Data Protection Policy

DB Entertainment – Data Policy & Privacy Notice

(Photo Booths, Selfie Pods & AI Photo Experiences)

1. Introduction

DB Entertainment (“we”, “us”, “our”) is committed to protecting the privacy and personal data of individuals who use our photo booths, selfie pods, and AI-powered photo experiences (“photo services”). This policy explains how we collect, use, store, share, and protect personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy applies to all participants whose images are captured while using our services.

2. Data Controller

DB Entertainment acts as the data controller for all personal data processed through our photo services.

Contact details:
Email: events@dbentertainment.co.uk

3. What Personal Data We Collect

When you use our photo services, we may collect and process:

• Photographs and images captured during your session
• AI-generated images created from those photographs (where applicable)
• Event-related information (such as event name and date)

While we do not deliberately collect sensitive personal data, photographs may constitute special category data under UK GDPR where they reveal biometric information or other sensitive characteristics, particularly when AI processing is involved.

4. How We Collect Your Data

Personal data is collected when participants voluntarily engage with our photo booths, selfie pods, or AI booths.

Before photos are taken, participants are required to actively acknowledge a clear disclaimer and/or waiver presented on-screen or at the booth. Participation does not rely on implied consent alone.

5. Lawful Basis for Processing (Article 6 UK GDPR)

We process personal data under the following lawful bases:

• Consent (Article 6(1)(a))
  Where individuals actively acknowledge the disclaimer/waiver and proceed to take photos.
• Legitimate Interests (Article 6(1)(f))
  For the secure operation, technical delivery, and management of our photo services, including storage, retrieval, and customer support, provided such interests are not overridden by individuals’ rights and freedoms.

Consent can be withdrawn at any time by contacting us (see Section 11).

6. Special Category Data & Article 9 Conditions

Where photographs or AI-generated images constitute special category data, including potential biometric data:

• Processing is carried out on the basis of explicit consent under Article 9(2)(a)
• Participation is optional and no adverse consequences arise from non-participation
• Appropriate safeguards are implemented to protect the data

Images are not used for biometric identification, facial recognition, or profiling for legal or similarly significant effects.

7. AI Processing Transparency

Some of our photo services use AI-based software to generate enhanced or transformed images.

• AI processing is used solely to create visual outputs requested by participants
• No automated decision-making with legal or similarly significant effects takes place
• Images are not used to train AI models unless explicitly stated and separately consented to
• AI processing may involve trusted third-party technology providers acting as data processors under contract

AI processing and cloud storage are necessary due to the technical operation of the software and the nature of AI-generated images.

8. Storage, Cloud Processing & International Transfers

• Photos are stored on secure, cloud-based servers
• Access is password-protected and restricted to authorised personnel
• Third-party service providers act only on our instructions and are contractually bound to comply with UK GDPR

Where data is stored or accessed outside the UK:

• Appropriate safeguards are in place, such as UK adequacy regulations or standard contractual clauses
• Data protection standards equivalent to UK GDPR are maintained
• Cloud storage is based either on UK servers or EU servers.

9. Data Retention

Photos may be stored in a cloud gallery for up to two (2) years from the date of capture.

This retention period is justified as necessary to:

• Allow participants and event organisers access after the event
• Manage customer service queries and deletion requests
• Support operational and contractual requirements

Photos may be deleted earlier where:

• An individual or organiser requests deletion
• Data is no longer required for the stated purposes

Once deleted, images are permanently removed where technically possible.

10. Deletion Requests

Individuals may request deletion of:

• Specific images, or
• All images from a particular event

Requests should be sent to:

events@dbentertainment.co.uk

Please include sufficient details (event name/date) to allow identification. You will receive a response confirming the actions taken or any further information required.

11. Children’s Data

Our services may capture images of children at events. Responsibility for ensuring appropriate consent rests with:

• Parents or legal guardians, or
• Event organisers acting in loco parentis

Children are not directly targeted, and images are processed only as part of the event experience.

12. Your Rights Under UK GDPR

You have the right to:

• Access your personal data
• Request rectification of inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict processing
• Data portability
• Object to processing based on legitimate interests
• Withdraw consent at any time
• Lodge a complaint with the Information Commissioner’s Office (ICO)

ICO website: https://ico.org.uk

Requests can be made by emailing events@dbentertainment.co.uk.

13. Changes to This Policy

This policy may be updated periodically to reflect changes in our services, technology, or legal requirements. The most current version will always be made available where our services are used.