Privacy notice

EqualFrame is a trading name of The Rabbit Hutch Limited, a company registered in England and Wales. We are the controller of the personal data this notice describes, except where section 4 says we hold something for a studio. ICO registration no. ZC112489.

Write to us at privacy@equalframe.com about anything in this notice. A person reads every message.

Members of the register; people whose record a studio started, whether or not they have claimed it; people a studio invites to contribute to a project through EqualFrame; people on the early-access waitlist and people we invite to join; the people at a studio who deal with us; people who appear in, or are credited on, a photograph here; visitors to the site; and anyone who writes to us or reports something to us.

From you, when you apply, create or claim an account, write your record, upload photographs, answer a studio’s questions here, or write to us.

From a studio you work with. A studio can start a record for you and send us what it holds for that purpose, such as your name, email address, city and country, and sometimes a phone number, a short biography, links to your other accounts, a photograph, a reference to your application and your answers to its own questions. If a studio has started a record for you, you can claim it, change it, or ask us to erase it; write to us if you are not sure whether one exists.

From our systems, when you use the site: sign-in and security records, and technical logs.

From other people, for example when a member uploads a photograph you appear in or credits you on one, when someone reports a record, a photograph or a credit, or when someone writes to us about you.

Your account. Your email address; your password, stored only as a hash; any passkeys you register; your sign-in sessions, with the IP address and the browser description each one came from; and one-time links we email you, held as hashes until they expire or are used. When you change your email address we keep the previous one for a short period so that a change you did not make can be undone. If we invite you, we keep the address and the invitation.

Your record. What you or a studio put on it, such as your display name, pronouns, city and country, biography, the kinds of work you do, languages, experience, how you prefer to be paid, links to your other accounts, your physical details and measurements, and your postcode if you give it. Some of this is held apart from your public page and shown only as your record explains. We also hold your choices about the record, such as whether it is shown and whether it is listed in member search. Your record does not need your legal name, your date of birth or your home address. If our team records a contact detail, your legal name or your date of birth because running the register needs it, that is held with the restricted parts of your record.

Your photographs. The image files you or a studio upload, and what we derive from them to prepare and check them; the ratings described in section 7; whether an image has cleared our checks; the confirmations you gave when you uploaded it (for example that you hold the rights to it); and any credits attached to it. Depending on your camera or phone, an image file can also record when and where it was taken. We remove that information, and the rest of the camera data in the file, when a photograph is uploaded. Photographs uploaded before we began doing this are being cleaned in the same way; until that is finished, the information may still be readable in some older photographs.

Age checks. Before you can show or see age-restricted work, we will ask you to confirm you are over 18. When we do, the check is run by a specialist age-assurance provider, on its own service, acting as our processor for the check under a contract with us. Section 15 names the provider. When you start a check, we tell the provider only which country’s check to use. We work that out from your IP address, because the rules and methods differ by country; that is our legitimate interest, and we don’t keep the country. We then send you to its check, you choose a method from those it offers, and you give it only what that method needs, such as an image of your face or your email address. The provider tells us whether you are over 18 and which method was used. We keep that result, the date, a reference to the check and a record that we showed you how the check works. We never receive or keep your date of birth, your documents or images of your face. If a method uses your face, that happens at the provider only if you choose it, and in most countries you can choose a method that does not. In Germany the check offers only a face scan, or reuse of an earlier check with the provider, and in Italy only a face scan or the provider’s double-blind method. You don’t have to use them, and everything else on your record works. A check a studio asks for is different (below). We do this to meet our legal duty to keep people under 18 away from age-restricted work and, where the law does not require a check, because we have a legitimate interest in doing so. The provider runs the check in the UK, or in the European Economic Area, which UK law recognises as protecting personal data adequately. If it, or a provider it uses, processes your data anywhere else outside the UK, it does so under safeguards recognised by UK law. The page that sends you to the check names the provider. If the provider keeps anything for its own legal duties or purposes, such as preventing fraud, it does so as a controller under its own privacy notice, which its check shows you. If you are unhappy with how a check was handled, write to us; you can also complain to the Information Commissioner, as section 11 explains.

Age checks a studio asks for. If a studio you work with asks us to confirm your age before a contract, a release or a shoot, the provider’s check uses a photo of your ID matched to a selfie, so it does use your face. It is the same check wherever you are, so we don’t work out your country for it. For that check we rely on your express consent, which we ask for before you start. You can say no, and the studio can check your age another way. We tell the studio only whether your age was confirmed and, if it was, the method and the date, and we hold that record for the studio.

Identity checks. Where we ask you to verify your identity, a specialist provider runs the check on its own service. We share with it only what the check needs. It tells us the outcome and how the check was done, and we keep that, a reference to the check and a record that you agreed to it. We do not receive the documents or images the provider uses; if a check ever needs a person here to see one, the check will tell you before you start.

Studios. The link between you and a studio you work with, the copy of your details the studio sent when it started your record, the studio’s acceptance of our terms for handling data, and the names and email addresses of the people at a studio who deal with us.

What you give a studio through EqualFrame. Your answers to a studio’s application questions, and to a project it runs here (a contribution campaign), with a record of the wording you agreed to and when. We hold these for the studio: the studio is responsible for them and decides what they are for and how long they are kept, and we act only on its instructions. You can raise anything about them with the studio or with us. If you choose to use your own answer on your record, it becomes part of your record.

The waitlist. Your first name, email address, the role you chose, how you reached us, your referral code and who referred you, a queue position we calculate from those, your confirmation that you are 18 or over, and your consent to hear from us and whether you have withdrawn it.

Reports and messages. What you write to us, and reports or complaints about a record, a photograph or a credit, including from people who are not members.

