AI Photobooth – Terms of Use and Privacy Notice (Comwrap Reply UK)

Who we are

· Service: The “AI Photobooth” is an event application that captures your photo on an tablet, sends it to an AI image processor to create a cartoon-style image and short avatar video, and optionally emails you the generated image if you provide an email.

· Provider: Reply Limited trading as Comwrap Reply (“we”, “us”, “our”), registered in England and Wales at [address]. Contact: [privacy@reply.com] for privacy matters; [t.asary@reply.com] for service issues.

· Role under data protection law: For the AI Photobooth, we act as an independent data controller. If we are running the booth solely on behalf of a specific client, we may act as a processor and the client will be the controller; where that is the case we will display the client’s name and contact details.

Eligibility and participation

· You must be 16 or over to use the Photobooth. If you are under 16, a parent/guardian must give consent on your behalf.

· By tapping “I agree” you accept these Terms and confirm the information you provide is accurate and that you have authority to grant the permissions in section 4.

· The Photobooth is for entertainment only. Do not use it to upload content that is illegal, offensive, or infringes others’ rights.

What you provide and what we produce

· You may provide: your name (required to personalise the output), your email (optional, used only to send you your generated image), and your photo (required to generate the avatar).

· We produce: a cartoon‑style still image and a short avatar video derived from your photo. Outputs are stylised and for fun; they are not intended to depict reality.

Permissions and intellectual property

· Users’ responsibility: the Photobooth is for entertainment purposes only. You are solely responsible for the content you choose to create, upload, or share, and for ensuring that your use complies with all applicable laws and regulations.

· Consent and Permissions: By using the Photobooth, the user declares and warrants that they have the necessary rights and permissions to upload any photo. This includes ensuring that, if the photo contains the image of another person, the user has obtained that person’s prior consent to upload, share, or otherwise use their likeness. The operator shall not be held responsible for any unauthorized use of third-party images.

· Restrictions: You shall not use it to upload content that is illegal, offensive, or infringes upon the intellectual property, privacy, or other legal rights of any third party. You are also forbidden to upload others’ photos without permission; attempt to reverse engineer or attack the system; generate content that is unlawful, hateful, defamatory, pornographic or infringes third‑party rights; or interfere with other participants’ experience. We may remove content or suspend the service to protect participants or comply with law.

· Event marketing (optional): With your separate, explicit consent (unticked by default), we and/or the event organiser may display your generated image/video on event screens or social channels. You can withdraw this consent at any time by contacting us; withdrawal does not affect prior lawful use.

Intellectual property

· Your content: You retain all rights in your photo and likeness. You grant us a limited, revocable, non‑exclusive licence to use your photo and likeness solely to generate your stylised image/video and to deliver the service (including temporary storage, transmission to our AI processor, and email delivery if requested).

· Our content: We (or our licensors) own the application and model assets used to generate outputs. We grant you a personal, non‑exclusive licence to use, download and share your generated image/video for your personal and non‑commercial use. For any commercial use, please contact us at t.asar@reply.com

These Terms do not limit liability for death or personal injury caused by negligence, fraud, or other liability that cannot lawfully be limited.

6. Liability Disclaimer

· Service availability and limitations: We aim to set up, run and dismantle the Photobooth during stated event hours. The service may be unavailable due to venue connectivity, maintenance, security requirements or technical faults. To the extent permitted by law, the service is provided “as is” and we exclude implied warranties of merchantability and fitness for purpose.

· No Warranties – While the system uses artificial intelligence to generate images, the results are produced automatically and may not always be accurate, appropriate, or reflective of reality. By using the Photobooth, you acknowledge and agree that we make no warranties, express or implied, regarding the accuracy, quality, or suitability of any generated images.

· No Liability – To the maximum extent permitted by law, we shall not be held liable for any claims, damages, losses, or consequences arising from the use or misuse of the Photobooth, including but not limited to reputational harm, infringement of third-party rights, or emotional distress. In any case, our liability total aggregate liability shall not exceed the amount of £ 10,000.

