Privacy Policy

Effective: 18 September 2026

This policy explains how MomentoSnap d.o.o. ("MomentoSnap", "we") processes personal data when you use a MomentoSnap outdoor photo booth, a MomentoSnap location gallery, or this website. It is written to meet the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the national data-protection laws of the countries where our booths operate.

1. Who is responsible (controller)

MomentoSnap d.o.o., Štrigova 99a, 40312 Štrigova, Croatia, OIB 76794616394. Contact for all privacy matters: info@momento-snap.com.

Where a booth is operated together with a local partner in your country, MomentoSnap remains the controller for your photos; the partner has no independent access to them.

2. What data we process

A photograph of you is personal data because you can be recognised in it. At the booth we process:

  • Your photo(s) - the image you take, and any AI background or filter version you choose.
  • Session data - time, booth location, number of prints, language chosen, whether you opted into the public gallery.
  • Payment - handled entirely by the card terminal provider (an independent controller). We never see or store your card number; we receive only confirmation that the payment succeeded and the amount.
  • Technical logs - booth health and error data that contains no photos.

3. Why we process it and on what legal basis

Taking, printing and delivering your photo (print + digital copy via QR code) - necessary to perform the service you requested (Art. 6(1)(b) GDPR).

Publishing your photo in a public location gallery on momento-snap.com - only with your explicit consent, given by ticking the box on the booth screen (Art. 6(1)(a)). You can withdraw it at any time (section 7).

Fraud prevention, safety and technical operation of unattended booths - our legitimate interest (Art. 6(1)(f)).

Website analytics and marketing cookies - only with your consent given in the cookie banner (Art. 6(1)(a); ePrivacy rules).

We do not use facial recognition, biometric identification, profiling or automated decision-making, and we never sell photos or data.

4. The booth is not video surveillance

The camera is activated only when you start a session and press the button. Nothing is recorded while the booth is idle, and preview frames shown on the screen are not stored. Only the photo you choose is saved.

5. How long we keep your data

Private photos (available only through your QR code) are deleted automatically 30 days after they were taken, or sooner where the notice on the booth states a shorter period.

Gallery photos you opted to share are removed from the public gallery and deleted 12 months after they were taken, or immediately when you ask us to remove them.

Session and technical logs are kept for up to 12 months in a form that does not include the photo. Payment records are kept as long as tax law requires, without any image.

6. Who receives your data

We use the following processors under GDPR Art. 28 contracts; none may use your photo for its own purposes:

  • DigitalOcean - cloud storage in Frankfurt, Germany (EU). Photos are stored encrypted and served only through short-lived signed links.
  • E-mail delivery provider - only if you ask for a photo by e-mail; the address is used for that delivery and not stored afterwards.
  • Card payment provider (independent controller) - processes your card payment under its own privacy notice.
  • Google and Meta - website analytics and advertising measurement, only if you accept those cookies. Some of these providers are established in the USA; transfers rely on the EU-US Data Privacy Framework or Standard Contractual Clauses.

7. Public galleries and other people in your photo

Sharing to the public gallery is optional and off by default. If you tick the box, the photo appears on the page for that location and can be seen by anyone. Please tick it only if every person in the photo agrees; you are responsible for obtaining their agreement. Photos of children should be shared only by a parent or guardian.

To withdraw consent and have a gallery photo removed, e-mail info@momento-snap.com with the location and approximate date and time, or a copy of the photo or its QR link. We remove it within 72 hours.

8. Children

The booth may be used by children only under adult supervision. Consent to public sharing must be given by an adult; where national law sets a digital-consent age (16 in Croatia, 14 in Austria, 13–16 elsewhere in the EU), we rely on the parent or guardian.

9. Your rights

You have the right to access, rectify and erase your data, to restrict or object to its processing, to data portability, and to withdraw consent at any time without affecting earlier processing. Because we do not store your name, please help us identify the photo: send the QR link, a copy of the photo, or the location plus date and time.

Write to info@momento-snap.com. We answer within one month. You may also lodge a complaint with your data-protection authority - in Croatia the Agencija za zaštitu osobnih podataka (AZOP), in Austria the Datenschutzbehörde, or the authority in your country of residence.

10. Security

Photos travel over encrypted connections and are stored in the EU. Access is limited to staff who need it to run the service, every access is logged, and photos on the booth itself are deleted as soon as they are uploaded. Should a data breach put your rights at risk, we will inform the supervisory authority within 72 hours and you without undue delay.

11. Cookies on this website

Strictly necessary cookies (your language and cookie choices) are always set. Analytics (Google Analytics) and marketing (Google Ads, Meta Pixel) cookies are set only after you accept them in the cookie banner. You can change your choice at any time via "Cookie settings" in the footer.

Independently of cookies, we measure how the site is used with Umami, an analytics tool we host ourselves. It sets no cookies and stores nothing on your device, does not keep your IP address, and produces only aggregate statistics - page views, clicks on buttons and links, scroll depth and form completions - that cannot identify you. We rely on our legitimate interest in understanding and improving the site (Art. 6(1)(f) GDPR).

12. Changes

We update this policy when the service or the law changes. The current version is always available at momento-snap.com/privacy-policy and, in short form, on every booth.