Privacy Policy

Who We Are

Photoczaro is the trading name of portrait and editorial photographer Hatim Champeli, operating as a sole proprietor based in Dubai, United Arab Emirates. We provide portrait photography, editorial photography, fashion shoots, virtual photography sessions, and related creative services to clients in Dubai, across the UAE, and internationally.

For the purposes of UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), Photoczaro acts as the Data Controller: the entity that determines how and why personal data is processed.

Legal Framework

This Privacy Policy is drafted in compliance with the laws of the United Arab Emirates. The principal legislation governing how we handle your personal data and photographic images includes:

UAE Personal Data Protection Law (PDPL)

Federal Decree-Law No. 45 of 2021 is the UAE's primary data protection legislation. It governs the collection, storage, processing, disclosure, and cross-border transfer of personal data. This law grants individuals specific rights over their personal information and imposes clear obligations on data controllers.

UAE Cybercrime Law

Federal Law No. 5 of 2012 on Combating Cybercrimes (as amended by Federal Decree-Law No. 34 of 2021) criminalises the unauthorised capture, storage, or publication of private images without the consent of the subject. Photoczaro strictly complies with these provisions: we will never share, publish, or use photographs without the subject's explicit prior consent.

Right of Portrait: UAE Civil Transactions Law

Federal Law No. 5 of 1985 (as amended) recognises every individual's right to their own image as part of their personal rights. Publishing or displaying a person's likeness without their consent constitutes a violation of personality rights and may give rise to civil liability under UAE law.

Dubai Media City & Content Standards

Photography in Dubai is subject to community standards enforced by the UAE National Media Council. Content that is considered indecent, defamatory, or contrary to public morals under UAE law will not be published by Photoczaro, regardless of any other consent given.

Data We Collect

We collect only what is necessary to provide our services and operate our website. The categories of personal data we process are:

Data You Provide Directly

• Identity data: your name, social media handle, or professional alias
• Contact data: email address, phone number (where provided)
• Communication data: messages sent to us via email, Instagram DMs, or the website contact form
• Booking data: session type, preferred dates, location preferences, project brief
• Consent records: signed model release forms, email confirmations of consent, and records of any usage restrictions you specify

Photographic & Creative Data

• Photographs and videos taken during your session: these are personal data when they identify you
• Image metadata (EXIF) embedded in raw files, including camera settings, date, and location data where GPS was enabled
• Session notes: creative direction, mood references, and post-processing instructions

Website Data (Collected Automatically)

• Usage data: pages visited, time on page, referral source
• Technical data: IP address, browser type, device type, operating system
• Analytics data: collected via Google Analytics 4 (anonymised where possible)
• Cookie data: session preferences, language redirect cookie (pcz_redir)

We do not collect sensitive personal data (as defined under the PDPL) such as health data, financial account details, biometric data, or racial/ethnic origin unless explicitly required for a specific service and consented to in writing.

How We Use Your Data

Service Delivery

• Scheduling and confirming photography sessions
• Communicating about session details, creative briefs, and deliverables
• Delivering edited photographs and creative assets
• Processing model releases and consent documentation

Portfolio & Publication

• Displaying selected images on photoczaro.com (with your consent)
• Submitting editorial work to magazines and publications (with your consent and as detailed in Section 8)
• Sharing images on Photoczaro's social media accounts (with your consent)

Website Operations

• Analysing website traffic to improve content and user experience
• Detecting and preventing fraudulent or abusive access
• Serving the correct language version of the site based on your browser settings

Legal & Administrative

• Maintaining records of consent and usage agreements
• Complying with UAE legal and regulatory obligations
• Resolving disputes or enforcing agreements

Lawful Basis for Processing

Under the UAE PDPL, we must have a valid lawful basis to process personal data. The bases we rely on are:

Consent (Article 4, PDPL)

Where we ask for your agreement before using your data or your likeness: for example, before adding your photographs to our portfolio, posting on social media, or submitting to a magazine. Consent must be freely given, specific, informed, and unambiguous. You may withdraw consent at any time (see Section 14).

Contract Performance (Article 4, PDPL)

Processing necessary to fulfil a photography booking or service agreement with you: including scheduling, shooting, editing, and delivering your images.

Legal Obligation (Article 4, PDPL)

Where UAE law requires us to process or retain data: for example, retaining financial records or responding to a valid request from a UAE regulatory authority.

