Fictional product, illustrative draft. Not legal advice.

Shutterline Privacy Notice¶

Draft for counsel review. Law as of 20 October 2026. This is not legal advice.

Last updated: [date]. Controller: Lumenfolk Media GmbH, Spichernstrasse 12, 50672 Köln, Germany, legal@lumenfolk.test, managing director Theresa Brandt.

This notice explains what personal data Shutterline collects, why, on what legal basis, who sees it, how long we keep it, and what rights you have over it. It covers users in the EU and the United States; where a right or a rule differs by where you live, that is stated in its own section below.

1. What we collect and why¶

Category of data	Purpose	Legal basis (EU)
Account data (email, birth date, display name, password)	Create and secure your account; confirm you meet our minimum age	Performance of our contract with you (Art. 6(1)(b) GDPR)
Photos, comments and profile content you post	Operate the public-facing parts of Shutterline (feed, profile, search)	Performance of our contract with you (Art. 6(1)(b) GDPR)
Direct messages	Deliver and store messages between you and another user	Performance of our contract with you (Art. 6(1)(b) GDPR)
Activity data (what you view, like, and how long you spend on content) used to show you plain contextual advertising	Show contextual advertising next to the feed, unrelated to your personal profile	Our legitimate interest in funding a free service through advertising that does not use your personal profile (Art. 6(1)(f) GDPR)
Activity data (what you view, like and interact with) used to show you advertising personalised to your activity	Show you advertising selected based on your own behaviour on Shutterline	Your consent (Art. 6(1)(a) GDPR). See our [Cookie Notice] for how we ask for this.
Reports you submit, and reports submitted about you	Run our content-moderation process	Our legitimate interest in keeping Shutterline safe and lawful, and, where the report concerns a legal claim, our legal obligation to act on it (Art. 6(1)(c), (f) GDPR)
Technical and device data (IP address, browser type, device identifiers)	Operate, secure and troubleshoot Shutterline	Our legitimate interest in running a secure, working service (Art. 6(1)(f) GDPR)

A privacy notice for a free, advertising-funded service cannot rely on legitimate interest for personalised advertising built from your own behaviour and interests: you cannot reasonably expect us to process your personal data for personalised advertising without being asked first, so the basis for that specific purpose is your consent, not our legitimate interest. Plain contextual advertising that does not use a behavioural profile is a separate purpose, with a separate (legitimate-interest) basis, because it does not carry the same surprise or intrusion.

United States¶

We collect the same categories of data described above from US users. See Section 9 (US state privacy rights) for the categories, sources, purposes, and sharing disclosures required under California, Virginia, Colorado, Connecticut and Texas law, and our [Cookie Notice] for how targeted advertising opt-outs work for US users.

2. Who sees your data¶

Other Shutterline users see your public profile, your public photos, and comments you post publicly. Only the recipient of a direct message sees its content.
Service providers who process data on our behalf, under contract, to help us run Shutterline (for example, hosting, email delivery, customer support tooling). [Open point: see open-points.md item 7: no specific vendor was named by the client, and this notice assumes every such vendor is established and processes data inside the EEA. If any vendor is outside the EEA, this section and Section 6 (international transfers) need to be updated with the specific vendor and transfer mechanism.]
Advertisers see aggregated or pseudonymised audience data to the extent needed to run a campaign; we do not sell your name, email address or direct-message content to advertisers.
Authorities, where legally required (for example, in response to a valid order under the Digital Services Act or a comparable legal process).

We do not sell your personal information for money.

3. How long we keep your data¶

We keep your account data and content for as long as your account is active, plus a limited period after deletion needed to comply with a legal obligation, resolve a dispute, or enforce our agreements (typically [X days/months: to be confirmed with the client's actual retention schedule]). A copy kept as required by law, a backup kept on our ordinary backup cycle, or content another user has already shared further before your deletion is kept as described in our [Terms of Service], Section 5.

4. Your rights (EU users)¶

You have the right to:

access the personal data we hold about you;
ask us to rectify inaccurate data;
ask us to erase your data, in the circumstances the law sets out;
ask us to restrict our processing, in the circumstances the law sets out;
object to processing based on our legitimate interest, on grounds relating to your particular situation; and
object to direct marketing, including related profiling, at any time, with no justification needed: we always honour this;
ask for your data in a portable, machine-readable format, where the processing rests on your consent or our contract with you and happens by automated means;
withdraw consent at any time, as easily as you gave it, with no effect on the lawfulness of processing before you withdrew; and
complain to a supervisory authority: in Germany, the data protection authority for North Rhine-Westphalia, or the authority in your own EU member state of residence.

