and selected EXIF data; galleries and series; ratings or aggregate statistics; comments; forum content; contest participation; event, trip or class listings; recommendations; classifieds; and other material you choose to publish.

Public pages may be indexed, cached, quoted or reshared by third parties. We can remove content from systems under our control, but we cannot guarantee deletion of copies previously made by search engines, archives, social networks or other people.

6. Cookies and local storage

The current Service uses only storage needed for the requested experience:

You can clear cookies and local storage through your browser. Clearing authentication data will sign you out; clearing fc_visitor_id will cause the browser to receive a new random identifier. Browser controls may not stop processing that is strictly necessary to deliver or secure the Service.

7. Who receives personal data

We disclose data only as needed for the purposes above:

• Vercel hosts and delivers the web application and processes request, network and deployment logs.
• [DATABASE PROVIDER] hosts the application database containing accounts, profiles, content and activity records.
• Cloudflare R2 stores public photographs and thumbnails. Public media objects can be fetched by anyone who has their URL.
• Resend processes email addresses, names and message delivery information for transactional email.
• Anthropic processes the content described in section 3.6 when AI features or editorial agents are used. Anthropic states that standard API inputs and outputs are deleted from its backend within 30 days, subject to contractual settings, safety enforcement and legal exceptions.
• Google, if Google sign-in is enabled and you choose it, processes the OAuth sign-in request under Google's own privacy terms.
• Telegram receives a digest when an administrator publishes it to the fotoclub.md channel. A digest normally contains editorial material, but it may include a public source, author credit or other public information selected for publication.
• Facebook, X and Pinterest receive the page URL, title and, where relevant, image URL only when you choose the corresponding share control. Their own policies then apply.
• External image hosts and linked websites may receive your IP address, browser information and referrer when the Service displays an image directly from their server or when you follow a link.
• Professional advisers, public authorities or transaction counterparties may receive information where reasonably necessary for legal compliance, claims, security, financing, reorganization or a transfer of the Service, subject to appropriate safeguards.

Our service providers act under their contracts and applicable data-protection obligations. We do not sell personal data and do not share it for cross-context behavioral advertising.

8. International transfers

Some providers, including Vercel, Cloudflare, Resend, Anthropic, Google and social-media services, may process data outside Moldova, Romania or the European Economic Area. Where transfer rules apply, we use an available lawful mechanism, such as an adequacy decision, standard contractual clauses or another recognized safeguard, and supplementary measures where appropriate.

You may request information about the safeguard relevant to your data by contacting [PRIVACY EMAIL]. Before publication, the operator must complete the transfer assessment and confirm the actual hosting regions and contractual safeguards.

9. How long we keep data

We keep personal data only for as long as needed for the purposes described, taking account of account status, community continuity, legal limitation periods, security, disputes and technical backup cycles. Current retention rules include:

• Account and profile: while the account is active, then anonymized or deleted as described below, except information required for legal or security purposes.
• Authentication: sessions remain until they expire or are revoked. Verification links are valid for 24 hours and password-reset links for 1 hour; used or replaced token records are deleted. Expired records may remain until routine database maintenance.
• Public contributions: until you delete them where self-service deletion is available, an administrator removes them, the parent item is deleted, or retention is no longer justified. Removed material may remain in restricted moderation records for security, dispute resolution or legal claims.
• Photographs and thumbnails: until the photograph is deleted. Deletion removes its database record and requests deletion of stored media; temporary, cached, failed-deletion or backup copies may remain for a limited period.
• AI critiques and translations: until the associated photo or content is deleted or we remove the generated record. Anthropic's separate API retention is described in section 7.
• Photo-view hashes: retained with the relevant photo and deleted when that photo's database record is deleted, unless earlier aggregated or removed.
• Recent-presence data and browser identifier: last-seen information is retained only while useful for presence and service operation; the identifier remains in your browser until cleared. [SET AND IMPLEMENT A FIXED SERVER-SIDE PRESENCE RETENTION PERIOD BEFORE PUBLICATION.]
• Server, security and email-delivery logs: according to the applicable provider configuration and for as long as reasonably needed for reliability, abuse prevention and investigation. [CONFIRM AND INSERT THE MAXIMUM PERIODS.]
• Backups: until overwritten according to our rolling backup schedule. [CONFIRM AND INSERT THE MAXIMUM BACKUP PERIOD.]

Account deletion

The current account-deletion process removes authentication connections and anonymizes the account by removing the email address, password and profile details and changing the public identity to a generic deleted-user label. To preserve coherent discussions and contest or gallery history, photographs, comments, forum posts, contest entries and similar contributions are not automatically erased merely because the account is closed.

Delete photographs or other eligible items before closing the account, or submit a separate erasure request. We will assess requests against your data-protection rights and any applicable freedom-of-expression, public-interest, security, legal-claim or record-keeping grounds.

10. Your data-protection rights

Subject to applicable law and exceptions, you may have the right to:

• receive transparent information about our processing;
• access your personal data and obtain a copy;
• correct inaccurate or incomplete data;
• request deletion;
• restrict processing;
• receive data you supplied in a structured, commonly used, machine-readable format and transmit it to another controller;
• object to processing based on legitimate interests, including direct marketing;
• withdraw consent at any time, without affecting earlier lawful processing; and
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

You can edit many profile fields and delete certain content in your account. For other requests, email [PRIVACY EMAIL] from the address associated with your account and describe the request. We may ask for information reasonably necessary to verify your identity. We will respond within the period required by applicable law. Requests are normally free, but the law may permit a reasonable fee or refusal for manifestly unfounded or excessive requests.

You may also complain to the National Center for Personal Data Protection of the Republic of Moldova (CNPDCP) at datepersonale.md or, if the GDPR applies, to the supervisory authority for your habitual residence, workplace or the place of the alleged infringement. In Romania, this is the ANSPDCP, available at dataprotection.ro.

We encourage you to contact us first so we can try to resolve the concern.

11. Children

The Service is intended for people aged 16 or older and is not directed to children. Do not create an account if you are under 16. If applicable law requires a higher minimum age, that higher age applies.

If you believe a child has provided personal data unlawfully, contact [PRIVACY EMAIL]. We will investigate and take appropriate action.

12. Security

We use technical and organizational measures intended to protect personal data, including hashed passwords, access controls, encrypted transport, role-based administration, restricted service credentials and security monitoring. No internet service is completely secure. Keep your password confidential, use a unique password and notify us promptly if you suspect unauthorized access.

Remember that photographs and other material published on fotoclub.md are public by design. Access controls that protect account data do not make public media private.

13. Third-party content and links

News, contests, events, trips, resources, partner placements and advertisements may link to independent third parties. Their sites may collect data, set cookies, require registration or apply different terms. We are not responsible for their privacy practices. Review their notices before supplying personal data or making a payment.

If we introduce advertising technology that tracks visitors or personalizes advertisements, we will identify the relevant partners, update this Policy and obtain consent where required.

14. Changes to this Policy

We may update this Policy as the Service, providers or law changes. We will post the new version with an updated date. If a change materially affects how we use personal data, we will provide a prominent notice and, where required, request consent before the change takes effect.

15. Contact

For privacy questions, rights requests or complaints:

[FULL LEGAL NAME OF THE OPERATOR]
[FULL POSTAL ADDRESS]
[PRIVACY EMAIL]
[OPTIONAL TELEPHONE]