Privacy Policy

Trace Studio 22 LLC, trading as Trace, is the data controller for the information described here. That means we decide what is collected and why, and we are the ones you can hold to account for it.

You can reach us about anything on this page through our contact page, which lists a dedicated route for privacy and data requests.

Trace is registered in Tbilisi, Georgia, and Georgia's Law on Personal Data Protection applies to us directly. If you use Trace from the EU, the EEA or the UK, you also have the rights the GDPR gives you, and we honour them in the same way.

Trace Studio 22 LLC is listed in Georgia's public company registry. For our registered address, write to legal@traceart.site.

Questions about your data go to privacy@traceart.site, and are answered within 30 days.

When you create an account:

• -your email address - used to sign you in and contact you
• -a username and a name, made from your email or taken from Google if you sign in with it; your username is public, and you choose whether your name is shown
• -your Google profile picture, only if you sign in with Google and have not chosen one of your own

You can sign in with a one-time link sent to your email, with Google, or with a passkey. You can also choose a password, when you join or later in Settings. We store only a scrambled (hashed) form of it, never the password itself. A passkey leaves only a public key with us; the private part never leaves your device.

When you use Trace: the work you list, the posts, comments and messages you write, the communities and exhibitions you join, who you follow, and what you collect. Most of this is content you are deliberately publishing.

If you sell work: the details needed to pay you and to meet tax and anti-fraud obligations, plus shipping addresses for the works you send.

Automatically: your IP address, browser and device type, and basic logs of pages loaded and errors hit. We use these to keep the service working and to investigate abuse.

When you were last active: while a Trace page is open, it tells us you are still there. We keep only the time of your latest visit, not a history of them. Only the Trace team sees it, to know who is around and to decide whether a reminder email makes sense.

If a gallery invites someone to an exhibition by email before they are on Trace, we keep that email address with the invitation and use it only to send it. If the invitation is never answered, nothing else is done with it.

Phones and cameras write details into every photo: when it was taken, the camera and lens, the settings, and sometimes where. When you upload a photo, Trace reads these details from the original on your device and keeps them privately, in our own database.

The photo that appears on Trace is a clean copy with all of these details removed. They are never shown on Trace, and never published, sold or shared. The one exception is yours to make: if you tick “Print the date on it” when adding a photo of an exhibition, the day it was taken is printed in its corner, like an old film camera.

We keep the date, camera, lens and settings for every photo, together with a fingerprint of the file. We keep where a photo was taken only if you agree to it. You are asked once, on your first upload, and you can upload either way.

We use these details only to:

• -keep a work’s history - when a piece existed
• -confirm who was at an exhibition
• -show an exhibition’s photos in the order they were taken
• -notice when the same image is uploaded twice, including by someone who is not its owner
• -understand and improve how Trace works, for example by suggesting people who were at the same exhibition

We do not keep camera or lens serial numbers.

Our lawful basis is legitimate interests for the date, camera and settings, and your consent for location. You can withdraw that consent at any time in Settings → Your photos. Withdrawing it also deletes the locations already kept. When a photo is deleted from Trace, its details are deleted with it.

We do not sell your personal data. We do not share it with advertisers or data brokers. There is no advertising on Trace, so there is no ad profile of you to build.

We do not use your personal data or your artwork to train machine-learning models.

We never see or store your full card number or bank credentials. When payments are introduced, they will be handled by a regulated payment provider that collects those details directly.

We use a small number of providers to run Trace. Vercel hosts the application. Neon stores account and content data in a database. Cloudflare stores uploaded images and media, in its EU jurisdiction, and handles our domain and incoming email routing. Resend sends our sign-in and notification emails. PostHog, only if you agree to it, records how Trace is used (see Seeing how Trace is used). Anthropic answers questions asked in the Trace Guide: we send it your question, the page you are on, and your @username if you are signed in, so please do not put private details in it. GitHub runs our nightly backup job, which stores the copies in Cloudflare's EU jurisdiction.

A video or song from YouTube, Vimeo, Spotify or SoundCloud in a post shows as that site's own picture of it until you tap play, so your phone fetches that one picture from the site. Only when you tap play does that site's player load, and from then on that site's own privacy policy applies to it. When someone posts a link, Trace reads the linked page's title, description and picture once, and keeps a copy of that picture, so a link card does not send your visit to the linked site while you scroll.

Payments are not live on Trace during the beta. Before any payment is taken, we will name our payment provider here and update this policy.

If you are in the UK, EU or EEA, the GDPR requires us to have a lawful basis for each use. Ours are:

• -Performing our contract with you - running your account, showing your work, processing sales and payouts
• -Legal obligation - tax records, anti-money-laundering checks, responding to lawful requests
• -Legitimate interests - keeping the platform secure, investigating fraud and abuse, and fixing faults; we balance these against your rights and use the least data that works
• -Consent - for anything optional, such as marketing email. You can withdraw consent at any time, and doing so is as easy as giving it

Trace uses cookies strictly necessary to keep you signed in and to keep the platform secure. We do not use advertising or cross-site tracking cookies. If you agree to analytics, PostHog keeps an id for this browser in its storage; saying no removes it.

Most of what you do on Trace, such as who you follow, the posts you save, the communities you join, and your uploads and profile, is stored on our servers against your account, so it is there when you sign in from another device. A small amount of interface state, such as display preferences, stays in your browser, is not sent to us, and disappears when you clear your browser storage.

