Privacy Policy

Last updated: 2026-10-09

1. Data Controller

2. Personal Data We Process

• Email address — account creation, authentication, transactional emails, newsletter (where consented)
• Name and username — optional profile information
• IP address — logged at login for security
• Authentication tokens — stored locally in your browser
• Data from third-party sign-in — if you sign in with Google, GitHub or Apple: your identifier at that provider, email address, name and, where the provider supplies them, username and profile picture. We receive these from the provider rather than asking you for them. We also store the access token the provider issues, which is used once during sign-in to retrieve those details.
• Signing in with Apple gives us no profile picture and no username, and Apple sends your name only on the very first sign-in. If you choose "Hide My Email", we receive a forwarding address at privaterelay.appleid.com instead of your own; your actual address stays unknown to us.
• Advertising identifiers — where consented (Google services)
• Usage statistics (Matomo) — when you visit our pages (mlcgo.eu and photoregistry.mlcgo.eu): page visited, time, referring page, browser, operating system, screen size and language, and your shortened IP address. We run Matomo ourselves; it sets no cookies, and the data does not leave our servers. On photoregistry.mlcgo.eu only the page is recorded, without search terms — identifiers you look up never reach the statistics — and a "Do Not Track" setting in your browser is respected.
• MLC Photo Registry (photoregistry.mlcgo.eu) — when you register photos as a photographer: your profile (display name, studio, contact), the public keys of your devices and, for each photo, the entry signed by your app. It contains the photo's identifier, the name entered in the app, the file name, the image size, the stated date and an image fingerprint (perceptual hash), plus the time it was received. Images are never transferred or stored. Publicly available are only the identifier, time received, key and verification level; display name, studio and contact only with your consent. The entered name, file name, image size, date and image fingerprint are never published, cannot be searched and are visible only to registry administrators resolving reports. For public lookups we briefly process the IP address to limit lookups per minute.

We do not process special categories of personal data (Art. 9 GDPR).

3. Legal Basis

• Art. 6(1)(b) GDPR — contract performance: processing your email and authentication data to provide the service. This includes third-party sign-in where you choose it.
• Art. 6(1)(f) GDPR — legitimate interests (security logging; cookieless usage statistics with shortened IP addresses to improve our service)
• Art. 6(1)(a) GDPR — consent (newsletter, advertising, publishing your profile in the MLC Photo Registry; revocable at any time in your account)
• Art. 6(1)(b) GDPR also covers the MLC Photo Registry: storing your keys and entries to link protected photos to their author.

4. Data Retention

• Account data: until account deletion. This includes the link to a third-party account and the details taken from it.
• Security logs: 90 days.
• MLC Photo Registry: profile, keys and entries until you request deletion (email to the address below). Withdrawn entries no longer appear in lookups but are kept as proof of the original registration. Encrypted backups are deleted after 90 days at most.
• Newsletter consent records: until unsubscription + 3 years.

5. Recipients

• Hosting: Strato AG, Pascalstraße 10, 10587 Berlin, Deutschland
• Email: Strato AG, Pascalstraße 10, 10587 Berlin, Deutschland
• Third-party sign-in (optional):
  • Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: policies.google.com/privacy.
  • GitHub, Inc., 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA (Microsoft Corporation). Privacy statement: docs.github.com/site-policy.
  • Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Privacy policy: apple.com/legal/privacy.
• Advertising (where consented): Google LLC. Privacy policy: policies.google.com/privacy. Opt out: adssettings.google.com.

We do not sell personal data.

6. Transfers to Third Countries

When you sign in with Google or GitHub, the sign-in takes place on that provider's servers. Your IP address and the fact that you are signing in to mlcgo.eu are therefore transferred to the United States. This cannot be avoided technically — it is the sign-in itself.

This does not apply to signing in with Apple. The contracting party is Apple Distribution International Ltd., based in Ireland; no transfer to a third country takes place.

These transfers rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework of 10 July 2023 (Art. 45 GDPR). Google LLC and GitHub, Inc. are certified under that framework.

Third-party sign-in is optional. You can instead create an account with an email address and password. If you do, no data is transferred to Google, GitHub or Apple in connection with signing in.

7. Cookies and Local Storage

Strictly necessary: When you sign in we set the session cookie mlcauth_token (valid for that domain only, HttpOnly, 60 minutes with automatic renewal, 12 hours at most) and store sign-in tokens in localStorage. Both are required for signing in and need no consent. Some pages also remember language and appearance (light/dark) in localStorage.

Usage statistics: Matomo runs without cookies and without browser storage.

Third-party sign-in: The provider may set its own cookies on its own domain to maintain your session there, which is outside our control.

Advertising cookies (where consented): Google AdSense may set cross-site tracking cookies. Withdraw consent via cookie settings.

8. Your Rights

• Access (Art. 15), Rectification (Art. 16), Erasure (Art. 17), Restriction (Art. 18), Portability (Art. 20), Objection (Art. 21), Withdraw consent (Art. 7(3)).

Contact: mlcgo.eu@michael-lechner.de. Response within 30 days.

9. Complaints

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Deutschland, poststelle@lda.bayern.de

10. Changes

The date at the top reflects the most recent version.

11. Contact

mlcgo.eu@michael-lechner.de