Privacy policy

eLash Solutions OG, Bauernstraße 6, 2514 Traiskirchen, Austria, is the controller for everything described here: for this website and for the Designey app. For access, rectification, erasure, or any other request under the GDPR, write to office@designey.ai. There is no form to fill in. An informal email is enough, and a person answers it.

The page you are reading informs you about Designey and processes very little itself. Our host keeps short-lived server logs (IP address, timestamp, requested page) to keep the site up and to stop abuse; the legal basis is Art. 6(1)(f) GDPR, and they are deleted after 14 days at the latest. Two strictly necessary cookies come with it: one stores your language choice (German/English), the other your answer to the cookie banner, so we do not ask you again on every page. Neither needs consent (§ 165(3) TKG 2021). Fonts are self-hosted.

Google Analytics. To measure how this website is used, we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, USA). Google Analytics sets cookies and processes your truncated IP address, the pages you visit, how long you stay and technical device data, so we can see how the site is used. Data may be transferred to Google LLC servers in the United States; Google LLC is certified under the EU-US Data Privacy Framework. Google Analytics runs only if you consent via the cookie banner (Art. 6(1)(a) GDPR, § 165(3) TKG 2021); without consent it is not loaded at all. You can withdraw your consent at any time in the cookie settings, with effect for the future. Analytics data is deleted after 14 months at the latest.

Your room photo and your room size. Uploaded without an account, and with your agreement to the AI processing (section 4): the upload form asks for it, and without it no room is created and no photo is kept. The photo is re-encoded the moment it arrives, which removes the metadata your camera attached to it, meaning location, device and timestamp. It is stored in a private bucket in Frankfurt that is not reachable from the public internet. The room size is one you type in yourself or confirm after we estimate it from the photo. When you replace a single piece of furniture you upload a photo of that piece where it stands; it is treated like a room photo. Legal basis: Art. 6(1)(b) GDPR, because it is the service you asked for. The agreement to send it onward is recorded against the room, with the exact wording you agreed to and the date.

Your account. When you render for the first time you sign in: with a code we email you, with your Google account, or in the iOS app with your Apple account. With Google and Apple our sign-in service (section 5) checks the token Google or Apple issues and stores what it contains: with Google, your name and profile picture beside the email address. We ourselves take your verified email address from it and, with Apple, also the user ID under which Apple knows you to us, so that you reach the same account even if your address at Apple changes or the app moves to another Apple developer account; it is deleted with your account. The record at the sign-in service goes with your account. Google or Apple learns that you are signing in to Designey; what they do with that is governed by their own privacy policies. From then we keep your email address, the moment you verified it, the country the app shows products and prices for, the products you save, a copy of the transfer agreement your room carries (section 4) with any withdrawal of it, and a render ledger: one dated row per successful picture, so any free pictures and any credits you bought can be counted down. The ledger records that you rendered, never what. We also keep your address in the one form described in section 6, and when an account is opened we compare its address in that form with those of the existing accounts: if one matches, the new account starts without the free pictures. The country is set first from the country of your connection, which our host reads from the IP address, and after that from your choice on the account page. In our database there is no name, no profile, no advertising identifier, and no record of what you looked at; only what you mark yourself is saved.

Notifications and purchases. If you allow notifications, the app fetches a push token from your device and we store it with your account, to tell you when a picture is ready. The message goes from our server to Expo's push service (650 Industries, Inc., USA) and from there to Apple or Google, who deliver it to your device. It contains the note that your picture is ready, the name of the style and the identifier of the room, never the picture itself. Legal basis is Art. 6(1)(a) GDPR: the permission your device asks you for, which you can take back in its settings at any time. A token that can no longer be reached we delete on our own, and all of them go with the account. You buy credits in the app through the App Store or Google Play (section 5).

The beta waitlist. If you ask to hear when custom design, the door that measures your room from a video, opens, we store your email address and the moment you asked, and nothing else. That moment is the record of your agreement. Legal basis: Art. 6(1)(a) GDPR, your consent, given by typing the address into a field whose one stated purpose sits beside it; § 174 TKG 2021 covers sending the message. We will write to you exactly once, when the beta opens. There is no newsletter, nothing else is sent, and the address is not joined to anything else we hold. A waitlist entry is not an account, and signing up does not create one.