To exercise a right, contact us at legal@lumenfolk.test. We respond within one month, extendable by two further months for a complex or numerous request, with a reason given to you within the first month. We do not charge for this unless your request is manifestly unfounded or excessive, and we carry the burden of showing that if we say so.

Right to erasure ('right to be forgotten')¶

(Art. 17 GDPR.) See the erasure right above; this heading is given in the GDPR's own fixed wording.

Where we ask for your consent (for example, for personalised advertising, or for a non-essential cookie), we ask separately for each purpose, in plain language, with a genuine option to decline that is as easy to use as the option to agree. You can withdraw consent at any time, as easily as you gave it, through your [Privacy settings]; withdrawing does not affect anything we did before you withdrew, and does not cost you anything or reduce the rest of Shutterline beyond what that one withdrawn purpose enabled.

6. International data transfers¶

[Open point: on the facts given, data is stored on Lumenfolk's own servers in the EU, and no processor outside the EEA has been identified. This notice is drafted on the assumption that no international transfer occurs. If any vendor (hosting partner, analytics, customer support tool, push notification service) is outside the EEA, this section needs the specific country, the transfer mechanism relied on (an adequacy decision, or standard contractual clauses backed by a transfer impact assessment), and how to get a copy of the safeguard, named here before publication.]

7. Children and minimum age¶

Shutterline is not directed to children under 16, and we do not knowingly collect personal information from anyone under 16. We check your age by asking for your birth date when you create an account. If we learn that a user is under 16, we will [close the account / limit it, as the client's actual process is: to be confirmed].

8. Cookies and tracking technologies¶

See our separate [Cookie Notice] for what we store or read on your device, why, and how to control it.

9. US state privacy rights¶

[Open point: see open-points.md item 4: whether Shutterline has crossed the CCPA's own numeric thresholds (a specific gross-revenue figure, a specific California-resident record-volume figure, or the 50%-of-revenue-from-selling-personal-information limb) has not been confirmed, and this notice does not estimate that from the global turnover or user-count figures given. The content below is drafted to the CalOPPA standard, which applies regardless of any threshold, plus a conservative, CCPA-style structure; it should be reviewed against the specific threshold determination before publication.]

CalOPPA (all California users, regardless of any threshold)¶

This privacy notice is linked from our homepage and app store listing using the word "privacy." We describe here how we respond to browser do-not-track signals: [state the actual practice: for example, "we do not currently respond to browser do-not-track signals because no common standard for how to respond has been adopted; we honor opt-out preference signals as described in our Cookie Notice instead"]. Other parties (our advertising partners) may collect data about your activity across Shutterline and other sites or apps, to the extent described in our [Cookie Notice]. You can review and ask us to change the personal information we hold by contacting us using the channel in Section 4. We notify you of a material change to this notice by [in-product notice / email, to be confirmed], and the effective date of this notice is stated at the top.

If CCPA applies in full (pending the threshold confirmation above)¶

Categories collected: identifiers (email, device ID), account and profile information, content you post, commercial information (advertising interaction), internet or network activity, and geolocation (to the extent your device provides it).
Purpose: to provide Shutterline, to show advertising (contextual and, with consent, personalised), to keep the service safe, and to comply with the law.
Sold or shared: we do not sell your personal information for money; see our [Cookie Notice] for whether any data sharing for cross-context behavioural advertising counts as "sharing" under the CCPA's own definition, and for your opt-out right if so.
Retention: see Section 3 above.
Your rights: to know, delete, correct, and opt out of sale/sharing or limit use of sensitive personal information (to the extent applicable); contact us at legal@lumenfolk.test, or [toll-free number / webform, to be added] to exercise these. We do not condition any of these rights on creating an account, and we do not charge for exercising them.
No discrimination: we do not charge you a different price or give you a different quality of service for exercising a privacy right.

Virginia, Colorado, Connecticut and Texas¶

[Open point: whether Shutterline's 1.5 million US monthly active users, broken down by state, cross the Virginia-model thresholds (100,000, or 25,000 with over a stated share of revenue from selling personal data) for any of these four states has not been confirmed and is not estimated here. If a per-state breakdown later shows a threshold is crossed for a given state, this notice needs that state's own content list (processing purposes and legal basis per category, the opt-out mechanism for targeted advertising and sale, the appeal process for a declined rights request, and, for Colorado, the universal opt-out signal and granular processing-purpose disclosures) added as its own subsection.]

Other US states¶

Shutterline has 1.5 million US monthly active users; depending on how they are distributed across states, another state privacy law may apply. See open-points.md item 5.

10. Contact us¶

Email: legal@lumenfolk.test. Postal address: Lumenfolk Media GmbH, Spichernstrasse 12, 50672 Köln, Germany.