· Indemnification – You agree to indemnify and hold harmless us against any claims or liabilities resulting from your use of the Photobooth in violation of these terms.

Privacy Notice (UK GDPR)

What personal data we process

· Identification: photo/likeness; first name (or alias). We do not require your real name.

· Contact (optional): email address (if you want the image emailed to you).

· Technical: device/app logs (timestamps, IP address, error logs), minimal telemetry for security and performance.

· Safety filtering: automated scanning may flag unsafe inputs/outputs (e.g., nudity, hate symbols) for blocking. We do not perform facial recognition or biometric identification.

Purposes and lawful bases

· Generate your image/video and show it on the tablet and television: consent (UK GDPR Art. 6(1)(a)). Participation is voluntary.

· Email delivery of your image (if you provide email): performance of a contract/steps at your request (Art. 6(1)(b)) and our legitimate interests to operate the service reliably (Art. 6(1)(f)).

· Security, fraud/misuse prevention, service diagnostics (including temporary logging): legitimate interests (Art. 6(1)(f)) to keep the service secure and functional.

· Event marketing display of your generated image/video: consent (Art. 6(1)(a)). Separate opt‑in.

· If operating as processor on behalf of a named client: we process per the client’s documented instructions (processor variant).

Note on special categories/biometrics: We do not use your photo to identify you or to create biometric templates. The AI processing is for entertainment transformation only. We do not infer sensitive attributes.

Where your data goes (recipients and transfers)

· Within our group: authorised staff operating the booth and support teams with a need to know.

· Processors: reputable cloud hosting and AI processing providers under written contracts that include UK GDPR‑compliant terms. Some providers may be outside the UK/EEA; where they are, we use the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs plus additional safeguards.

· Email delivery: reputable email service providers for transactional messages.

Retention and deletion

· Raw input photo and intermediate files: deleted automatically within 24 hours of event close or generation (whichever is sooner), unless a longer period is needed to resolve a support issue you reported.

· Generated outputs on our systems (image/video): retained up to 30 days to allow you to re‑request delivery during the event period, then deleted.

· Email address (if provided): stored only for sending your image, then retained in sending logs for up to 30 days for troubleshooting and anti‑abuse, after which it is deleted or anonymised.

· Event marketing copies: where you opted in, your image/video used for displays/social posts may persist on those channels until removed; you can withdraw consent and request removal.

Your rights

You have the right to withdraw consent, and to request access, rectification, erasure, restriction, objection to processing, and data portability (where applicable). To exercise rights, contact [privacy@reply.com]. You also have the right to complain to the UK Information Commissioner’s Office (www.ico.org.uk).

Security measures

We apply proportionate technical and organisational measures, including:

· Encrypted transfer (TLS) to and from our AI processor and email services.

· Hardened, fully patched devices; endpoint protection; full‑disk encryption on event laptops/tablets.

· Access control with named, least‑privilege accounts; MFA for administrator access; secure secrets storage.

· Logging of security‑relevant events; regular deletion per section 7.4.

· Supplier due diligence and data processing agreements with our processors.

Contact details of the controller/DPO Controller:

Comwrap Reply, a trading company of Reply Limited
38 Grosvenor Gardens, London, SW1W OE

Data Protection Officer (or privacy contact): [privacy@reply.com]:

Mr Nigel Berragan
Reply Ltd
Nova South, 160 Victoria Street
Westminster
London
SW1E 5LB
dpo.uk@reply.com
07860182017

· Children: The service is designed for participants aged 16+. If you are 13–15, a parent/guardian must consent on your behalf at the booth. We do not knowingly collect data from children under 13.

· Complaints and disputes: Please contact us at contact details above to resolve any issues. These Terms are governed by the laws of England and Wales and the courts of England and Wales have exclusive jurisdiction, except that mandatory local consumer laws may also apply.

· Changes to this notice: We may update these Terms and the Privacy Notice for legal or operational reasons. The version and date will be shown on the tablet; material changes during an event will be communicated at the booth.