How your account starts. We are testing which start works better for new accounts: with free pictures, or without them, so that a purchase is needed before the first picture. When your account is created, we draw at random which of these start variants it begins with, and we store the variant drawn and the country you signed up from with your account. Our host tells us the country from your IP address; we keep only the country code. What share of new accounts gets which variant is set per country. The draw is random and is not based on a profile or on anything else about you. A second account whose address, in the one form described in section 6, matches that of an existing account gets no draw of its own but the first account's variant, and accounts created before the test began stay in the variant with free pictures. We pass the variant to RevenueCat (section 5) as a subscriber attribute, to compare purchases between the variants. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in finding out which start works better. The variant and the country are kept as long as your account exists.

Server logs. Our host keeps short-lived request logs (IP address, time, requested path) to keep the service up and to stop abuse. Legal basis: Art. 6(1)(f), our legitimate interest in operating a working, un-abused service.

Crash reports. When something fails on our server, we record the error, the technical trace of where it happened, the requested path, and, if you are signed in, your internal account number. Not your email address, not your photo, and no link to it. Legal basis: Art. 6(1)(f), our legitimate interest in a service that works, and in hearing about it when it doesn't rather than waiting to be told. We do not ask you for this one: an error report puts nothing on your device.

Two things are done with your room photo by AI models operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and by OpenAI Ireland Limited, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, whose models run in the United States: the visualization of a concept in your own room is produced from it, and the room is read (its colours, its materials, how bright it is, and which pieces of furniture it already has) to match products to it, so what we suggest suits the room you actually have.

The reading is done from the photo, and for a room you describe by voice also from your room wish. The picture needs more, so with your re-encoded room photo we send a floor plan of the room, which we draw from the room size you gave us and which shows where each product is to stand, the product images, and one line of text per product. The room size is written into the instructions as well, so the picture keeps the proportions of the room you measured. Your budget is not sent: it decides which pieces of our own catalogue you are offered, and that happens here. We do not send your email address, your account identifier, or anything else that names you. Google keeps what it receives and what it sends back for up to 55 days, to detect misuse and for disclosures the law requires. OpenAI keeps both for up to 30 days to detect misuse, and longer only where the law requires it or where that is reasonably necessary to protect its services or others from harm.

These transfers do not come with the usual EU safeguards. We rest neither transfer on standard contractual clauses under Art. 46 GDPR nor on processor guarantees of the kind that cover our other providers. US authorities can, under US law, demand access to data held there, and enforcing your rights against a US company is harder than against an Austrian one.

Because of that, the transfer runs on your explicit consent under Art. 49(1)(a) GDPR. We ask for it on the upload form, before your photo is sent anywhere at all, on a box you have to tick yourself, covering both of the things above and both providers. It is asked once per room, because it is the room's photo that gets sent, and we record the exact wording you agreed to alongside it. If what we use your photo for ever changes, we ask again.

If you do not agree, we cannot take your room any further. Nothing is sent, nothing is stored, and no room is created. There is also no concept, no plan and no shopping list, because all of them start from the photo. We would rather say that plainly here than let you find it out at the end.

You can withdraw at any time, from your account page in one tap, or by emailing office@designey.ai. After that we send nothing further about the rooms you already have. Withdrawal does not undo renders already made (Art. 7(3)); deleting your account does, and takes the photos with it. A new room asks the question again, and a fresh agreement stands on its own.

Every render is labelled as an AI visualization in the app, and images made by Google also carry Google's invisible SynthID watermark.

A room video goes to the United States too, but not to Google or OpenAI. If you have a 3D preview made from a finished picture, we send that picture, and only that, to fal (Features and Labels, Inc., 2261 Market Street, San Francisco, USA), where a video model turns it into a short camera move. Your photo does not go with it, but a picture that shows your room does. Unlike the transfer above, the usual safeguards apply here: fal processes on our behalf under Art. 28 GDPR, under EU standard contractual clauses under Art. 46 GDPR, and we collect the finished video and store it in our Frankfurt storage, next to the picture it came from. So we do not ask separately for this; the legal basis is Art. 6(1)(b) GDPR, because you request the video, and what it costs in credits is on the button before you press it.

These companies touch your data in the running of the service. They process it on our behalf under Art. 28 GDPR, on our instructions only, and never for their own purposes. Purchases in the app are sold by Apple through the App Store and by Google through Google Play, which also take the payment. The purchase details we need to credit your account reach us through RevenueCat.

