Last updated: September 13, 2026
Portraitor ("we", "our", "us") is a service operated by Project Fifty4, which is the data controller for the information described here.
Registered address and company number to be inserted here.
You can reach us at admin@portraitor.ai about anything in this policy.
This policy explains what information we handle when you use portraitor.ai (the "Service"), why, and the choices you have. By using the Service you agree to the practices described here. If you do not agree to them, please do not use the Service.
Before any part of your conversation is transmitted, your browser removes names, email addresses and telephone numbers and replaces them with anonymous placeholders. This process takes place entirely on your own device. If it does not complete successfully, no data is transmitted and your payment is refunded automatically.
The redacted text is then transmitted to our servers and passed immediately to Google Gemini for the generation of your portrait. We do not store the content of your conversation. It is held in memory only for as long as generation requires, and is discarded once your portrait has been produced. It is not written to any database, backup or log.
The Service does not operate user accounts. You may purchase a single portrait as a guest, or purchase a Pass, which is an anonymous code granting a monthly allowance of portraits. A Pass is not associated with your name or email address, and we are unable to identify the person using one.
When you make a purchase, you give us your email address at checkout so that Stripe can issue your receipt and so that we can deliver your portrait. We pass it to Stripe and keep no copy of it. That address is held by Stripe and is not retained by us. We retrieve it from Stripe only at the point of delivery and do not copy it into our own records.
Payments are processed directly by Stripe. We receive confirmation of payment and a transaction reference only. We do not receive or store your card details at any time.
Your portrait history, comprising the conversations you submit and the results returned to you, together with the email address last used for billing or delivery, is stored within your own browser. While a subscription purchase is being completed, your browser also keeps a short record of it, holding the subscription reference and a single-use confirmation value so that your Pass code can still reach you if the page is reloaded; that record holds no card details, no email address and no Pass code. This information remains on your device and is not transmitted to us unless you choose to share it or enter the address at checkout. Clearing your browsing data for this site removes it permanently.
Our servers record IP addresses, browser type and times of access for security and diagnostic purposes, and we record technical faults in order to correct them. Where an IP address is retained in our fault records, it is stored in an irreversible form that allows us to establish whether a series of failures originates from one visitor or several, but does not enable us to identify that visitor. Retention periods are set out in section 7.
Data protection law requires us to identify a lawful basis for each purpose for which we process your personal data. Those bases are set out below.
| Purpose | Lawful basis |
|---|---|
| Processing your conversation in order to generate and deliver your portrait | Performance of a contract with you |
| Taking payment and maintaining the transaction record | Performance of a contract, and compliance with a legal obligation for the tax retention period |
| Maintaining server and fault records, and limiting abuse of the Service | Our legitimate interests in keeping the Service secure and available |
| Responding to your enquiries and to requests concerning your data | Compliance with a legal obligation |
We do not use your data for advertising, and we do not take automated decisions producing legal or similarly significant effects concerning you.
The following is a complete list of the third parties that receive your data, the data each receives, and the purpose for which it is disclosed. Each processes data under its own privacy policy.
| Who | What they receive | Why |
|---|---|---|
| Google Gemini Privacy Policy |
Your masked conversation text | Generates your portrait |
| Stripe Privacy Policy |
Your email address, card details, billing country | Takes payment, sends receipts, and holds the only copy of your email address |
| Google Analytics Privacy Policy |
Pages visited, referring site, device and browser type, approximate location. Never your conversation. | Shows us how the site is used so we can improve it |
| Hostinger Privacy Policy |
Everything that passes through the Service, plus your portrait and email address when we send it | Hosts the Service and sends your portrait by email |
| Google Fonts Privacy Policy |
Your IP address, when a page loads | Serves the typefaces the site is set in |
| Cloudflare Privacy Policy |
Your IP address, when a page loads. When you make a purchase, your email address and the details of that purchase, which pass through the payment gateway we run on Cloudflare. Your card details never pass through it, and never reach our servers either: they go from your browser directly to Stripe. | Serves one JavaScript library used to read chat export files, and routes payment requests to Stripe so that no payment credentials are held on our own servers |
Our payment processor's script is loaded on all pages of the site rather than on payment pages alone, and collects device information for the purpose of fraud prevention.
