1. Who We Are
LumaGrid is a trading name of OGR Group Ltd, a company registered in England and Wales (company number 17258397). Our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. You can contact us at legal@lumagrid.uk.
LumaGrid is registered with the Information Commissioner's Office (ICO) as a data controller. Our ICO registration reference is C1968207.
2. What Data We Collect
Event Organisers & Clients
- Name, email address, phone number, billing address
- A keyed fingerprint of your IP address (a scrambled code, not the address itself), used to prevent fraud
- Payment details (processed by Stripe — we do not store card data)
- Event details: name, date, venue name and postcode
- Messages you send us from your event portal, and our replies
Event Guests (Uploaders)
- A scrambled (one-way hashed) version of your IP address and device, used to prevent abuse; we don't store the address itself
- Your reactions and comments, and an optional first name if you leave a comment
- Photographs uploaded to event galleries
- Voice messages, if the booth at your event offers them: a message of up to 30 seconds that you choose to record, kept with the photo the booth takes of you. Only the event's organiser can hear it; other guests can't. We clean up the sound (less background noise, an even volume) and keep only that cleaned copy. We never use it to recognise voices.
- Fun effects, if the booth at your event offers them: if you add one (a party hat, googly eyes, a new background), the booth finds the faces or the people in the photo to draw it, on the booth itself. This is only used to place the effect, then deleted. We never use it to recognise anyone. Only the photo you choose to keep is saved.
- Photo metadata (such as when and where a photo was taken, and the device). It is removed from every photo shown to other guests and the organiser; we keep the original file privately and delete it with the photo
- Automatic safety checks: every photo is checked for known child sexual abuse material (Microsoft PhotoDNA) and, on our own server, for nudity. A photo the nudity check flags is kept off the live screen (and, at most events, out of the gallery) until the organiser or our staff check it. It is never deleted or reported on that basis alone
People Who Report a Photo
- The report, the reason and anything you write
- A keyed fingerprint of your device, so the report button can't be misused
- For reports of child sexual abuse only: an email address, if you choose to give one, for the authorities (we never contact you)
Website Visitors
- We use Cloudflare for DNS, CDN, and security. Cloudflare retains server access logs independently for up to 30 days.
- We do not use third-party analytics or advertising trackers.
3. Why We Collect It & Legal Basis
Contract (Art 6(1)(b)): To provide the event photo service you have paid for — creating your gallery, enabling guest uploads, processing your download.
Legal obligation (Art 6(1)(c)): To comply with UK law — retaining evidence in connection with content reports, responding to lawful requests from the authorities, meeting OSA obligations.
Legitimate interests (Art 6(1)(f)): To keep events safe, to protect the platform from fraud and illegal content, to defend against chargebacks, and to maintain platform security.
4. How Long We Keep It
- Event photos: deleted when your package's download period ends, and erased from our systems within a few days. For Picta packages that is about a week after the event (Budget) or about two weeks (Upload). If the organiser bought “Keep your album longer”, one album file of the event’s photos is kept 1, 3 or 12 months longer for the organiser to download, then deleted.
- Voice messages: deleted with the event's photos.
- Fun effects: what the booth finds to place an effect is deleted on the booth straight away; the photo you keep is deleted with the event's photos.
- Organiser contact details: about 1 month after the event. Organiser accounts: 12 months after last use.
- Booking and payment records: 6 years after the end of the financial year, as tax and company law require.
- Reports: closed with no action, 30 days; action taken, 12 months (for the most serious, the removed photo is kept sealed for the same 12 months); passed to the authorities, 1 year, plus a log of the reference number with nothing personal in it for 6 years. Someone found to be misusing the report button: only that flag, for 12 months.
- Appeals: 12 months after the decision. Complaints and data protection requests: 2 years. Messages from your event portal: 12 months after the last message. Enquiries, records of emails we sent, and security logs: 12 months.
- Card disputes: if a payment is disputed, we may stop the email address used from booking again for up to 24 months, to prevent repeat fraud (legitimate interests). Ask legal@lumagrid.uk if you'd like it reviewed.