• Supabase, Inc. (USA): Database, private file storage and the sign-in service, which also checks sign-ins through Google and Apple. The project runs in the EU region eu-central-1 (Frankfurt, Germany); room photos, pictures and videos are stored there and nowhere else. Standard data protection agreement including EU standard contractual clauses.
• Vercel, Inc. (USA): Hosting for the server the app talks to. Server functions are pinned to the fra1 region (Frankfurt, Germany). Vercel keeps short-lived request logs for operational security. Standard data protection agreement including EU standard contractual clauses.
• Resend, Inc. (USA): Delivers the emails this service sends: the sign-in emails that carry your 6-digit code, and the single message to the beta waitlist when custom design opens. For those, it receives your email address and the message itself, and nothing else. When you report one of your pictures in the app, Resend also delivers that report to us: your internal account number, the reason you chose, the note if you wrote one, the identifiers of the room, the picture and the report, and the time you reported it. We do not add your account email address or attach the picture.
• Functional Software, Inc. d/b/a Sentry (USA): Error tracking. When something fails on our server, Sentry receives the error, its stack trace, the requested path and, if you were signed in, your internal account number, which is a random identifier and not your email address. Reports are stored in Sentry's EU region (Frankfurt, Germany). Standard data protection agreement including EU standard contractual clauses.
• Stripe Payments Europe, Limited (Ireland): processed the payments for the purchases the website used to offer, and keeps their invoices and customer records (section 6); no new payments go through Stripe.
• Google: receives your room photo, with its size and your room wish, for reading and rendering only with your explicit consent (section 4), writes down a room wish you speak (we do not store the recording; Google keeps it for up to 55 days to detect misuse and for disclosures the law requires), checks your account when you sign in with Google (section 3), and runs the audience measurement on this website (section 2, Google Analytics, consent only).
• OpenAI: receives your room photo, with its size and your room wish, for reading and rendering only with your explicit consent (section 4).
• fal (Features and Labels, Inc., USA): makes the room video from a finished picture (section 4). Receives that one picture and nothing else that names you. Standard data protection agreement including EU standard contractual clauses.
• Expo (650 Industries, Inc., USA): delivers the mobile app's notifications (section 3). Receives your device's push token and the text of the message, and passes both on to Apple or Google. Certified under the EU-US Data Privacy Framework.
• Apple Inc. and Google LLC (USA): bring the notification to your device, Google on Android through Firebase Cloud Messaging, and handle the purchases in the mobile app, Apple through the App Store, Google through Google Play Billing. What they store in doing so is governed by their own privacy policies; we receive no payment details from them. Both are certified under the EU-US Data Privacy Framework.
• RevenueCat, Inc. (USA): matches the purchases in the app to your account. Receives your email address as the customer identifier, the store's purchase receipts and your account's start variant (section 3), so the credits land with you and the app knows your plan. Standard data protection agreement including EU standard contractual clauses.

Partner links. We do not sell data, and we pass nothing to advertisers. The products in the app come from our partner retailer's range, and a product link leads through the retailer's partner programme into its shop. For XXXLutz that is pvn.xxxlutz.at, run by XXXLutz KG, Römerstraße 39, 4600 Wels, Austria, with EASY Marketing GmbH, Dortmund, Germany, as its technical provider. When you click, the programme sets two cookies in the retailer's shop (TRS and TRSCJ) that attribute a later purchase to Designey. They mark the partnership, not you, and nothing about you travels from us with them. All we learn from them is that a purchase happened, its value and our commission, never who bought. The retailer is responsible for this tracking; you can object to it at pvn.xxxlutz.at/privacy-optout.do, and what you do in its shop is covered by its privacy policy, not this one.

Room photos, pictures and videos: 12 months of inactivity. They are kept while you are using the service, and deleted after 12 months in which you have neither uploaded a room nor made a render. Because we keep no record of your visits, simply signing in or reopening an old render does not count. If you want to keep a photo, make something with it. A photo uploaded without ever signing in is deleted 12 months after upload. This runs automatically, every night. A video hangs on its picture and goes with it.

Account data (email, verification date, country, start variant and sign-up country, saved products, in the mobile app the push tokens of your devices, your copy of the transfer agreement and any withdrawal of it, and the render ledger) is kept while your account exists. Each room's own consent record is part of that room, so it is deleted whenever the room is, either by the purge above or by deleting your account.

What a purchase leaves behind (that a pack or a plan was bought under your address, the store's identifier or, for an earlier purchase on the website, Stripe's customer, payment and invoice identifiers, how many pictures it granted and when) is kept while your account exists too. It is not on the twelve-month clock above: it is what your balance is counted from, so deleting it would delete the credits with it. An earlier purchase on the website made under an address that never signed in has no account to delete, so that record simply stays until someone asks us to erase it. Email office@designey.ai and we will.

