Privacy Policy

1. Data Controller

Olga Dimenshtein (“I”, “me”, “the Photographer”) is the data controller responsible for your personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 — GDPR) and Italian data protection legislation (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

2. Personal Data I Collect

Depending on how you interact with me, I may collect the following categories of personal data:

When you enquire about or book my services
  • Name, surname, and contact details (email, phone number, address)
  • Tax identification code (Codice Fiscale) for invoicing purposes
  • Event details (date, location, schedule, participant names)
  • Payment information (invoice records — I do not store credit card numbers)
During and after a photo shoot
  • Photographic images (including RAW files and edited photographs) — these constitute personal data under GDPR, as they may identify individuals
  • Names and roles of individuals being photographed
  • Location data associated with photographs (metadata)
When you visit this website
  • IP address and approximate geolocation (processed by Cloudflare and Hostinger)
  • Browser type, operating system, screen resolution, and language preferences
  • Pages visited, referrer information, device type, performance metrics, and aggregated usage statistics collected through Cloudflare Web Analytics
  • Interaction and verification data submitted through Cloudflare Turnstile when you use protected forms on this website
  • Font display data transmitted when web fonts are loaded (Google Fonts)
3. Purposes and Legal Bases for Processing

I use your personal data exclusively for the purposes listed below. Each purpose is linked to its legal basis under Article 6(1) GDPR:

Purpose Legal Basis
Communicating with you about your booking, event planning, and photo delivery Contract performance
Art. 6(1)(b)
Performing the photography services described in our agreement (shooting, editing, selecting, and delivering your photographs) Contract performance
Art. 6(1)(b)
Displaying selected images in my portfolio (website, social media, printed materials, professional presentations) unless you have opted out or chosen the full-privacy option Legitimate interest
Art. 6(1)(f)
Issuing invoices, processing payments, and maintaining accounting records as required by Italian tax law Legal obligation
Art. 6(1)(c)
Responding to your enquiries or requests Contract performance / Legitimate interest
Art. 6(1)(b)/(f)
Hosting and delivering the website and email communications (Hostinger) Legitimate interest
Art. 6(1)(f)
Protecting the website against malicious traffic, automated abuse, DDoS attacks, and spam (Cloudflare, Cloudflare Turnstile) Legitimate interest
Art. 6(1)(f)
Displaying the website with consistent typography (Google Fonts) Legitimate interest
Art. 6(1)(f)
Improving my website and services through aggregated, cookie-free analytics (Cloudflare Web Analytics) Legitimate interest
Art. 6(1)(f)

Where processing is based on legitimate interest, you have the right to object to such processing in accordance with Article 21 GDPR, subject to applicable legal exceptions.

4. Data Retention
Type of Data Retention Period
Finished (edited) photographs 24 months from delivery date, for backup and portfolio purposes
RAW image files Until completion of editing and delivery of the finished photographs to the Client, then securely deleted
Invoices and financial records 10 years, as required by Italian tax law
Contact and communication records 24 months from the last engagement, or until you request deletion
Website analytics data (Cloudflare Web Analytics) Retained by Cloudflare in accordance with the settings and retention periods applicable to Cloudflare Web Analytics
Cloudflare security logs Retained by Cloudflare in accordance with their data retention policy (typically up to 72 hours for security event logs)
Hostinger server logs Retained by Hostinger in accordance with their data retention policy

After the retention periods above, personal data is securely deleted or anonymised. Photographs used in my portfolio may be retained longer in accordance with the terms of our agreement.

5. Your Rights

Under GDPR, you have the following rights regarding your personal data:.

  • Access — request a copy of the personal data I hold about you
  • Rectification — request correction of inaccurate or incomplete data
  • Erasure — request deletion of your data (subject to legal retention obligations)
  • Restriction — request that I limit how I process your data
  • Portability — receive your data in a structured, commonly used, machine-readable format
  • Objection — object to processing based on legitimate interest, including processing related to website security, anti-abuse measures, and portfolio use, where applicable

To exercise any of these rights, please contact me at . I will respond within 30 days.

6. Data Sharing and Third-Party Services

I do not sell, rent, or trade your personal data. I may share limited data with the following categories of recipients, only as necessary:

Photography services
Recipient Purpose Data Processed
Cloud storage providers Hosting and delivering your photographs via secure cloud links Photographs, delivery metadata
Accountant / tax advisor Processing invoices and complying with Italian tax obligations Name, Codice Fiscale, invoice data
Second photographer / assistant Sharing relevant logistical details when additional coverage is arranged for your event Event schedule, location details
Website infrastructure and services
Service Provider Purpose Data Processed Legal Basis
Hosting & email Hostinger International Ltd. (Lithuania / Cyprus) Web hosting, email delivery, server-side processing IP address, HTTP request data, email content and metadata Legitimate interest
DNS & security Cloudflare, Inc. (USA) DNS resolution, DDoS protection, web application firewall, SSL/TLS encryption, bot management IP address, HTTP headers, browser and network signals, and, where applicable, strictly necessary security cookies managed by Cloudflare Legitimate interest
Web fonts Google LLC (USA) Serving typefaces for consistent website typography IP address, browser user-agent string, referrer URL Legitimate interest
Analytics Cloudflare, Inc. (USA) Privacy-focused website usage statistics and performance measurement IP address, pages visited, referrer information, device/browser data, and performance metrics processed in aggregated form; Cloudflare states Web Analytics is cookie-free Legitimate interest
Anti-spam / bot protection Cloudflare, Inc. (USA) Protecting forms from automated abuse and spam submissions (Turnstile) IP address, browser and device signals, interaction data, verification token, and, depending on configuration, strictly necessary Cloudflare cookies or related challenge data Legitimate interest
7. International Data Transfers