Legitimate Interests (Article 4, PDPL)

Where processing is necessary for our legitimate business interests: such as website analytics to improve user experience, or maintaining records of past collaborations: provided those interests are not overridden by your rights and interests.

Photography & Image Rights

This section addresses image rights: who owns the photographs, how they may be used, and what protections exist for subjects.

Copyright Ownership

Under UAE Federal Law No. 38 of 2021 on Intellectual Property Rights, the copyright in every photograph created by Photoczaro vests exclusively in the photographer (Hatim Champeli / Photoczaro) at the moment of creation. Clients and subjects do not acquire copyright simply by being photographed or by paying for a session.

Clients receive a licence to use the delivered images for the agreed purpose (personal, portfolio, editorial, or commercial), as defined in the booking agreement or model release. Ownership of the copyright remains with Photoczaro.

Right of Personality & Image

Your image is a personal right. We will never publish, share, or commercially exploit photographs of you without your explicit prior consent, in compliance with UAE Civil Transactions Law and the UAE Cybercrime Law. This applies regardless of the context in which the photograph was taken.

Credit & Attribution

When Photoczaro's images are shared, published, or displayed: by clients, magazines, or collaborators: the following credit is required: Photography: Hatim Champeli / @photoczaro_portraits (or as specified in the release). Removal of watermarks, EXIF author metadata, or attribution notices without written permission is prohibited.

Retouching & Editing Rights

Photoczaro retains the right to creatively process, edit, and retouch images in accordance with its artistic style. We will not publish retouched images that materially misrepresent a subject's appearance in a harmful or defamatory manner. Subjects may request that specific retouching approaches not be applied to their images: please raise this before or during your session.

Prohibition on Reverse Use

Clients and subjects may not use session photographs in any way that:

• Attributes the work to a different photographer
• Creates the impression of endorsement of a product or service without separate written commercial consent from Photoczaro
• Violates UAE content and public decency standards
• Is used in AI training datasets, generative model inputs, or synthetic media without separate written consent

Model Consent & Release

Every collaboration begins with a clear, written agreement about how images will be used. This is both a legal requirement under UAE law and a fundamental principle of ethical photography.

Pre-Session Consent

Before or at the time of a photography session, subjects are asked to confirm the intended use of the images. This is captured through a model release form (physical or digital), an email confirmation, or an equivalent written agreement. The release will specify:

• The type of use permitted (personal portfolio, website, social media, magazine, commercial)
• Whether the subject's name may be disclosed alongside the images
• Any specific exclusions the subject wishes to apply
• The duration of the licence (indefinite by default unless otherwise agreed)

Scope of Consent

Consent is specific to the agreed use. Publishing images in a context materially different from what was consented to: for example, using portrait work in a commercial advertising campaign without a commercial release: requires a separate written agreement.

Right to Withdraw Consent

You may withdraw consent for future use of your images at any time by contacting us in writing. Withdrawal of consent does not affect:

• Uses that have already taken place prior to your withdrawal
• Images already published in printed magazines or physical exhibitions (which cannot be recalled)
• Processing carried out on another lawful basis, such as contract performance or legal obligation

Upon valid withdrawal, we will cease using the relevant images in new posts, listings, or submissions as soon as reasonably practicable, and will remove images from photoczaro.com upon request within 30 days.

Collaborative Shoots (TFP / Test Shoots)

For time-for-portfolio (TFP) collaborations, both parties agree in advance on the images to be produced, their intended use, and any exclusions. TFP participants consent to portfolio and social media use by Photoczaro in exchange for receiving edited images for their own portfolio use. Commercial exploitation by either party requires a separate written agreement.

Publication & Editorial Use

Photoczaro works with international fashion, portrait, and lifestyle publications. This section sets out how editorial submissions are handled.

Magazine Submissions

When we submit work to a magazine or editorial publication, we share the relevant photographs with the publication's editorial team. We will not submit photographs featuring identifiable individuals to a publication without their prior consent. Where consent has been given for "editorial use," this covers submission to and publication in print and digital magazines.

Publication Credits

We include accurate model and collaborator credits in every editorial submission. If a publication omits or alters credits, Photoczaro is not liable: however, we will pursue correction where possible. Subjects who have concerns about credits in a published work should contact us directly.

