Last updated: 28 September 2026
This notice explains how we handle the personal data of visitors, early-access subscribers and photographers using SmartCull. For the photos photographers upload, the photographer is the data controller and we are their processor — see our Data Processing Agreement.
SmartCull is the UK service of Fotóválogató. Data controller: Foroszán Pál Márk ev., sole trader (egyéni vállalkozó) registered in Hungary, registration no. 62853549, MAGYARORSZÁG, 5700 GYULA, SZÖNYI KÖZ 1., EU VAT number HU91145804, email hello@fotovalogato.hu.
| Data | Purpose | Legal basis | Kept for |
|---|---|---|---|
| Early access: name, email, business name (optional), sessions per year (optional) | Sending your invitation and occasional launch news; understanding demand | Your consent (UK GDPR / EU GDPR Art. 6(1)(a)) | Until you unsubscribe, or at most 24 months after the UK launch |
| Account: name, email, password (hashed), photographer details you enter | Providing the service, login, contacting you | Contract (Art. 6(1)(b)) | While your account exists |
| Credit, sessions and purchase records | Billing and accounting | Contract; legal obligation (Art. 6(1)(c)) | 8 years (Hungarian accounting law) |
| Consent records, IP address, technical logs | Proof of consent, security, preventing abuse | Legitimate interest (Art. 6(1)(f)) | Up to 90 days (logs); as long as the consent (consent records) |
We do not sell your data. No tracking cookies are used on smartcull.uk; a session cookie is set only when you log in.
Rackforest Kft., Budapest (hosting — all data is stored on our server in Hungary, EU); Paddle.com (our reseller and Merchant of Record — processes payments and receives the data needed for your order under its own privacy notice); Google LLC (our support mailbox is forwarded to Gmail). The UK recognises the EU/EEA as providing adequate protection.
You can access, correct, delete and port your data, object to processing and withdraw consent at any time (every email has a one-click unsubscribe link). You can complain to the UK Information Commissioner's Office (ico.org.uk) or the Hungarian authority (NAIH, naih.hu).