PORTRAIT
Contact
Privacy notice
Written from the system as it is actually built. Last updated 16 September 2026.
1. Who is responsible
The data controller is Portrait – Simone Pasqua, Via Marco Celio, Bologna, Italy. Write to info@portrait.bio for anything about your data.
2. The short version
- If you join the launch wishlist, we keep your email address to write to you once, when PORTRAIT is released, and then delete it.
- To give you a licence we store your name, institution, email address and country, and the licence key we issue.
- PORTRAIT sends basic technical diagnostics and crash reports, which you can switch off. They never include your images, file names, measurement results or location. Sharing which features you use is off unless you switch it on.
- Your images and your results never leave your computer, unless you yourself connect PORTRAIT to a database server of your laboratory's choosing.
- We use no advertising, sell no data, and set no cookies on this website.
3. What we collect, and why
3.1 When you join the launch wishlist
| Data | Why | Legal basis |
|---|---|---|
| Your email address, when you gave it, the page you gave it on, and the version of this notice you were shown | To write to you once, when PORTRAIT is released, and to be able to show that you agreed to it | Your consent (Art. 6(1)(a) GDPR), given by submitting the form |
| An invisible field that people cannot fill in | To ignore automated submissions | Legitimate interest in protecting the service (Art. 6(1)(f)) |
You can withdraw your consent at any time by writing to info@portrait.bio; we then delete your address. Otherwise it is deleted once the launch email has been sent.
3.2 When you register on portrait.bio
| Data | Why | Legal basis |
|---|---|---|
| Full name, institution, email address, country | To issue a licence to a named person and support it | Contract (Art. 6(1)(b) GDPR) — the licence, free in its first year, is an agreement between us |
| The licence key issued to you | So you can activate PORTRAIT, and so a lost key can be sent again rather than replaced | Contract (Art. 6(1)(b)) |
| Your IP address, and the signals the Cloudflare Turnstile check reads in your browser | To stop automated registrations | Legitimate interest in protecting the service (Art. 6(1)(f)) |
| Time spent on the form, and an invisible field that people cannot fill in | Same — a form filled in faster than a person can read it, or with that field filled, is refused | Legitimate interest (Art. 6(1)(f)) |
Your IP address is kept for at most 48 hours, only as part of a counter that limits how many registrations one network can make per hour and per day.
3.3 When you activate and use PORTRAIT
| Data | Why | Legal basis |
|---|---|---|
| A one-way code derived from your computer's hardware identifier (a SHA-256 hash; the identifier itself is never sent) | To bind the licence to one computer at a time | Contract (Art. 6(1)(b)) |
| Activation date, last contact date, number of times the licence has moved to another computer | To operate and support the licence | Contract (Art. 6(1)(b)) |
PORTRAIT contacts the licence server only at activation, about 60 and 30 days before the licence expires, after it has expired, and when you ask it to check for a renewal. The rest of the year it does not connect at all.
3.4 Password recovery
| Data | Why | Legal basis |
|---|---|---|
| The email address of each PORTRAIT account, with the account name and the one-way code of the licence it belongs to | To email a one-time code when someone forgets their password | Contract (Art. 6(1)(b)) |
| A one-time code (stored only as a hash), and when it expires | To check that the person asking controls that mailbox | Contract (Art. 6(1)(b)) |
On a shared laboratory installation the administrator enters their colleagues' addresses, and is told in the application that they must inform those colleagues. Passwords are never sent to us and are never stored by us: they stay in the laboratory's own database.
3.5 Diagnostics
| Level | What is sent | Legal basis |
|---|---|---|
| Basic diagnostics and crash reports (on by default; switch off in Settings › About › Privacy) | Application started or closed and session length, application version and operating system; a crash, with the error type only; a failed segmentation, with its stage and a coded reason (for example “no organoids found”); an image PORTRAIT could not open, with a coded reason and the file extension only | Legitimate interest in keeping PORTRAIT working (Art. 6(1)(f)) |
| Feature usage (off unless you switch it on, on first run or in Settings › About › Privacy) | Which pages you open, that an analysis, comparison, quality control or export was run, and summary numbers: the count of organoids, analysis duration, number of conditions; for an export, its format, the screen it came from, and whether it covered one result or several saved samples | Your consent (Art. 6(1)(a)) |
Switching basic diagnostics off stops every diagnostic event, feature usage included, and deletes the events still waiting on your computer to be sent. Events wait on your computer only while it is offline, at most the latest 5,000. The licence checks of §3.3 are not diagnostics and continue: without them the licence cannot work.