Exclusivity

Some publications request an exclusivity period before or after publication. Subjects will be informed of any exclusivity commitment that affects when their images can be shared elsewhere, and exclusivity will not be granted without the subject's agreement where it materially affects their own use of the images.

Retrospective Objection

If a subject objects to a published editorial after the fact, we will work in good faith with the publication to request removal. However, we cannot guarantee removal of printed materials or third-party digital archives that are outside our control. Prevention: through clear consent before submission: is always preferable.

Collaboration Terms

These principles apply to all creative collaborations: including sessions with models, stylists, makeup artists, designers, and creative directors.

Mutual Respect

All collaborators are entitled to a professional, safe, and respectful working environment. Any conduct during a shoot that makes a collaborator uncomfortable should be communicated immediately. Sessions can be paused or terminated by any party if this standard is not maintained.

Session Recordings

Behind-the-scenes photographs or video recordings made during a session by any collaborator must be agreed in advance. Recording the session without consent of all parties present may constitute a violation of UAE Cybercrime Law.

Image Selection & Delivery

Photoczaro selects the images to be edited from each session. Unless otherwise agreed, not all frames from a session will be delivered. Raw files are not delivered as standard: this may be negotiated separately and will be reflected in the written agreement.

Social Media Tagging

Collaborators who share session images on their own social media accounts are encouraged (but not obligated unless agreed) to tag @photoczaro_portraits and credit the photographer. Collaborators may not use session images in paid advertising or sponsored content without a separate commercial licence.

Non-Disclosure

Where a session involves an unreleased brand campaign, upcoming publication, or confidential creative project, all parties agree to keep the project details confidential until the agreed release date. Violation of confidentiality may constitute a breach of contract under UAE law.

Cancellation & No-Show Policy

Any personal data collected in connection with a booking that is cancelled by the client will be retained for a reasonable period (see Section 13) and then deleted, unless required for legal or accounting purposes. Cancellations do not automatically invalidate any previously signed model release.

Minors

The protection of minors is an absolute priority. The following rules apply without exception.

• Photoczaro will not photograph anyone under the age of 18 without the explicit written consent of a parent or legal guardian, who must be present throughout the session.
• Photographs of minors will not be published on photoczaro.com, social media, or submitted to any publication without separate, specific written consent from the parent or guardian.
• Consent provided for images of a minor by a parent or guardian may be withdrawn at any time. Upon valid withdrawal, all publicly accessible images of the minor will be removed within 14 days.
• Photoczaro does not knowingly collect personal data from minors through the website. If we discover that a minor has contacted us without parental knowledge, we will delete the communication upon becoming aware of it.

Data Sharing & Third Parties

We share personal data only where necessary and with appropriate safeguards in place. The categories of recipients are:

Publications & Magazines

Editorial photographs (and associated model credits) shared with magazine editors as part of a submission. This occurs only with the subject's prior consent for editorial use.

Cloud Storage & Delivery Platforms

We use professional file delivery services (such as WeTransfer, Google Drive, or similar) to share edited images with clients and collaborators. These services are used in accordance with their own privacy policies. Files are shared via password-protected or time-limited links where possible.

Website & Analytics Providers

• Cloudflare Pages (hosting infrastructure): processes request metadata for security and performance
• Google Analytics 4: collects anonymised usage statistics about website visitors. You can opt out via the Google Analytics opt-out browser add-on or by disabling cookies

Legal & Regulatory Authorities

We may disclose personal data where required by applicable UAE law, a court order, or a valid request from a UAE regulatory or law enforcement authority. We will, where permitted by law, notify you of such a disclosure.

Professional Advisors

Lawyers, accountants, or insurers who are subject to professional confidentiality obligations and who require access to data in connection with providing services to Photoczaro.

We do not share personal data with social media platforms beyond what is implicit in posting published images (where consent has been given). We do not sell, trade, or rent personal data to any third party for commercial purposes.

International Transfers

Some of the third-party services we use are operated by companies outside the UAE. When personal data is transferred outside the UAE, it is subject to the cross-border transfer provisions of the UAE PDPL (Article 22).

We take the following steps to protect data transferred internationally:

• Using service providers located in countries or regions with adequate data protection standards
• Ensuring contractual protections are in place where data is transferred to providers in other jurisdictions
• Minimising the personal data included in international transfers to what is strictly necessary

By submitting a booking enquiry or engaging in a session with Photoczaro, you acknowledge that your data may be processed by our third-party providers operating in other countries, in accordance with this policy.

Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by UAE law.

• Photographs and creative files: Retained indefinitely as part of the photographic archive, unless the subject exercises their right to deletion (subject to any overriding lawful basis for retention)
• Model release forms & consent records: Retained for the lifetime of the permitted use, plus 5 years, to protect against future disputes
• Booking and communication records: Retained for 3 years from the date of the session
• Financial and accounting records: Retained for 5 years as required by UAE Commercial Transactions Law
• Website analytics data: Retained in aggregated, anonymised form; individual session data retained per Google Analytics retention settings (default: 14 months)
• Unanswered enquiries: Deleted within 12 months if no booking results

When personal data is no longer needed, it is securely deleted or anonymised so that it can no longer be linked to an individual.

Your Rights

Under the UAE PDPL, you have the following rights regarding your personal data. You may exercise any of these rights by contacting us at info@photoczaro.com.

We will respond to all rights requests within 30 days of receipt. This period may be extended to 60 days for complex requests, in which case we will notify you of the extension and the reason for it.

We may need to verify your identity before fulfilling a request to ensure we are disclosing or amending data belonging to the correct individual.

Cookies & Analytics

Our website uses a small number of cookies and similar technologies. We keep this minimal.

Strictly Necessary Cookies

• pcz_redir: stores whether your browser has already been redirected to your language version of the site. Duration: 7 days. No personal data is encoded in this cookie.

Analytics Cookies (Google Analytics 4)

We use Google Analytics 4 to understand how visitors interact with photoczaro.com. GA4 collects:

• Pages visited and time spent
• Referral source (how you arrived at the site)
• Device and browser type
• Approximate geographic location (country/city level, derived from IP: the full IP address is not stored)

GA4 data is processed by Google and subject to Google's Privacy Policy. You can opt out of GA4 tracking by installing the Google Analytics Opt-out Browser Add-on or by disabling JavaScript.

Managing Cookies

You can control and delete cookies through your browser settings. Disabling the analytics cookie will not affect your ability to use the website. Disabling the language redirect cookie may cause you to be redirected on each visit.

Security

We take reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• HTTPS encryption across photoczaro.com (enforced at the Cloudflare layer)
• Secure cloud storage for client images with access controls
• Password-protected or time-limited file delivery links
• Restricted access to client data: only Hatim Champeli has access to personal data held by Photoczaro
• Regular review of third-party service providers' security standards

No method of electronic transmission or storage is completely secure. In the unlikely event of a data breach that poses a risk to your rights, we will notify you and the relevant UAE authority as required by the PDPL.

Website Terms of Use

This section covers the general terms of using photoczaro.com, separate from the photography-specific consent and collaboration terms set out above.

Acceptable use

You may browse and use this website for its intended purpose: viewing our portfolio, reading the Journal, and enquiring about or booking a photography session. You agree not to scrape, copy, or republish site content or images without permission, attempt to gain unauthorised access to any part of the site, or use the site in a way that could damage, disable, or impair it.

Intellectual property

All photographs, text, and design on this website are the property of Hatim Champeli (Photoczaro) unless otherwise licensed or credited, and are protected by UAE and international copyright law. No content may be reproduced, distributed, or used commercially without prior written permission.

No warranty

This website and its content are provided "as is". While we take reasonable care to keep information accurate and the site available, we do not guarantee it will be error-free, uninterrupted, or fit for a particular purpose.

Limitation of liability

To the extent permitted by UAE law, Photoczaro is not liable for indirect or consequential loss arising from your use of this website. Nothing in this section limits liability that cannot lawfully be excluded under UAE law.

Governing law

These terms are governed by the laws of the United Arab Emirates, consistent with the legal framework set out in Section 2.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable UAE law. When we make material changes, we will update the effective date at the top of this page.

We encourage you to review this policy periodically. Continued use of our services or website after an update constitutes acceptance of the revised policy. Where changes significantly affect how we use photographs or personal data obtained under a prior version of this policy, we will seek fresh consent where required.

Version history

• 22 July 2026 — Current version. Added a dedicated Website Terms of Use section and this version history.

Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact us:

UAE Data Protection Office

If you are not satisfied with our response to a complaint, or if you believe we have violated your rights under the UAE PDPL, you have the right to lodge a complaint with the UAE Data Protection Office:

We take all privacy concerns seriously and aim to resolve any issue within 10 business days of receipt.