Data processing agreement

Last updated: 24 October 2026

This agreement under Art. 28 GDPR is concluded between the studio that creates an account with Envis (controller) and Fabio Michael Gell, Ottakringer Straße 180/12, 1160 Vienna, Austria (processor, hereafter Envis). It takes effect when the studio ticks the confirmation while creating its account; the time is stored with the account.

1. Subject matter and duration

Envis provides the studio with a web application to upload tattoo designs, generate customer links and receive its customers' snapshots and replies. Processing lasts for as long as the studio has an account with Envis.

2. Nature and purpose, data categories, data subjects

The purpose is previewing a tattoo design on the customer's body before tattooing, and the coordination about it between studio and customer.

Processed are: project label (usually a first name), body part and size, the design in all its versions, placements, snapshots (photos of the customer's body that the customer sends themselves), replies as text or reaction, a device identifier as a cookie, plus timestamps and view counters.

If the studio asks for a deposit on approval, this adds: amount, status and times of the deposit and the identifiers of the payment at Stripe.

Data subjects are the studio's customers and the people who operate the panel for the studio.

3. Instructions

Envis processes the data only on the studio's documented instructions. The studio gives instructions by operating the application (uploading, archiving, revoking a link) and, beyond that, by email to hallo@envis.at. If Envis considers an instruction unlawful, it informs the studio.

4. Confidentiality

Everyone at Envis with access to the data is bound to confidentiality. Customer data is accessed only for troubleshooting at the studio's request or to meet legal obligations.

5. Technical and organisational measures

Transport over TLS only. Database and image storage in Cloudflare's Western Europe region, stored encrypted. Images are reachable only through signed addresses with an expiry. Sign-in without passwords via one-time links; session and link tokens are stored as hashes only. Customer links are random with 80 bits of entropy, revocable and can be given an expiry. Access to production systems only through personal credentials kept in a secured keychain. Changes to projects are recorded in an event log.

6. Sub-processors

The studio approves the use of these service providers: Cloudflare, Inc. (running the application, database and image storage, region Western Europe), Supabase, Inc. (reports sent with “Problem or request” and appointments with Envis, Frankfurt data centre), Plus Five Five, Inc. (Resend; sending emails to the studio, region EU) and Stripe Payments Europe, Ltd. (payments of the studio to Envis and the payment page for deposits customers pay to the studio, Dublin; for a deposit Stripe receives the amount, the studio's name and an identifier of the deposit, and no designs, snapshots or replies). Envis has a contract under Art. 28 GDPR with each of them. Where a provider processes data outside the EU, this is based on an adequacy decision or the standard contractual clauses of the EU Commission. Envis announces a change or an additional provider by email four weeks in advance. If the studio objects within this period, it may terminate the contract as of the day of the change.

7. Supporting the studio

Envis supports the studio in answering data subject requests, in reporting personal data breaches (notification to the studio without undue delay, at the latest 48 hours after becoming aware) and, where relevant, in data protection impact assessments.

8. Deletion and return

The studio can archive projects; the customer link ends immediately. On instruction, Envis deletes individual projects or the whole account including images within 30 days. Before that, the studio can download its designs and snapshots from the panel.

9. Evidence

On request, Envis provides the studio with the information needed to demonstrate compliance with this agreement and allows reviews to a reasonable extent, with two weeks' notice.

10. Final provisions

Austrian law applies. Envis announces changes to this agreement four weeks in advance. The current text is available at envis.at/avv; the version confirmed when the account was created is sent on request.