5. Who We Share Data With
- Cloudflare: Infrastructure provider (Workers, R2 storage, D1 database, CDN). Data Processing Agreement in place.
- Stripe: Payment processing. They are an independent data controller for payment data.
- Resend: Transactional email delivery (US-based).
- Microsoft (PhotoDNA): Every uploaded photo is checked against databases of known child sexual abuse material. Microsoft receives a digital fingerprint (hash) of the photo; in occasional fallback cases the photo itself is sent for the check. Provided under Microsoft's PhotoDNA Cloud Service terms.
- Hostinger: Hosts our email mailboxes, and a server we use to process photos and voice messages (safety fingerprints, our nudity check, thumbnails, album downloads, and cleaning up the sound of voice messages). Nothing is kept there after processing.
- Child safety: If we find suspected child sexual abuse material, we pass the relevant information to the National Center for Missing & Exploited Children (NCMEC), a child-protection organisation, and to the relevant authorities where the law requires.
- Legal requests: We only share data with the authorities when UK law requires it (for example under the Investigatory Powers Act 2016 or PACE 1984).
We do not sell your data. We do not share your data with advertisers.
6. Your Rights
Under UK GDPR you have the right to: access your data (Subject Access Request), correct inaccurate data, request deletion (where no legal obligation to retain applies), object to processing, and data portability. To exercise any of these rights, contact legal@lumagrid.uk. We will respond within 30 days.
Removing a photo. The quickest way to have a photo of you removed from an event is to ask the event organiser: they can remove any photo straight away. We are here if that doesn't work.
Parents and guardians can ask the event organiser to remove photos of their child. If asking the organiser isn't appropriate, use the Report button on the photo ("A child who must not be shown here"). The first few are removed straight away; if there are more, our team removes the rest, usually within one working day. If you can't open the gallery, email safety@lumagrid.uk with the event name.
If you are unhappy with how we handle your data, you can raise a complaint directly with us first via our contact form (select "Data Protection Complaint") or by emailing legal@lumagrid.uk — we will acknowledge your complaint within 30 days. If you remain unsatisfied, or would prefer to go straight to the regulator, you also have the right to complain to the ICO: ico.org.uk/make-a-complaint · 0303 123 1113.
6a. Children's Data
Our guest upload and gallery pages are likely to be accessed by children attending the events they relate to, so we have considered the ICO's Age Appropriate Design Code. We collect no account, profile, or behavioural data from any guest — including children — and we do not use tracking, advertising, or profiling of any kind. The only data involved is the event photos themselves and any reactions or comments; the only name asked for is an optional first name when commenting, which can be left blank. Photos are retained only for the limited periods set out above and are then permanently deleted. Photos only appear on a live screen after the safety checks have passed; the organiser can keep any photo off the screen at any time, and guests can choose to keep their own photo just for the organiser when they upload, so it stays off the screen and out of the general album unless the organiser chooses to share it.
7. International Transfers
Some of our providers (Cloudflare, Resend, Microsoft, Stripe and Hostinger) may process data outside the UK, and child-safety reports go to NCMEC in the US. Where data leaves the UK, we rely on the UK's adequacy regulations or the safeguards in each provider's data processing terms (such as the UK International Data Transfer Addendum).
8. Changes to This Policy
We will update this page when our practices change. Significant changes will be communicated by email to active account holders.
1. The Service
LumaGrid is a private event photo service. You book an event, your guests upload photos with a QR code or event link and the event keyword, and you can view and download them for the period your package includes. Galleries are keyword-protected and time-limited.
By booking an event you confirm you are at least 18 years old, that you have the authority to bind any organisation you represent, and that you have read and accepted these terms.
2. Your Responsibilities
- You are responsible for the event and the content uploaded through your event code.
- Share your event code and keyword only with your guests, not publicly.
- Take reasonable steps to keep prohibited content out of your event (see the Acceptable Use Policy), and remove anything that shouldn't be there. You can remove any photo straight away from your portal.
- Act on requests from guests, or from parents and guardians, to remove photos of them or their children.
