Passportrait: ID Photo Maker
Last updated: 30 July 2026 · Version 1.1
The controller responsible for processing personal data in connection with the "Passportrait: ID Photo Maker" app is:
auronet GmbH
Labbéstr. 18
41169 Mönchengladbach
Germany
E-Mail: passportrait@auronet.de
Passportrait turns a photo into a passport, visa, or ID photo for the country and document type you choose: it separates you from the background, replaces the background with the required colour, aligns the crop to the official template, checks the geometry, and exports a digital file or a printable 4×6 / 10×15 sheet. Everything runs on your device. There is no backend and no cloud AI service — your photos never leave your phone. You can use the app without an account; no name, email, or sign-in is required.
The app is free to download. Capture, background removal, alignment, the compliance check, and a watermarked preview are free. Removing the watermark and exporting is a one-time in-app purchase — there is no subscription and there are no ads.
| Category | Examples | Where it lives |
|---|---|---|
| Photo content | The photo you capture or select, and the processed passport photo | On device only |
| Face measurements | Face landmarks, head height, eye line, crown position — computed to align and check the crop | On device only, transient (see §5) |
| Camera / photo library access | Used to capture or import a photo you choose | On device |
| App preferences | Recently used countries and document types, the purchase credit ledger, a pending-purchase record used to recover an interrupted unlock, your analytics choice, and the random analytics ID | On device only (local app storage; the analytics ID and your analytics choice are held in the system keychain / keystore) |
| Analytics events | A randomly generated app-local ID plus technical context added automatically by the analytics SDK — app version and build, OS name and version, platform, device manufacturer and model name, screen size, language and time zone — and feature events (e.g. screen viewed, country/format selected, capture completed, compliance passed, export succeeded with export type, paywall shown, purchase started / completed (with product, price and currency) / failed / restored / claimed, settings changed, error shown). PostHog additionally derives an approximate location (country/region level) from the IP address of the request; the IP itself is not stored on the event. No photos, no face data, no name or email, and no advertising or device identifier (no IDFA, IDFV, or Android Advertising ID) | PostHog (EU cloud) |
| Purchase data | Purchase / receipt status, entitlement status | App store / RevenueCat |
| Technical data | App version, OS version, crash reports collected by Apple or Google if you have enabled sharing in your device settings | On device / app store |
We do not upload your photos, build advertising profiles, run ads, or sell data. We do not require an account.
To align your head to a template and verify the required proportions, the app measures facial geometry — landmark positions, head height, eye line, head pose, and crown position. These measurements are computed on your device, held only in memory for the current editing session, and are never transmitted to us or to anyone else. We never receive them and cannot access them. They are not used to identify or recognise anyone, are not matched against any database, and are discarded when you finish or leave the session. Because this processing happens exclusively under your control on your own device, no biometric data is processed by us as controller.
We use PostHog on its EU cloud to understand which features are used and where people get stuck. Events carry no photos, no face measurements, no name, no email, and no advertising or device identifier — the only identifier is a random ID the app generates for itself on first launch, which is not linked to you and which we cannot connect to any other account or service. Alongside it, the analytics SDK attaches the technical context listed in §3 (app version, OS, device model, screen size, language, time zone), and PostHog derives an approximate country/region from the request IP. On Android the random ID is removed when you uninstall; on iOS it is stored in the system keychain, which the operating system may keep across a reinstall.
Screen-view events are sampled: a fixed share of installations (currently 25%, chosen by hashing the random ID) reports them and the rest never send them at all. All other events are recorded in full. You can turn analytics off at any time in the app under Settings → Share Usage Data. The switch takes effect immediately: no further events are sent, and on the next launch the analytics client is not started at all.
| Purpose | Legal basis |
|---|---|
| Producing your passport/ID photo (on-device) | Performance of a contract, Art. 6(1)(b) |
| Processing purchases & validating receipts | Performance of a contract, Art. 6(1)(b) |
| Usage analytics (feature adoption, funnel analysis) | Legitimate interest, Art. 6(1)(f) — opt out any time via Settings, see §6 |
| Stability, diagnostics, security | Legitimate interest, Art. 6(1)(f) |
Because image processing is on-device, we do not share your photos with anyone. The only external parties are:
Transfers outside the EU/EEA. Analytics events are processed in the EU. RevenueCat, Inc. is based in the United States, so purchase and entitlement data is transferred there; that transfer is covered by the EU standard contractual clauses in our data processing agreement with RevenueCat, supplemented by the EU–US Data Privacy Framework where RevenueCat is certified. Apple and Google process purchases under their own terms and transfer mechanisms.
Exports are unlocked by a one-time in-app purchase — a single-photo export credit, a lifetime unlimited unlock, or an extra-format purchase that re-solves an already unlocked photo for another country or document type. There is no subscription and no automatic renewal. Payment is handled by the app store; we do not receive full payment details (e.g. card numbers), only the purchase/receipt status needed to unlock the export. A previous unlock can be restored via Restore Purchases in Settings.
Under the GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), and to object to processing based on legitimate interests, including analytics (Art. 21). Because your photos and face measurements live only on your device, you control them directly — delete them or uninstall the app at any time. You can object to analytics directly in the app by switching off Settings → Share Usage Data. For anything else, contact passportrait@auronet.de — you can reach us from Settings → Contact Support.
You also have the right to lodge a complaint with a supervisory authority. The authority competent for us is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestr. 2–4, 40213 Düsseldorf, Germany (ldi.nrw.de). You may also complain to the authority where you live or work.
We do not carry out automated decision-making or profiling within the meaning of Art. 22 GDPR. The compliance check is a geometric measurement of the photo you supply; it produces no decision about you as a person, and its result is advisory only (see §2). You are not required to provide any personal data: the app works without an account, and analytics is optional — switching it off has no effect on any feature.
We have not appointed a data protection officer, because the criteria in Art. 37 GDPR and § 38 BDSG do not apply to us. Data protection enquiries reach us at the address in §1.
The app can be used to make photos of anyone, including babies and children, at the direction of the adult using it. The app itself is not directed to children under 16, and we do not knowingly collect data from children — photos and face measurements are processed only on-device and are never uploaded.
We may update this policy, for example when adding features or in response to legal changes. The current version is always available in the app and at this address.
© 2026 auronet GmbH · Passportrait: ID Photo Maker