Privacy policy

Last update: 2026-04-21

At Eterna we handle your data with the minimum necessary and with transparency. This document explains what data we collect, for what purpose, with whom we share it, and what rights you have.

1. Data controller

  • Legal name: Cabrera Feijoo Consulting
  • Tax ID: CHE-271.164.828
  • Address: Avenue Alexandre-Vinet 3, 1815 Clarens, Switzerland
  • General email: hello@eterna.dog
  • Privacy email: hello@eterna.dog

2. Data we collect

Depending on your interaction with us:

CategoryDataWhen we collect
Contact dataName, email, postal address, When you place an order
Payment dataLast 4 digits + card brand — we never access the full number (processed by Shopify/Shopify Payments)Purchase
Pet photoThe image you upload for the portraitWhen you create the portrait
Browsing dataApproximate IP, device type, pages visitedWhen visiting the site
Email preferencesNewsletter subscription emailIf you subscribe

3. Purposes and legal basis

PurposeLegal basis (GDPR)
Process your order, generate the portrait, print and ship itContract performance (Art. 6.1.b)
Order communications (confirmation, preview, shipment)Contract performance
Invoicing and accounting/tax obligationsLegal obligation (Art. 6.1.c)
Customer supportContract performance and legitimate interest
Newsletter and marketingConsent (Art. 6.1.a), withdrawable in one click
Aggregated site usage analysisLegitimate interest, pseudonymised data

4. What we do with your photo

Important for transparency. Your photo is processed as follows:

  1. It's uploaded encrypted (HTTPS) to our Cloudflare R2 storage (Europe region).
  2. It's sent to fal.ai (provider of the Flux Kontext model) to generate the portrait. fal.ai does not retain it for training; it's infrastructure-as-a-service.
  3. The generated portrait is stored with the order to enable reprinting or incident resolution.
  4. At 30 days from delivery, the original photo is automatically deleted. The generated portrait is kept for the contractual relationship duration + tax retention periods.

We never:

  • Train our own models with your photos.
  • Sell or share photos with third parties.
  • Publish your pet's portrait in our gallery without explicit consent.

5. Data sharing

Only with processors necessary to provide the service:

ProviderData sharedPurposeLocation
Shopify Inc.Order, payment, contact dataOnline store and payment gatewayIreland/EU + subprocessors
CloudflareIP, uploaded photo, generated portraitStorage and CDNEurope (R2 EU region)
fal.aiPhoto + prompt + portraitAI generationUSA (SCC agreement)
Gelato APSAddress + portraitPrinting and shippingEU (Norway + EU hubs)
Email provider (Klaviyo)Email + order dataTransactional emailsUSA (SCC agreement)

Each under GDPR data processing agreement.

6. International transfers

  • fal.ai, Klaviyo (USA): transfers made under EU Commission Standard Contractual Clauses (SCC).
  • Cloudflare, Shopify, Gelato: data mainly processed in EU; subprocessors with equivalent safeguards.

7. Retention

DataPeriod
Original uploaded photo30 days after order delivery
Generated portraitOrder lifetime + warranty (24 months after delivery)
Order and invoicing data6 years (tax obligation)
Newsletter emailUntil you unsubscribe
Technical logs (IP, user agent)12 months

8. Your rights

You have, at any time, the right to:

  • Access: know what data we hold.
  • Rectification: correct inaccurate data.
  • Erasure ("right to be forgotten"): ask us to delete your data when no longer necessary.
  • Restriction: ask us to pause processing while we verify something.
  • Portability: receive your data in a standard format.
  • Objection: object to processing based on legitimate interest.
  • Not to be subject to automated decisions: AI portrait generation is made at your request and under your supervision (you approve before printing); it's not a decision producing legal effects on you.
  • Withdraw consent to newsletter at any time (one click in email).

To exercise them, write to hello@eterna.dog. We respond within 30 days max.

9. Complaints

If you believe we don't handle your data correctly, you can complain to the supervisory authority:

  • Your EU country: your national data protection authority
  • Switzerland: Federal Data Protection and Information Commissioner (FDPIC), https://www.edoeb.admin.ch

10. Security

We apply reasonable technical and organisational measures:

  • HTTPS/TLS encryption site-wide.
  • Encrypted backups.
  • Access control to data (authorised personnel only).
  • Access log on personal data.

No measure is infallible. If we detect a breach with risk to your rights, we'll notify you within 72 hours.

11. Cookies

See cookie policy.

12. Changes

We update this policy when our practices change. The current version is published at https://eterna.dog/privacy. If we introduce substantial changes, we'll notify you by email (if you're a customer) or via a visible banner on the site.