Legal
Privacy policy
Working draft, to be reviewed by a lawyer before going live. This page lists what the final text has to cover. It is not a valid privacy policy.
Face photos and sensitive data
A face photo used to build a model is sensitive personal data, and the markets we sell in do not all treat it the same way. We only handle it on your explicit consent, collected when you send the photos:
“I authorize JoyLamp to use my photos to model my figurine, and I confirm I hold the rights to the images I send.”
Your photos are only used to make your figurine. They're never resold and never used to train a model, and you can ask us to delete them at any time.
A photo of a protected character (film, game, comic) can't be made: we decline the order and refund you.
The final text has to give the legal basis, the exact retention period for photos and for renders, and how you withdraw consent, including for photos of children, where a parent or guardian gives it. TODO: a lawyer has to say which of our markets classifies these photos as biometric data and which does not, because that answer decides what consent we have to collect.
What we collect
Your contact and order details, and the photos you send (faces, often children's) used only to model the figurine.
Why we are allowed to
Which legal basis covers each use: performing your order for most of it, explicit consent where consent is what is required, in particular for photos of children. TODO: name the regime that applies in each market: it is not the same one for a European customer and a US one.
How long we keep it
How long each item is kept: the photos you send, the renders you approved, print files, order records. The final text has to give a concrete duration for each one.
Who else touches it
The providers involved: the ones we use to build the 3D model, cloud storage, and payment. The final text has to name them one by one, with what each one does.
Sending data abroad
Print files go to manufacturing partners in other countries. TODO: name the safeguard each market's regime requires before data crosses a border, and list the countries involved.
Your rights, and deleting your photos
Access, correction, deletion and the other rights your market gives you, including how to get your photos deleted: write to contact@joylamp.com. The final text has to give a response time. TODO: name the authority you can escalate to in each market.
Cookies
What the site keeps on your device, and what it is for. A consent banner goes up before any audience-measurement tool is connected.
The other working drafts: legal notice, terms of sale, cookie policy and shipping and returns.