Houghton Photo
Privacy
Last updated: 16 May 2026
Photo Panel is a web application run by Joe Houghton, trading as Houghton Photo, based in Lucan, County Dublin, Ireland. This page describes what personal data we collect, why we collect it, who we share it with, and what rights you have over it.
The short version
- Account data. We store your name, email, a bcrypt hash of your password (if you signed up with email), your role (user or admin), and your credit balance. Nothing more.
- Photographs.Your panel images are processed in memory, sent to Anthropic's Claude API for the critique, then discarded the moment the response is complete. We do not store your photographs anywhere on our servers.
- Payment data. When you buy credits, the card transaction is handled by Paddle. We never see your card details. We receive a record of the purchase (amount, credits added, order ID) for our credit ledger.
- No tracking pixels. No Google Analytics, no advertising pixels, no fingerprinting. The only cookies we set are the NextAuth session cookie and your CSRF token.
What we collect, and why
| Data | Legal basis | Why |
|---|---|---|
| Name and email | Contract performance (Art. 6(1)(b) GDPR) | To create your account, authenticate you, contact you about your account. |
| Password hash (if you signed up with email) | Contract performance | To verify your sign-in. We store only a bcrypt hash, never the plaintext. |
| Credit balance and transaction history | Contract performance | To gate access to the Service and to keep an audit trail of credits granted, purchased, and used. |
| Payment records (amount, order ID, credits added) | Contract performance + legal obligation (Irish tax law) | To keep an account of purchases for our records and for tax filings. We do NOT receive your card details. |
| Photographs (transiently) | Contract performance | To produce the critique you requested. Held in memory only, never written to disk or object storage. |
| Session cookie | Strictly necessary (no consent required under PECR) | To keep you signed in across pages. |
What we share with Anthropic
To produce a critique we send your image and a fixed instruction prompt to Anthropic's Claude API. Anthropic processes the image to generate the critique text. Under Anthropic's commercial terms, customer inputs (your image and prompt) are not used to train their models. See Anthropic's privacy policy for details.
What we share with Paddle
When you buy credits, you're routed to a Paddle-hosted checkout. You enter your card details directly with Paddle - we never see them. Paddle acts as the Merchant of Record and is responsible for VAT, fraud screening, and PCI compliance. We send Paddle your email address (so they can email you a receipt) and the price ID identifying which credit pack you bought. Paddle sends us back a webhook event when the payment clears, with the order ID, the amount paid, and a reference to the purchase. See Paddle's privacy notice for details.
Sub-processors
A sub-processor is a third party that processes personal data on our behalf. We use the following:
- Anthropic (USA, with EU-region inference for Claude) - transient processing of your image and prompt to generate the critique.
- Vercel (USA, with EU-region functions where possible) - hosting and standard server logs (path, status, IP for rate-limiting purposes).
- Neon (Frankfurt, EU) - the Postgres database that stores your account record, credit balance, payment history, and credit-transaction audit log.
- Paddle (UK + EU) - card processing for credit purchases. Paddle is the Merchant of Record. They receive your email and the price ID you selected; we receive payment confirmation back via webhook.
- Brevo (formerly Sendinblue, France, EU) - transactional emails (welcome on signup, feedback notifications, future password-reset and account-related notices).
How long we keep your data
- Account data (name, email, password hash, role, credit balance) - for as long as your account is active. Deleted within 30 days of account closure, except where retention is required for legal or accounting reasons (see Payment records).
- Payment records (Paddle order ID, amount, credits added) - retained for at least six years to satisfy Irish tax law (s.886 Taxes Consolidation Act 1997). After that period, payment records are anonymised.
- Credit-transaction audit log - retained for the life of the account, then anonymised when the account is deleted.
- Photographs - never stored. Held in memory only for the duration of the critique request, then garbage-collected.
- Server logs - retained by Vercel per their standard retention (typically 30 days).
Your rights
Under GDPR you have the right to access your personal data, correct it, ask us to erase it (the "right to be forgotten"), object to processing, request portability, and lodge a complaint with a supervisory authority.
To exercise any of these rights, email joe.houghton@gmail.com with a clear description of what you want. We'll respond within 30 days. If we need to verify your identity (to protect against unauthorised requests) we'll tell you exactly what we need and why.
The Irish supervisory authority is the Data Protection Commission. If you are resident in another EU member state, you may complain to your country's supervisory authority instead.
Children
Photo Panel is intended for users aged 16 and over (the minimum age for valid consent under the Irish Data Protection Act 2018). We do not knowingly collect personal data from anyone under 16. If you believe a child under 16 has created an account, email us and we will close it.
International transfers
Where data is transferred outside the EU/EEA (to Anthropic and Vercel in the USA, for example), we rely on the European Commission's Standard Contractual Clauses to provide an adequate level of protection.
Feedback widget
The Feedback button at the bottom of every page sends your message, any screenshots you attach, and (optionally) the email address you supply to Joe Houghton by email. Feedback is not stored in a database. If you supply an email address it is used only to write back to you about your feedback - it is not added to any mailing list.
Changes to this notice
We may update this privacy notice from time to time. Substantive changes will be notified by email to your account address at least 14 days before they take effect.
Contact
For anything about this notice, contact Joe Houghton at joe.houghton@gmail.com.