123 Cheese Studio — Privacy Policy
Effective 23 August 2026. This Policy explains how Intaglo, Inc. handles portrait and account-related information for customers in the United States, United Kingdom, Australia, Canada, and New Zealand.
Your photos, your subject
Every face and full-body reference must show the same person. The uploader must be that person or an authorised adult family organiser. We do not permit another person's body photo, scraped images, unauthorised stock photos, or public-figure images without documented express authority as references.
Controller and privacy contact
Intaglo, Inc. · Delaware, United States
Privacy contact email must be configured before production launch.
Privacy mailing address must be configured before production launch.
1. Scope and controller
This Policy applies to 123 Cheese Studio family portraits, VIP Solo Profiles, remote family uploads, previews, paid unlocks, support, rights complaints, abuse prevention, and related websites. Intaglo, Inc., a Delaware corporation, is the controller or business responsible for personal information unless a specific notice says otherwise. This Policy is designed as a common baseline for customers in the United States, United Kingdom, Australia, Canada, and New Zealand; additional state, provincial, or national rights continue to apply.
2. Same-person photo rule
For each portrait subject, the face photo and full-body photo must depict that same person. We do not permit another person's body to be used as a shape reference. The uploader must be the person pictured or an adult who has that person's express authority. A parent or lawful guardian must authorise processing for a minor. Internet, scraped, stock-model, or otherwise unauthorised images are prohibited. Images of celebrities, entertainers, athletes, influencers, royals, public officials, candidates, politicians, or other recognisable public figures are prohibited without documented express authority from the person and all necessary copyright owners.
3. Information we collect
Depending on the feature, we process names or labels, family role, user-selected visual presentation, confirmed height, face and full-body reference images, optional venue images, theme, wardrobe, gaze and pose choices, generated portraits and quality reports, random session and member identifiers, timestamps, device or diagnostic data, support communications, and locally stored preferences. Our V1 checkout database does not store a customer name, email address, telephone number, postal address, full card number, IP address, or browser user-agent. It stores only a random order identifier, random session identifier, purchased entitlement code, amount, currency, payment status, provider transaction identifiers, terms version, and payment timestamps. Stripe or PayPal separately processes the payer information required to complete the payment.
4. Where information comes from
We receive information directly from the person using the service, from an authorised family organiser, from a parent or lawful guardian, from a family member using a remote-upload link, and automatically from the browser or server during operation. If an organiser provides another person's information, the organiser must give that person this Policy and obtain the required authority before upload.
5. Why we use information
We use personal information to create and deliver requested portraits; match face and body references; apply height and presentation choices; review input and output quality; detect public-figure, impersonation, false-association, political-manipulation, fraud, abuse, and unsafe-content risks; operate sessions and remote uploads; process payment and discounts; investigate rights complaints; provide support; secure and debug the service; keep transaction and consent evidence; comply with law; and establish, exercise, or defend legal claims. We do not use customer reference photos to train our own general-purpose AI model.
6. Legal bases for UK customers
For UK GDPR purposes, contract is the primary basis for processing needed to provide the requested service. Consent is used where processing is optional or where special-category biometric processing requires explicit consent. Legitimate interests may support proportionate security, fraud prevention, quality assurance, service diagnostics, and legal claims after balancing the person's rights. Legal obligation supports tax, accounting, regulatory, and lawful-request records. Consent may be withdrawn for future processing, but withdrawal does not invalidate earlier lawful processing or records we must retain.
7. Facial, body, and biometric information
A photograph is personal information when a person is identifiable. Technical analysis of facial or bodily characteristics may also be biometric information, and may be sensitive or special-category information when used or intended for unique identification under applicable law. Our quality review may compare whether two submitted photos appear to show the same person and whether a generated portrait follows the requested identity constraints. We do not use this analysis for access control, credit, employment, insurance, health diagnosis, or government identification.
8. AI processors and other recipients
Reference images and instructions may be sent to OpenAI for portrait generation. Reference images, generated candidates, and identity constraints may be sent to Google Gemini for independent quality review. Supabase provides PostgreSQL records and private object storage and, only for account features when enabled, authentication. Stripe and PayPal process checkout, refunds, and related fraud signals; the Studio does not receive or store full card numbers and does not copy payer contact details into its V1 checkout database. Hosting, security, analytics, email, or support providers may process the minimum information needed for their services when enabled. We may disclose information to professional advisers, courts, regulators, law enforcement, transaction counterparties, or another entity involved in a corporate reorganisation when legally permitted and appropriately protected.
9. International transfers
Intaglo is based in the United States, and providers may process information in the United States and other countries. Those countries may have different privacy laws. Where UK law requires a transfer mechanism, we rely on an adequacy regulation, the UK International Data Transfer Agreement or Addendum, or another lawful safeguard. For Australia and Canada, we remain accountable as required for information handled by overseas processors and provide notice of likely overseas processing. Where New Zealand Privacy Act 2020 Information Privacy Principle 12 applies to a disclosure, we use a recipient subject to the Act or comparable safeguards, an appropriate contractual safeguard, another permitted basis, or express informed authorisation as the law requires. Provider locations can change and are governed by the applicable provider contract and transfer documentation.