- If you mark your event as 18+, the declaration you make must be true.
- You acknowledge that content uploaded through your event code may be passed to the relevant authorities without prior notice to you.
3. How We Keep Events Safe
- Every photo is checked automatically for known child sexual abuse material.
- Automatic software also checks photos for nudity. It can be wrong in either direction, so a photo it flags is held for you to review: you decide whether it is shown. It doesn't catch everything, so please still remove anything that shouldn't be there.
- Photos reach a live screen only after these checks. You can keep any photo off the screen at any time.
- Serious reports are removed straight away. We may pause access to an event where we need to keep someone safe or comply with the law.
- If we remove a photo, you can ask us to look again from your portal; we usually decide within 2 working days. Some removals can't be reversed, and we can't always give a reason.
- We may remove a photo, without notice or explanation, where this is needed to protect someone, including a child. A removal for safety reasons does not affect the service you have paid for.
4. Cancellations & Refunds
LumaGrid is a service. When you book, you ask us to start providing it straight away. You can cancel within 14 days of booking; once your package has been fully provided, the right to cancel ends. The full rules, and the price table used for part refunds, are in the Refund & Cancellation Policy.
5. Data Retention
Event photos are deleted when your package's download period ends (shown when you book). Download them before then: once deleted, they can't be recovered. We are not liable for photos lost because they weren't downloaded in time. If you bought “Keep your album longer”, your album download (one zip of your photos) is kept for the months you chose after that; the individual photos and the guest gallery still end on the normal schedule.
6. Platform Availability
LumaGrid is built on Cloudflare infrastructure and targets high availability. We do not guarantee 100% uptime. If an outage stops your event working as described, tell us and we will put it right or refund you under the Refund & Cancellation Policy.
7. Limitation of Liability
To the maximum extent permitted by law, our total liability to you for any claim arising from use of the service is limited to the amount you paid for the booking in question. We are not liable for indirect, consequential, or incidental losses. Nothing in these terms limits our liability for death or personal injury caused by our negligence, for fraud, or for anything else the law doesn't allow us to limit.
8. Complaints
If something isn't right, contact us through the contact form or at hello@lumagrid.uk and we'll try to put it right. If you're not happy with our answer, Citizens Advice (0808 223 1133) can help.
9. Governing Law
These terms are governed by the laws of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.
10. Changes to Terms
We may update these terms. The terms you accepted when booking apply to that booking; we will tell you by email about any material change that affects it.
Prohibited Content
The following content is strictly prohibited on LumaGrid. It will be removed, and may lead to the event being closed and referral to the relevant authorities where required:
- Child Sexual Abuse Material (CSAM) — any sexual image of a person under 18
- Content that facilitates the sexual abuse or exploitation of children
- Content promoting, glorifying, or facilitating terrorism or political violence
- Content depicting or facilitating serious violence or harm to individuals
- Non-consensual intimate imagery
- Pornography, sexually explicit images and images of genitals — at every event, including events marked 18+
- Content that is illegal under the laws of England and Wales
Comments
Comments are seen by everyone at the event. No web links, no hate or slurs at any event, and ordinary swearing only at events marked 18+. Comments that break these rules are not posted.
Voice messages
Messages left at a booth go only to the event's organiser. The same rules apply as everywhere on LumaGrid: nothing illegal, hateful or abusive. The organiser can delete or report any message.
Booth fun effects
Effects are for fun, chosen by you from the booth's menu. Do not use them on someone who does not want them. Anyone in a photo can ask for it to be removed.
Content Safety
We use Microsoft PhotoDNA to check every uploaded photo against known child sexual abuse material, normally within a minute of upload, and automatic software to check for nudity. We look at a photo only when it is reported or flagged by these checks, and suspected child sexual abuse images are never viewed: they are passed to NCMEC and the relevant authorities unseen.
Reporting Content
Every gallery photo has a Report button. Every report is recorded and checked, and the most serious are removed straight away. You can also contact safety@lumagrid.uk.
If you believe a crime has taken place, do not wait: contact the police on 101 (non-emergency) or 999 (emergency).