We use Google Analytics to understand how the site is used: which pages are visited, where visitors arrive from, and what kind of device and browser they use, together with an approximate location derived from the network address. Analytics measures your use of the site itself; it never receives your conversation, which is protected by the separate mechanisms described above. If you prefer not to be counted, Google's browser opt-out add-on prevents the analytics code from running, and blocking cookies for this site in your browser has the same effect. We use no advertising pixel and no session recording software.
We set the cookies that are strictly necessary for the Service to function, and Google Analytics sets cookies to measure how the site is used. We do not use cookies to advertise to you, whether on this site or elsewhere. You can prevent the analytics cookies through your browser's cookie settings or with Google's browser opt-out add-on.
| Purpose | Set by | Duration |
|---|---|---|
| Keeping your Pass active Allows your Pass to remain active as you move between pages, so that it need not be re-entered each time. |
Portraitor | Up to 30 days |
| Fraud prevention on payments Used by our payment processor to detect fraudulent activity. See Stripe's cookie policy. |
Stripe | Up to 1 year |
| Usage analytics Google Analytics cookies ( _ga and variants) distinguish visitors and sessions so we can see how the site is used. You can block them in your browser or with Google's opt-out add-on, as described above. |
Google Analytics | Up to 2 years |
Your portrait history is held in your browser's own storage rather than in a cookie, and is not transmitted to us.
| Data | Kept for | Reason |
|---|---|---|
| Conversation content | Not retained | Processed only for the duration of generation, then discarded |
| Your email address | Not retained by us | Held by Stripe. We access it to deliver your portrait and keep no copy |
| Your Pass | Retained indefinitely | Required to operate your monthly allowance and to permit a cancelled Pass to be reinstated. Contains no information identifying you |
| Payment records | 7 years | Required by tax law. No name, email address or card details |
| Technical fault records | 90 days | Diagnosing and correcting faults. IP addresses held in irreversible form |
| Server access logs | 30 days | Security and prevention of abuse |
| Payment confirmations | 30 days | Verifying that each payment is applied once and once only |
| Portraits held in your browser | Until you clear them | Stored on your device and under your control |
Depending on your country of residence, you may have the right to obtain access to your personal data, to have it corrected or erased, to receive it in a portable form, to object to certain processing, and to withdraw any consent you have given. The procedure for exercising each of these rights is set out on the Your Data Rights page. You may also write to us at admin@portraitor.ai, and we will respond within 30 days.
Because we operate no accounts and retain no email address, the scope of most requests is limited. The personal data associated with you is held by our payment processor and can be erased there on request. Your portraits reside on your own device and are not accessible to us.
You also have the right to lodge a complaint with a data protection supervisory authority. In the United Kingdom this is the Information Commissioner's Office. In the European Union it is the supervisory authority of your country of residence. We would encourage you to raise the matter with us first, but you are not obliged to do so.
All data in transit is encrypted using HTTPS. Pass codes are stored only in an irreversible form, so the code itself cannot be recovered from our records. No permanent copy of your conversation is retained on our servers, and we review our security arrangements regularly. No method of transmission over the internet is entirely secure, however, and we are therefore unable to guarantee absolute security.
Your redacted conversation is transmitted to Google's Gemini service for analysis. The use Google may make of that content depends on the terms under which the service is accessed, and we set our position out expressly below rather than leaving the matter to inference.
We access the Gemini service on its paid tier. Under Google's terms applicable to that tier, Google does not use your conversation to train or improve its models, and it is not reviewed by Google personnel for that purpose. Google does retain submitted content for a limited period for the purpose of monitoring misuse of its service, and we are unable to disable that retention. Google's terms are available here.
Your data may be processed outside your country, including in the United States where Google and Stripe operate. These transfers are protected by appropriate safeguards, including Standard Contractual Clauses.
The Service is not intended for anyone under 16. We do not knowingly collect data from children. If you believe that a child has provided us with personal data, please contact us and we will remove it.
We may update this policy from time to time. We'll post the new version here and update the date above. Continuing to use the Service after a change means you accept it.
Project Fifty4
Email: admin@portraitor.ai