10. Retention and deletion
Active render input packages are encrypted in transit and held in private object storage only while a render or one permitted recovery attempt is pending; completed-job inputs are deleted. Temporary memory buffers may remain for up to 30 minutes. A V1 family event invitation normally remains open for seven days unless the host closes, extends, or completes it sooner. Remote face and full-body uploads share that invitation deadline. After a family portrait is successfully generated, those remote source files are scheduled for deletion after 24 hours; because free-tier cleanup runs periodically, final removal may occur during the next scheduled cleanup after that time. Paid, quality-approved portraits are retained in the customer's private Family Space for 30 days by default, after which they are deleted unless a different retention choice is expressly offered and selected. Browser local storage may retain session members, images, preferences, and solo subjects on the user's device until the user clears site data or the application removes them. Payment, transaction, terms-acceptance, authority, fraud, safety, rights-complaint, security, and legal records are retained only as long as reasonably necessary under tax, accounting, contract, limitation, dispute, evidence-preservation, and regulatory requirements, then deleted or de-identified. A complaint or lawful preservation duty may require restricted preservation while the matter is investigated. AI providers may retain data under their applicable service and data-processing terms.
11. Security
We use measures appropriate to the sensitivity and context of the information, including passwordless account authentication, row-level database access controls, private storage, signed or unguessable invitation credentials, payment-webhook signature verification, idempotent payment-event handling, limited-purpose processing, validation, provider controls, and fail-closed quality and abuse checks. No network or storage method is completely secure. If a breach creates a legally reportable risk, we will notify affected people and regulators as required by applicable US, UK, Australian, Canadian, and New Zealand law.
12. No sale or behavioural advertising
We do not sell customer reference photos, body data, height, generated portraits, or biometric information. We do not share those items for cross-context behavioural advertising or targeted advertising. If our practices change, we will update this Policy and provide any notice, consent, opt-out, or limit-use mechanism required before the new practice begins.
13. Children
The service is for adults. Children may be included in a family portrait only through a parent or lawful guardian. We do not knowingly collect a child's images directly from a child. Where the US Children's Online Privacy Protection Act applies, verifiable parental consent is required before covered online collection. UK, Australian, Canadian, New Zealand, provincial, and state child-privacy requirements may impose additional age and consent rules. Contact us to request deletion of a child's information submitted without proper authority.
14. Your privacy rights
Subject to applicable exceptions, you may ask to access, correct, delete, restrict, or obtain a copy of your information; object to certain processing; withdraw consent for future processing; or complain. UK users may also have portability rights and may complain to the ICO. Australian users may request access and correction and complain to the OAIC after contacting us. Canadian users may request access and correction, challenge compliance, and complain to the OPC or an applicable provincial commissioner. New Zealand users may request access and correction and complain to the Office of the Privacy Commissioner. Residents of California and other covered US states may have rights to know, access, correct, delete, obtain a portable copy, opt out of covered sale, sharing, targeted advertising or profiling, limit certain sensitive-information uses, and appeal a refusal. We do not discriminate against anyone for exercising a privacy right.
15. Automated review
Automated quality and abuse review can block, retry, or withhold a portrait when inputs may depict different people, an image is unclear, person count or requested presentation appears wrong, identity similarity is insufficient, visible defects are detected, or the request may involve an unauthorised public figure, impersonation, false endorsement, political manipulation, or prohibited content. This decision protects subjects, rights holders, users, and the service and does not determine legal identity or produce a similarly significant decision about employment, credit, housing, insurance, education, health, or public benefits. A user may provide authorised, clearer references or contact the Studio for review; we may require evidence of authority.
16. Requests, verification, and authorised agents
Submit a request through the current privacy contact displayed on this page. We may verify the requester using information already associated with the session and may ask for additional information only when reasonably necessary. An authorised agent may submit a request where local law permits, but we may require proof of authority and direct identity confirmation. We aim to respond within the period required by the applicable law and will explain any lawful extension or refusal.
17. Complaints and regulators
Please contact our privacy lead first so we can investigate. A person whose image was submitted without authority may also request access restriction, deletion where available, and preservation of relevant complaint evidence. If unresolved, you may contact the UK Information Commissioner's Office, the Office of the Australian Information Commissioner, the Office of the Privacy Commissioner of Canada or an applicable provincial commissioner, the New Zealand Office of the Privacy Commissioner, the California Privacy Protection Agency, a US state attorney general or privacy authority, or the US Federal Trade Commission, depending on where you live and which law applies.
18. Changes and contact
We will update the version and effective date when this Policy changes. Material changes affecting existing information will receive additional notice or consent where required. The operator is Intaglo, Inc., Delaware, United States. The monitored privacy email and mailing address configured by the operator are displayed at the top of this page. These contact details must be published before production launch.
Privacy regulators
This Policy is a common baseline and does not replace market-specific legal review. Intaglo must publish a monitored privacy contact and complete processor, transfer, retention, and child-consent reviews before production launch.