Privacy Policy Introduction
This document explains how Picento Automated Photography Systems Limited (“Picento”, “we”, “us”, “our”) collects, handles, and uses your personal data when you use our services, including accessing your images via our website or Picento apps.
It explains how we use your data responsibly and how we keep it safe and secure.
We provide this information to comply with applicable data protection legislation, including the UK GDPR, the Data Protection Act 2018, and (where applicable) the EU GDPR.
Who Are We?
Picento Automated Photography Systems Limited is a privately owned company registered in England.
We provide automated photography services to attractions and theme parks, alongside a website and app that allow you to access and store your photographs.
Picento is the Data Controller for your personal data.
We are not required to appoint a Data Protection Officer; however, we have appropriate data protection training and support in place.
You can contact us at: info@picento.com
What Data We Collect
We collect and process a limited amount of personal data, including:
Name
Email address
Photographic images (including images you upload)
Where you upload an image for facial recognition, we process this to extract facial landmark data.
Because facial recognition is used, this constitutes biometric data, which is classified as special category data under data protection law.
We may also collect:
Marketing preferences
Competition entry information
Payment-related information via third-party payment providers
We only process biometric data (facial recognition) where you have provided explicit consent.
How We Collect Your Data
We collect data directly from you when you:
Purchase products or services
Register for an account
Upload images for facial recognition
Subscribe to marketing communications
Enter competitions or promotions
Contact us with enquiries
We also process photographs taken at attractions and link them to your account where applicable.
How We Use Your Data
We use your personal data to:
Provide and operate our services
Deliver and match your photographs
Manage your account
Process transactions
Improve our services
Communicate with you (including marketing where consent is given)
⚖️ Legal Bases for Processing
We rely on the following lawful bases:
Consent – for account registration, marketing, and general data processing
Explicit Consent – for biometric (facial recognition) data
Contract – where you purchase services or create an account
Legal Obligation – for financial and regulatory compliance (e.g. HMRC)
Legitimate Interests – to operate and improve our business
How We Store Your Data
We take appropriate technical and organisational measures to protect your data.
This includes:
Secure cloud-based storage (hosted within the EEA)
Access controls and restricted permissions
Up-to-date security software (antivirus/firewalls)
Contracts with third-party processors
Sharing Your Data
We:
Do not sell, rent, or trade your personal data
Only share data where required by law or with trusted service providers under contract
Do not transfer data outside the EEA unless appropriate safeguards are in place
Facial recognition is used to assist in matching images but does not produce legal or similarly significant effects on individuals. Therefore, it is not considered automated decision-making under Article 22 UK GDPR.
Data Retention
We retain personal data only as long as necessary.
Typical retention periods:
Financial records: 6 years
Contracts: 6 years after termination
Account data: until deletion or withdrawal
You may request deletion of your data at any time.
Your Rights
You have the following rights:
Access your data (Subject Access Request)
Rectify inaccurate data
Request deletion (right to erasure)
Restrict processing
Data portability
Object to processing
Rights related to automated decision-making
Requests can be made via: info@picento.com
We will respond within one month.
Withdrawing Consent
You can withdraw consent at any time by:
Clicking “unsubscribe” in emails
Contacting: info@picento.com
Please note: withdrawing consent may prevent us from providing certain services.
Complaints
If you are unhappy with how we handle your data, please contact us first.
You also have the right to complain to the Information Commissioner’s Office (ICO):
Website: www.ico.org.uk
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Facial Recognition (Additional Information)
Facial recognition works by detecting facial features and converting them into a unique numerical identifier based on facial landmark points.
This identifier is securely stored and linked to your account to enable automated image matching.
You can:
Remove your facial data at any time
Request full deletion of your account and associated data
Document Details
Date Published: March 2026 Version: 2.2