Privacy notice of R Fotografie
1. Who is responsible
R Fotografie (the sole proprietorship of Rolf Kühr, Dutch Chamber of Commerce number 81531567, Rode Ring 49 N, 1566 HR Assendelft, the Netherlands) is the controller for the processing described here. R Fotografie works with Romy van Leeuwen Fotografie (sole proprietorship, Dutch Chamber of Commerce number 66388031, based in Uitgeest) when carrying out assignments. She processes personal data under R Fotografie’s responsibility. You can submit privacy requests through our contact page.
R Fotografie has not appointed a data protection officer; one is not legally required for an operation of this size.
2. Data, purposes and legal bases
2.1 Website enquiries
| Data | Purpose | Legal basis |
|---|---|---|
| Name, email address, selected service, your wedding or shoot date (including an approximate date), and your message | Reply to your enquiry, check availability and make a proposal | Steps taken at your request before entering a contract (GDPR Article 6(1)(b)) |
The form runs through our server. It first saves your enquiry in a directory inaccessible from the internet, then sends two emails: one to us and a confirmation to you. In August 2026, we found that email delivery could fail silently and an enquiry could be lost. We delete the saved file once the enquiry has been handled, and in any event within six months. If it leads to a booking, the client file retention period in section 4 applies.
If a submission is rejected by the form check, for example because a password manager filled a hidden field, it is saved separately instead of discarded, with the same data and a maximum six month retention period. A rejection can be mistaken; retaining it lets us still reach you. The legal basis is legitimate interests (GDPR Article 6(1)(f)).
To prevent automated misuse, the server counts submissions from an address for up to one hour. It does not retain your IP address: it converts it to an irreversible code, kept separately from the information you entered and then automatically deleted. The legal basis is legitimate interests (GDPR Article 6(1)(f)).
2.2 Booking and performance
When an enquiry leads to a booking, we process the data needed for the contract: contact and billing details, the date and location of the photography assignment, and our agreed arrangements. The legal bases are performance of the contract (GDPR Article 6(1)(b)) and, for basic invoice and payment information, a legal obligation (Article 6(1)(c)).
2.3 Photographs
We take and edit photographs of you and your guests to perform the assignment (GDPR Article 6(1)(b)). We use images in our portfolio, on social media, in trade publications or in presentations for suppliers only with your consent for each specific purpose (Article 6(1)(a)).
We ask for consent when you book. In the proposal or booking confirmation, you can agree to each use separately. You may also agree by email, WhatsApp or verbally; we then record that agreement with your booking. Silence is never consent. If you do not respond, we publish nothing.
Refusal does not affect the price, scheduling or delivery. You may withdraw consent for future use at any time, free of charge, via the contact page. We will remove existing publications within 30 days where reasonably possible. We select carefully where several people appear in an image; in case of doubt we do not publish it. For identifiable images of children, we ask a parent or guardian for consent.
2.4 Client gallery
Your gallery is accessible only through a personal invitation. We process your name and email address for the invitation and access control, and download and access activity for security. The legal bases are performance of the contract and legitimate interests (security). We built the gallery ourselves and manage it on a one.com VPS in Germany. One.com provides the hosting infrastructure and is listed as a processor in section 3. We do not use an external gallery platform.
2.5 Withdrawal form
If you use the withdrawal form, we process the details you enter: your name, postal address, email address, the service concerned, the order date, any date of receipt, and any explanation. We need these to handle your withdrawal and document its receipt. The legal bases are legal obligation (GDPR Article 6(1)(c), as the law provides the withdrawal right and duty to acknowledge receipt) and performance of the contract (Article 6(1)(b)).
This form also passes through our server, but we do not store its contents there. The server turns them into two emails, one to us and one confirming receipt to you, and retains nothing further. The email retention period in section 4 applies.
To prevent automated misuse, the server counts submissions from an address for up to one hour. It does not retain your IP address, but converts it to an irreversible code that is separate from the form data and disappears automatically. The legal basis is legitimate interests (GDPR Article 6(1)(f)), namely keeping a form for exercising a legal right available.
2.6 Visitor statistics without personal data
Since 1 August 2026, we have counted visits using Umami on our own server in Germany. It sets no cookies, retains no IP addresses and builds no profiles. We see only aggregate numbers by page, country and referring website, plus counts of actions such as successful contact form submissions and telephone clicks. These counts are not linked to a person or a message. As no personal data is processed, neither a legal basis nor consent is required. See our cookie policy.
2.7 What we do not do
- No advertising or marketing tracking, third-party pixels, or analytics traceable to individuals.
- No sale or rental of personal data.
- No automated decisions with legal effects and no profiling.
- No public self-registration for galleries.
3. Recipients and processors
We share data only with parties necessary to provide our services. Their processing role, storage region and transfer mechanism are recorded in our processor register. Main parties:
| Party | Role | Region / transfer |
|---|---|---|
| Hostinger International | Marketing website hosting | Storage in Frankfurt, Germany, within the EU; the company is based in Lithuania |
| one.com | VPS hosting the client gallery and Umami visitor counter | Storage in Germany, within the EU; the company is based in Denmark |
| Cloudflare | DNS and domain registration | United States; EU–US Data Privacy Framework and standard contractual clauses |
| Apple (iCloud Mail) | Ireland / United States; Data Privacy Framework | |
| Resend (Plus Five Five, Inc.) | Emails carrying your enquiry to us and its confirmation to you | United States; EU–US Data Privacy Framework and standard contractual clauses (SCCs) |
| Encrypted backup service (being set up) | Recovery | Will be recorded before activation |
| Mollie (only in phase 3) | iDEAL deposits | Netherlands; R Fotografie never stores payment details itself |
Processing for assignments in Italy takes place within the EU/EEA. There are no transfers to Italian third parties beyond venue and supplier arrangements you make yourself.
4. Retention periods
- Enquiry without a booking: its email is deleted from our mailbox no later than 12 months after the enquiry. The server file described in section 2.1 is removed once the enquiry is handled, and in any event within six months.
- Client file, contract and basic invoice data: seven years after the financial year, under the tax retention obligation.
- Other correspondence and shoot details: two years after delivery.
- Gallery: for weddings, six months online with Basis and 12 months with Favoriet and Luxe, counted from delivery; then the gallery goes offline and the images are removed. We extend it only at your request. These periods also appear in Terms Article 10(3).
- Backup copy: we keep a copy for two years after delivery so you can ask for images again if you lose them; it is then deleted.
- Withdrawal: the form data is not stored on the server. Its email is kept for seven years after the financial year with the client file, as withdrawal affects the contract and invoicing. The abuse prevention code described in section 2.5 disappears within an hour.
5. Security
We use suitable technical and organisational measures, including encrypted connections (TLS with HSTS), limited access on a least privilege basis with two factor authentication on all administrator accounts, and separate setups for the gallery and payments. The client gallery also requires both a password and a PIN. You choose which images to share with guests.
6. Your rights
You have rights of access, rectification, erasure, restriction, data portability and objection. Where consent is the legal basis, you may withdraw it for future use. Send a request through the contact page; we respond within one month. You may also complain to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).
7. Changes
We may amend this notice. The current version, number and date appear on our website. For bookings, we record which version applied at the time.