Diagnostics are identified by a one-way code derived from your licence key (SHA-256). They never contain your name, email address, licence key, images, file or folder names, or measurement results. This is enforced in the application, not only promised: every event and every value is checked against a fixed list before it is stored, and anything not on it is discarded. The IP address is discarded and no location is derived from it. Where the application is run from source code by a developer, nothing is sent.
3.6 Renewal reminders
About 60, 30 and 7 days before your licence expires we email you to say when it expires and how to renew. This is information about your licence (contract, Art. 6(1)(b)).
3.7 Payments
From the second year, if you pay by card, Stripe processes the payment and its own privacy notice applies to the payment data. We store your Stripe customer identifier, never your card details. Invoices and accounting records are kept as Italian law requires.
3.8 What we do not collect
Your images, your measurements, your analyses and your exported files stay on your computer. PORTRAIT has no mechanism to send them to us. If you use the Web server or Synced database modes, your data travels to the database server your laboratory configures — that server is under your laboratory's control, not ours, and your laboratory is the controller of that data.
4. How long we keep it
| Data | Retention |
|---|---|
| Launch wishlist | Until the launch email has been sent, or until you withdraw consent — then deleted |
| Registration and licence data | For as long as the licence is active, and 24 months after it last expired |
| Correspondence | As long as the registration or contact it belongs to |
| Diagnostics | 5 years, and deleted earlier if you ask us to delete your registration |
| Invoices and accounting records | 10 years, as Italian law requires (art. 2220 Civil Code) |
| IP-based registration counters | At most 48 hours |
| Server logs at Cloudflare | At most 7 days; they contain the licence's one-way code, never the name or institution |
5. Who receives it
No one buys or receives your data from us. It is processed by these providers, on our instructions and under a data processing agreement:
| Provider | What it does for us | Where |
|---|---|---|
| Cloudflare, Inc. | Delivers the website; stores the launch wishlist; hosts the licence server and its database; runs the Turnstile check | Wishlist stored in the European Union; licence database in Eastern Europe; website delivered from Cloudflare's global network |
| Amazon Web Services (Amazon SES) | Sends the email containing your licence key or password reset code | Ireland |
| PostHog, Inc. | Diagnostics, if you allow them | EU Cloud, Frankfurt (Germany) |
| Our email (Gmail / Google Workspace) | Google's global infrastructure | |
| Anthropic | IT services | United States; Anthropic Ireland Limited provides the service in the EU |
| Stripe Payments Europe, Limited | Card payments, from the second year | Ireland |
6. Transfers outside the EU
Some of these providers are US companies, or may give access to staff and sub-processors outside the European Economic Area. Each transfer is covered as follows:
- Cloudflare, Google, PostHog and Stripe are certified under the EU–US Data Privacy Framework, and their data processing agreements also include the European Commission's Standard Contractual Clauses.
- Amazon Web Services and Anthropic: the European Commission's Standard Contractual Clauses, included in their data processing agreements.
You can ask us for a copy of the relevant safeguards at info@portrait.bio.
7. Your rights
You can ask us to access, correct or delete your data, to restrict its processing, and to receive it in a portable format (Articles 15–20 GDPR). You can object at any time to processing based on legitimate interest, including basic diagnostics (Article 21). Where processing is based on consent — the wishlist and feature usage — you can withdraw it at any time, without affecting what was done before.
Deleting your registration also deletes your licence, so PORTRAIT stops working at its next contact with the licence server. We tell you this before we delete anything, and confirm by email once it is done.
Write to info@portrait.bio. We answer within one month. You also have the right to complain to a supervisory authority — in Italy the Garante per la protezione dei dati personali (www.garanteprivacy.it).
8. Cookies and the website
This website sets no cookies, uses no analytics or advertising, and loads no fonts or scripts from third parties. The one exception is Cloudflare Turnstile, on the registration pages only: it reads your IP address, TLS fingerprint and browser user-agent to tell people from bots, not to identify or profile you, and stores a single technical entry (cf.turnstile.u) in your browser's local storage for Cloudflare's domain. It is strictly necessary for the registration you asked for, so it needs no consent.
9. Automated decisions
None. A registration can be refused automatically as likely automated (§3.2); that has no legal or similarly significant effect, and writing to us resolves it.
10. Children
PORTRAIT is professional research software and is not directed at children.
11. Changes to this notice
We update this page when something changes, and change the date at the top.