Some of the third-party services listed above are provided by companies based outside the European Economic Area (EEA), including Google LLC and Cloudflare, Inc., which are based in the United States. When personal data is transferred outside the EEA, I ensure that appropriate safeguards are in place in accordance with Chapter V of the GDPR, including:

  • EU Standard Contractual Clauses (SCCs) — adopted by the European Commission, forming part of the data processing agreements with these providers
  • EU-U.S. Data Privacy Framework — where the recipient is certified under the framework

Hostinger International Ltd. processes data within the EU/EEA. You may request further details about the safeguards in place by contacting me at the details provided in Section 1.

8. Cookies and Tracking Technologies

This website uses cookies — small text files stored on your device — and similar technologies to ensure security, maintain essential website functionality and, where applicable, support limited privacy-focused analytics.

Types of cookies and technologies used
Category Cookie / Technology Provider Purpose Legal Basis
Strictly necessary Session cookies This website Essential for the website to function correctly Legitimate interest
Security __cf_bm, __cfruid, cf_clearance and similar Cloudflare security cookies, where applicable Cloudflare Bot detection, DDoS protection, security challenge management, and related site protection functions Legitimate interest
Anti-spam / bot protection Turnstile widget scripts, verification token, and related challenge datas Cloudflare Turnstile v3 Distinguishing human visitors from automated bots and protecting forms from abuse. Turnstile usually works without interactive CAPTCHA challenges. Depending on configuration, Cloudflare may also set strictly necessary security cookies./td> Legitimate interest
Analytics Cookie-free analytics script Cloudflare Web Analytics 4 Collecting aggregated website traffic and performance statistics in a privacy-focused, cookie-free manner, according to Cloudflare Legitimate interest
Cloudflare Web Analytics

This website uses Cloudflare Web Analytics to measure website traffic and basic performance metrics in a privacy-focused manner. According to Cloudflare, Web Analytics is cookie-free and is designed to provide aggregated statistics without using client-side analytics cookies.

Cloudflare Turnstile

This website uses Cloudflare Turnstile to protect forms from automated abuse and spam. Turnstile works without traditional CAPTCHA challenges in most cases and generates a verification token that must be validated server-side to confirm a legitimate submission. Depending on your configuration and Cloudflare security features enabled on the site, strictly necessary Cloudflare cookies may also be set for security or challenge management purposes.

Managing cookies

You can manage or disable cookies through your browser settings. Please note that disabling strictly necessary or security-related cookies may affect the proper functioning or security of this website. Because Cloudflare Web Analytics is described as cookie-free, there may be no analytics cookies to disable for that service itself.

9. Data Security

I take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include encrypted storage, secure cloud services with access controls, regular backups, password-protected devices, and SSL/TLS encryption for all website traffic (provided via Cloudflare).

10. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, I will notify you without undue delay and, where feasible, within 72 hours of becoming aware of the breach. I will also notify the Garante per la protezione dei dati personali as required under Article 33 GDPR.

11. Photographs of Third Parties

During event photography, I may photograph individuals other than my direct client (e.g., guests, attendees). Under my service agreements, the client is responsible for obtaining the necessary permissions from individuals appearing in the photographs. If you believe a photograph of you has been taken or used without appropriate permission, please contact me and I will address your concern promptly.

12. Portfolio and Promotional Use

I use selected photographs from my engagements for my professional portfolio and promotional purposes, based on legitimate interest (Art. 6(1)(f) GDPR). This usage is governed by the terms of my service agreement, which includes:

  • The right for clients to request exclusion of specific photographs within 10 days of delivery
  • A full-privacy option available for an additional fee, under which no photographs will be used for promotional purposes
  • A commitment to respect requests regarding sensitive or private images

If you are a non-client individual who appears in photographs on my website or social media and would like to request removal, please contact me at the details above.

13. Children

I do not knowingly collect personal data from children under the age of 16 without parental or guardian consent. When photographing events that include minors, the client is responsible for obtaining any necessary consent from parents or guardians. I take particular care when selecting images of minors for portfolio or promotional use.

14. Changes to This Policy

I may update this privacy policy from time to time to reflect changes in my practices or legal requirements. The updated version will be posted on this page with a revised effective date. I encourage you to review this policy periodically.

If you have any questions about this privacy policy or how I handle your personal data, please contact me.

Last update: 22 April 2026