privacy policy
Last updated: 10 November 2026
1. who is responsible
STUDIO ETRELA (SAS, RCS Paris 991 993 288, 200 rue de la Croix Nivert, 75015 Paris) operates ephmr studio. Privacy contact: hello@ephmr.app. We have not appointed a data protection officer, as the law does not require one for our activity.
2. what we collect, why, and for how long
| Data | Why | Legal basis | Kept for |
|---|---|---|---|
| Email (sample request, account) | Create your account, send your sample and book links, service messages | Contract (or steps before a contract) | While your account is active; then deleted within 30 days of account deletion. Sample requests without an account: 3 months |
| Photos, logo and texts you upload; projects and generated PDFs | Lay out and deliver your book | Contract (we act on your behalf, see section 5) | While your account is active. Samples that you never turn into a purchase: deleted after 30 days. Accounts inactive for 12 months: we warn you by email 30 days before deleting your projects |
| Temporary files created while rendering | Generate the PDF | Contract | A few hours |
| Download links | Deliver your files | Contract | 30 days |
| Payment and invoicing data | Paddle, as Merchant of Record, takes payment, invoices you and handles VAT. We receive your name/email, country, order reference and subscription status, not your card number | Contract; legal obligations (Paddle) | As required by law (accounting records: 10 years at STUDIO ETRELA, for the payouts we receive from Paddle) |
| Consents (withdrawal-right waiver, optional "example" permission, optional newsletter) | Prove what you accepted and when | Legal obligation / legitimate interest | Duration of the contract + 5 years |
| Newsletter / product news (only if you tick the box) | Send news | Consent | Until you unsubscribe; inactive contacts removed after 3 years |
| Technical logs (IP address, errors, security) | Security and troubleshooting | Legitimate interest | 6 to 12 months |
| Support messages | Answer you | Contract / legitimate interest | 3 years after the last exchange |
| Backups | Resilience | Legitimate interest | 30 days maximum |
We do not use your photos to train AI models, we do not sell your data and we do not carry out automated decisions that have legal effects on you. The automated layout of your book is a technical process; you can always change the result or ask us to look at it.
3. how deleting works
- Delete your account from your account settings: this deletes your projects, photos and PDFs from our servers immediately, and from backups within 30 days. Payment records kept by Paddle and our accounting records are kept as required by law.
- Delete one project or photo at any time from your account.
- Or write to hello@ephmr.app; we reply within one month.
4. people who appear in the photos
If you are shown in a photo uploaded by someone else and want it removed, write to hello@ephmr.app with the details; we remove it from our service. Users promise that they hold the consent of the people they photograph (see the Terms). We do not identify people by their face and we do not run facial recognition.
5. our role
For your account and your payment we are the data controller. For the photos and texts you upload we process them on your instructions (as a processor) only to provide the service. Where you are a business, a data processing agreement is available on request.
6. who receives your data (sub-processors)
| Recipient | Role | Location |
|---|---|---|
| Scaleway SAS | Hosting of the app and file storage | Amsterdam, Netherlands (zone AMS-1) |
| Paddle.com Market Limited (30 Old Bailey, London EC4M 7AU) and affiliates | Merchant of Record: payment, invoicing, VAT, refunds; acts as an independent controller for payment data (see paddle.com/legal/privacy) | United Kingdom; may involve the USA |
| Purelymail (Add Rabbit LLC, USA) | Mailbox for hello@ephmr.app (support and contact emails you send us) | AWS us-east-1 region, United States |
| Mailjet (operated by Sinch AB and its subsidiaries) | Sending transactional emails | European Union |
We do not use advertising trackers. If this list changes, we update this page.
7. transfers outside the eu
Hosting stays in the EU, in Amsterdam, Netherlands. Support and contact emails sent to hello@ephmr.app are handled by Purelymail (Add Rabbit LLC, USA), with servers in the AWS us-east-1 region in the United States. This means those emails are transferred outside the EU to the United States. Paddle may transfer data outside the UK/EEA; according to its privacy notice (https://www.paddle.com/legal/privacy, section F) it uses Standard Contractual Clauses (EU Decision 2021/914) and the UK addendum. Paddle's GDPR page names no other mechanism. Contact for copies: privacy@paddle.com.
8. your rights
You can access, correct, delete, restrict, object to the processing of your data and ask for a portable copy; where we rely on consent you can withdraw it at any time. Write to hello@ephmr.app. We reply within one month. You can also lodge a complaint with the CNIL (cnil.fr, 3 Place de Fontenoy, 75007 Paris).
9. cookies
We only use cookies that are strictly necessary to run the service (login session and security) and our own audience statistics, which do not use third-party cookies or trackers. These do not require your consent. The Paddle checkout may set cookies needed to process your payment; see Paddle’s privacy policy. If we add other cookies, we will ask for your consent first.
10. security
Data are encrypted in transit (HTTPS); access to files is limited to the service and to authorised staff; download links expire.
11. changes
We will update the date above and, for important changes, tell you by email.