The spaces that are not open yet, such as eARTh, Frequency, TraceVision and studios, still keep what you do in them in your browser only. When each one opens, its data moves to your account and this page will say so.

Only if you say yes, Trace records how you use it, so the team can see what works and where people get lost: which pages you open, what you tap, roughly where you are (the country and city your connection comes from), your browser and device type, and recordings of the screen as you move around. We use PostHog for this, on its servers in the European Union.

What is never recorded: anything you type (every field is hidden in recordings), your email address or name, and anything inside Messages, the Trace Guide, Settings or the team's own pages. PostHog knows you only by your account number and your @username, so the team can see who was active and what they did.

You are asked once in each browser. You can change your answer at any time in Settings, under Help us improve Trace. Saying no stops it at once and forgets this browser's analytics id. Recordings are kept for at most 30 days, other analytics for at most a year.

Our lawful basis is your consent. Nothing is recorded before you give it.

Some emails come with having an account: sign-in links, and messages about things that need you, such as an invitation or a reply waiting.

A few are reminders: a note a few days after joining if your profile is not set up yet, a nudge when someone mentioned you and it is still unanswered after a day, and, after two weeks away, one note about what is waiting for you. Every one of these has an Unsubscribe link at the bottom, and your mail app shows an unsubscribe button next to the sender. One tap stops all of them, without signing in.

Notifications you turned on, in the app or on your phone, you can turn off in Settings at any time.

Your messages are seen by you and the person you write to. The Trace team does not read them, with one exception: if someone in a conversation reports it, the team can read that conversation, and only that one, to decide what to do. Each time it is opened, that is recorded with who opened it.

Anything you publish - your profile, listings, posts, comments in public communities - is visible to other people on Trace, and public profiles may be visible to anyone on the internet. Posts in closed or invite-only groups are shown only to that group's members.

Owning a work is different. Every artwork keeps a public record of its history, but you decide how you appear in it, separately for each piece you own: by name, as "Private collection" with your city, or as "Private collection" alone. Private is the default - you are never named publicly unless you choose to be - and you can change it at any time. The record of the sale stays intact and verified either way; only whether it carries your name changes.

To be clear about what that setting does and does not do: it controls what other people see. Trace itself always knows who owns a piece, because we cannot ship a work, release an escrowed payment, settle a dispute or meet anti-money-laundering and tax obligations without knowing. That knowledge is also what makes an anonymous entry worth anything - "Private collection" means we verified the sale and chose not to publish the name, rather than that nobody knows. We treat owner identity as sensitive, restrict who inside Trace can see it, and use it only for those purposes.

Behind the scenes we share data with service providers who process it only on our instructions and under contract: our hosting provider, our payment processor, our email provider, and shipping carriers for works being delivered.

We may disclose data where the law compels us to, or where it is necessary to protect someone's safety. If we ever receive a government request for your data, we will tell you unless we are legally forbidden from doing so.

If Trace is ever acquired, your data may transfer to the buyer - who would remain bound by this policy until you are told otherwise and given a chance to leave.

Account and profile data is kept while your account is open. When you close it, your profile and content are removed from public view immediately and deleted within 30 days.

Some records outlive that: transaction and tax records are kept for the period the law requires (typically 6-7 years), and records of serious violations are kept long enough to stop banned accounts simply being recreated.

Every night we back up the database and the uploaded files. Each backup is kept for up to 31 days and then deleted, so something you delete can stay in a backup for up to 31 days. Backups are private and used only to recover from mistakes or failures.

Wherever you live, you can ask us to:

• -show you what we hold about you
• -correct anything wrong
• -delete your data
• -give you a copy in a portable format
• -stop or limit a particular use, including anything based on legitimate interests

We will respond within 30 days and will not charge you or make your experience worse for asking. If you think we have handled your data badly you can complain to a regulator - your national data protection authority if you are in the UK, EU or EEA, or the Personal Data Protection Service of Georgia, which supervises us directly. We would rather you came to us first.

Trace is available internationally, so your data may be processed in a country other than your own. We are established in Georgia, which the European Commission has not issued an adequacy decision for - so where personal data moves from the UK, EU or EEA to us or to our providers, we rely on Standard Contractual Clauses (and the UK Addendum) to protect it.

You can ask us for a copy of the safeguards we have in place for any particular transfer.

Our database is hosted in Frankfurt, Germany, and uploaded images and media are stored in Cloudflare's EU jurisdiction. Our sign-in and notification emails are sent from Ireland. Vercel, which runs the application, is a United States company and may process data in the United States as well as in the EU. Our team also accesses this data from Georgia. Anthropic, which answers Trace Guide questions, and GitHub, which runs our backup job, are United States companies. PostHog, which records how Trace is used if you agree to it, keeps that data on its servers in the European Union; PostHog Inc. is a United States company. If you choose to sign in with Google, Google, a United States company, handles that sign-in and shares your name, email address and profile picture with us.

Trace is not for under-16s, and selling work requires you to be 18. We do not knowingly collect data from children. If you believe a child has an account here, tell us and we will remove it.

When you join, we ask your month and year of birth once. We do not keep the answer: we keep only the fact that you are old enough. If the answer is under the minimum age, the account is deleted straight away with everything in it.

If we change how we use your data in a way that materially affects you, we will tell you by email and on the platform at least 30 days before it takes effect - not quietly update this page.

You can reach us about your data at privacy@traceart.site.