Privacy
What we collect, why, who receives it, how long we keep it – and how you can withdraw your consent at any time.
1. Controller
The controller responsible for processing personal data on this website and in Project 001 is LUCERANTIS GROUP DOO ("we"). Company details (address, registration number, tax ID) are listed in the imprint. For any data protection request, use the contact form or the pages "My photo" and "Withdrawal".
2. Which data we process
Order and contract: first and last name, email address, country, optional phone number, chosen area, place number, price and currency, time of the order, the versions of the legal texts you accepted, every declaration you made (with time stamp), your optional message, and payment status and reference from the payment provider. Card or account details never reach us. Your photo: the live selfie taken in your browser, cropped to your face; the metadata of the camera frame are never uploaded. Your likeness is personal data. Website security: IP address, time and type of access, browser type, the approximate country derived from the IP address and a random session identifier.
3. Purposes and legal bases
Conclusion and performance of the contract – reservation, payment, photo review, production and application of the tile, confirmation and status emails, handling of withdrawals and complaints: Art. 12(1)(2) of the Law on Personal Data Protection (ZZPL). Public display of your likeness on the vehicle, and – only with separate tick boxes – of your photo, first name, country or message on the website: your consent, Art. 12(1)(1) ZZPL (see section 4). Accounting, tax and fiscal records: legal obligation, Art. 12(1)(3) ZZPL. Security of the website, prevention of abuse, rate limiting, error analysis and partner attribution: legitimate interest, Art. 12(1)(6) ZZPL. For buyers in the European Union the GDPR provides the equivalent bases (Art. 6(1)(a), (b), (c) and (f)). Providing the order data is necessary to conclude the contract; without them no place can be bought.
4. Display of your face on the vehicle – consent and withdrawal
Displaying your photo on the vehicle is based on your consent, which you give with a separate tick box before the order. Your photo is displayed from the moment the tile is applied until one month after the end of the public exhibition, at the latest 6 months after the end of the sales period. The sales period lasts 60 days from the first confirmed payment of the project; its exact end date is shown on the project page. If this period has to be extended, we will inform you by email in advance. You can withdraw your consent at any time, as easily as you gave it: on the page "My photo" (you receive an access link by email) or via the contact form. After a withdrawal we remove your tile from the vehicle without delay, delete the photo and every image generated from it, and stop any further processing. The withdrawal has no negative consequences for you and does not affect the lawfulness of the processing carried out before it. We keep a record of when you gave and when you withdrew your consent, as proof.
5. Live selfie and automated pre-check
The photo can only be taken live with your device's camera. Before you take it, a live check in your browser asks you to blink; this check runs entirely on your device, and nothing from it is transmitted or stored. For the live check and for centring the face, your browser loads program files from the content delivery networks jsDelivr and Google (storage.googleapis.com); your IP address is transmitted to these providers in the process. On upload an automated pre-filter (Amazon Web Services Rekognition, region Frankfurt, as our processor) checks that exactly one face is visible, estimates an age range and checks our photo rules. Nobody is identified, no biometric templates are created or stored, and no image is stored at AWS. The final decision on every photo is always made by a person. There is no automated decision with legal effect on you and no profiling.
6. Recipients and processors
We use the following service providers, who process data only on our instructions under a data processing agreement: Vercel Inc. (USA) – hosting and delivery of the website; Supabase Inc. (USA), with storage in a data centre in the EU – database and encrypted private photo storage; Amazon Web Services EMEA SARL (Luxembourg), region Frankfurt – automated photo pre-check; Resend Inc. (USA), sending via the EU (Ireland) – transactional emails; the printing and application partner we commission – it receives only the photo and the place number, never your name or email address. Payments are processed by a licensed payment institution or bank in the Republic of Serbia, named in the payment step before you pay; it is independently responsible for the payment data. Partners who promote the project (creators) never receive buyer data. Data are not sold and not passed on for third-party advertising.
7. Transfers to other countries
Photos and order data are stored in the European Union, which ensures an adequate level of protection. Some of our providers are US companies (Vercel, Supabase, Resend) and may access data from the USA, which does not offer an adequate level of protection in every respect. For these transfers we rely on the standard contractual clauses contained in the data processing agreements with these providers and, where applicable, on the EU-US Data Privacy Framework. You can request a copy of these safeguards via the contact form.
8. How long we keep data
Photo, tile file and the share images and videos generated from it: until the end of the display period (section 4), then deleted within 30 days – earlier if you withdraw your consent, withdraw from the contract, or if the photo is rejected and not replaced. Selfies that do not lead to an order (for example an unfinished purchase): deleted automatically within 24 hours. Order, contract and payment records and fiscal receipts: 10 years from the end of the year of the order, as required by accounting and tax law, then deleted. Records of consents and withdrawals: as long as the order records, so that we can prove them. Waitlist email address: until we have informed you about the start of sales, at the latest 12 months. Session identifiers expire after 7 days; server logs are deleted after 30 days at the latest.
9. Your rights
Under the ZZPL you have the right of access (Art. 26), rectification (Art. 29), erasure (Art. 30), restriction of processing (Art. 31), data portability (Art. 36) and the right to object to processing based on legitimate interest (Art. 37), as well as the right to withdraw a consent at any time. A message via the contact form is enough. You also have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik), Bulevar kralja Aleksandra 15, 11120 Belgrade, www.poverenik.rs. Buyers in the European Union may also contact the supervisory authority of their country.
10. Cookies
We only set cookies that are necessary to run the website and one cookie for partner attribution. No tracking, analytics or advertising cookies are used. Details are in the cookie policy.
11. Age
The offer is only for persons aged 18 or over. Only the buyer can be shown on the photo; photos of minors are rejected.
12. Security
All connections are encrypted. Photos are kept in encrypted, private storage and are only accessible to the people responsible for review and production. The database is protected against public access, administrative access requires two-factor authentication, and every access to sensitive data is logged.
13. Creator code
If you came through a partner's link or entered a creator code, we store this code with your order so that the partner can be credited. The partner only sees aggregate numbers, never your name, email or photo.
14. Changes
This notice is version 2026-10-17. If processing changes materially, we update this page and inform buyers by email.
Version 2026-10-17