Invoices must be kept for seven years. For the purchases the website used to offer, we were the seller, so Austrian tax law makes us keep the accounting record of such a sale for seven years (§ 132 BAO), and Art. 17(3)(b) GDPR is the reason an erasure request does not reach it. The invoice is held at Stripe, names your address and what you paid, and stays for those seven years whatever else you delete. Nothing about your rooms, your photos or your pictures is in it. For purchases in the app, the store issues the invoice and keeps it under its own rules.

The beta waitlist: until we write to you, and no longer. Your address is kept until we send the one email it exists for, and deleted once that email has gone. You do not have to do anything to be forgotten, and the message itself will say so, naming the day you signed up and telling you the address has already been removed. If you would rather it went sooner, write to office@designey.ai and it goes the same day.

You can delete your account at any time in the app, in the You tab. That erases your photos, your pictures and videos, your saved products, the push tokens of your devices, your ledger, the record of any purchase made under your address and our copy of a customer record that an earlier purchase on the website created at Stripe, and the address itself, including at the sign-in provider, immediately and without asking why. The invoice stays, for the seven years described above. RevenueCat still keeps its record of your purchases under your address; email office@designey.ai and we delete it there. Any unspent credits are lost with it and are not refunded, which is why the page that asks you to confirm says how many they are; if you want a refund instead, request it from the store before you delete. If you would rather we did the deletion, write to office@designey.ai.

After your account is deleted, a one-way code made from your email address stays for 60 days. It has one purpose only: that the 3 free pictures cannot be claimed again by deleting an account and opening a new one. The code is a keyed hash (HMAC-SHA256) of your address, made with a secret key that only we hold, after the address is brought into one form: lower case, without a “+” suffix, and for Gmail without dots, with googlemail.com counted as gmail.com. We do not store the address itself, and without the key it cannot be worked back out of the code. With the key we can still check whether a given address was deleted, so the code is pseudonymised data, not anonymous. If an account is opened within those 60 days with an address that gives the same code, it starts without the free pictures; signing in and buying credits work as usual. Codes older than 60 days are deleted automatically, every night. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in stopping the free pictures from being claimed again this way.

This website: server logs are deleted after 14 days at the latest, Google Analytics data after 14 months at the latest (section 2).

Your decision. We store your answer to this website's cookie banner in a cookie. The answer stands for six months; after that we ask again, and sooner if something arrives that you have not answered for yet. You can change or withdraw it at any time through “Cookie settings” in the footer of every page. The full list of every single cookie, with its purpose, its duration and its provider, is in the cookie policy.

On this website, two strictly necessary cookies store your language choice and that decision. Google Analytics sets cookies of its own, but only after you consent via the banner (section 2). If you decline, nothing is loaded and nothing is set.

The iOS and Android app keeps your sign-in in your device's protected storage, so our server knows the pictures are yours. That is strictly necessary and needs no consent (§ 165(3) TKG 2021). There is no advertising in the app, no ad network, no tracking pixel and no audience measurement, and nothing of ours follows you to another site; what a retailer's partner programme sets in its own shop is in section 5. You buy credits in the app through the App Store or Google Play, with no browser and no cookie.

You have the right to access your data (Art. 15), to have it corrected (Art. 16) or erased (Art. 17), to restrict or object to processing (Art. 18, 21), to receive it in a portable form (Art. 20), and to withdraw any consent you gave (Art. 7(3)) without affecting what was lawful before: the audience-measurement consent through the cookie settings in the footer of every page on this website, the transfer agreement as described in section 4, the permission for notifications in your device's settings. Write to office@designey.ai, and we answer within a month.

You can also complain to the Austrian data protection authority: Österreichische Datenschutzbehörde, Barichgasse 40-42, 1030 Vienna, dsb.gv.at.

From 16 you can use Designey on your own. If you are 13, 14 or 15, you may use Designey only if your parents or guardians have agreed. They must also agree before you consent to us sending your room photo to the AI providers in the United States (section 4). Under 13 you may not use Designey or create an account, not even with the consent of your parents or guardians.

You may buy credits or a plan once you are of legal age, which in most countries means 18, and before that only with the consent of your parents or guardians. If the law of your country sets a higher age for using Designey or for purchases, that age applies.

If we learn that an account belongs to a child under 13, or to someone under 16 whose parents have not agreed, we delete it with all its rooms, pictures and videos. What section 6 says outlasts a deletion, such as invoices or the code made from the email address for 60 days, stays only as long as section 6 describes.

Parents and guardians can write to office@designey.ai at any time to find out what we store about their child or to have the account deleted. We first check that the request really comes from a parent or guardian.

Designey is early, and the way it works still moves. If the processing changes we update this page and its date; if the change changes what we use your photo for, we ask for your consent again.