Logs. A record of actions taken on the register (who did what, to which record, why, and from which IP address, including details of what changed); records of the emails we send and whether they were delivered; codes derived from email addresses that we use to avoid writing to someone too often or at all after they have asked us not to; technical logs of requests to our servers; and error reports from our software.

We use personal data for the four purposes below, each with the lawful basis we rely on.

Running the register. Holding your account and record, showing your record as you choose, letting a studio you work with read it, letting members find and credit one another, choosing records and photographs to feature on the register, holding a record a studio started until you claim it or it is removed, contacting you about your account and your record, preparing images for the web, backing up, and giving you your data when you ask. Basis: our contract with you, the agreement to provide the register that you make when you create or claim an account. Where there is no contract yet, as with a record a studio started, the people in or credited on a photograph, or a studio’s own contacts, our legitimate interest in running the register the studio and its members use and in giving you the chance to take your record over.

Keeping it safe and lawful. Checking photographs before they are shown to others, keeping age-restricted work away from people who should not see it, verifying age or identity where we need to, keeping a record of actions on the register, restricting or suspending accounts, honouring requests not to be contacted, investigating reports, preventing abuse, and reporting unlawful material to the authorities. Basis: our legal obligations, and our legitimate interest in a register people can trust. An age check a studio asks for rests on your consent instead (section 4).

Telling people about EqualFrame. Writing to the waitlist about joining and about the register, and telling members about EqualFrame. We use photographs from your record to promote EqualFrame outside the register, for example on social media, only with your agreement. Basis: your consent. We send members news about EqualFrame only if they have agreed, or where the law on electronic marketing allows it and we offered a simple way to refuse when we collected their address. Every such message lets you stop them. Withdrawing consent stops future use and does not undo what was done before.

Running and developing the business. Understanding how EqualFrame is used, improving it and developing new features, fixing faults, keeping the service secure, keeping the minimum evidence we need to show that a consent was given or a use was permitted, meeting our accounting and legal duties, and establishing or defending legal claims. Basis: our legitimate interests, balanced against yours, and our legal obligations.

Information about you that the law treats as sensitive. We do not need it to run your record, and we do not use photographs or anything else to work out your health, beliefs, ethnicity or other sensitive characteristics. If you choose to add such information to your record in your own words, we hold it on the basis of your express consent, which you can withdraw at any time by removing it or writing to us. Where a studio’s own questions ask for it, the studio is responsible for that answer, and we keep it for the studio only if you gave the consent the question asks for.

What you have to give us. Nothing on your record is required by law. We need your email address and a password to open an account, and the details a check or a studio needs to do what you ask. Without them we cannot provide that part of the register.

We do not sell your personal data. We do not share it with anyone for their own marketing. We use no advertising networks and no tracking pixels. We count visits to our public pages without cookies (section 12). We make no decision about you by automated means alone that has a legal or similarly significant effect on you; if a check ever works that way, it will tell you so, and you can ask a person to review its result.

Photographs are checked by software before they can appear on a public page or to other members, and the photographs we deliver are also scanned for known unlawful material. An image classifier, which today runs on our own private server and keeps no copy of the image, rates each image by the audience it suits: general viewing, or an age-restricted level. Where it is unsure, it chooses the more restricted level, and an image it cannot check stays unshown. Which images a page may show depends on these ratings, on the rating you gave, and on who is looking.

These checks decide which audience an image may reach, not anything about you as a person. If you think an image has been rated wrongly, write to us and a person will look at it.

Your record’s public page is public. While your record is shown, anyone who has its link can see it and the photographs cleared for it, including services that show a preview of a link, and you choose what it shows. While EqualFrame is in early access, we ask search engines not to list records.

Other members can find a record by its name to credit someone on a photograph, but only a record its owner has chosen to list in member search. Member search, which also finds records by city, lists your record only if you have chosen to be listed.

A studio you work with can read your record while that access lasts. You can end it from your account page. A studio that sends you photographs can see whether you have opened and downloaded them.

Our team can see records, including the parts your public page does not show, when running the register or keeping it safe needs it, and we keep a record of the actions they take.

Providers who work for us, under contract: for example, hosting for our website, application and database; storage, delivery and checking of photographs; sending email; age and identity checks; counting visits to our public pages; error reporting; and monitoring that the service is up. Most act only on our instructions. Some, such as an age-check provider, also have legal duties of their own, and their own privacy notice, which we point you to before you use them. Section 15 names our age-check provider and the service that counts visits, and says how to find out who the others are.

Professional advisers, such as lawyers and accountants, where we need their advice.

Authorities and child-protection bodies, where the law requires it or where material is unlawful.

A buyer, investor or successor, and their advisers under a duty of confidence while they consider it, if EqualFrame or its business is sold, invested in or reorganised. A buyer or successor would hold your data under this notice.

Our database, our application servers and our photograph storage are in the United Kingdom and the European Union. Some providers in section 8, for example for web hosting, email and error reporting, may process data outside the UK and the EU. Where they do, we rely on safeguards recognised by UK law and, where it applies, EU law, such as adequacy decisions or approved contract terms. Write to us for details.

We keep your account and record for as long as you have them. One-time links and sign-in sessions are deleted after they expire. A record a studio started is kept until you claim it, the studio asks us to remove it, you ask us to erase it, or we decide it is no longer needed. What we hold for a studio is kept for as long as the studio instructs, and answers the studio marks for a set period are removed when it ends. Photographs a studio sends you through EqualFrame are kept until the latest retention date of the model releases linked to them, or for seven years from the shoot if none is linked, unless they are removed sooner. Waitlist entries are kept until you ask us to erase them or the waitlist is wound down; taking yourself off the list stops our messages but keeps the entry until you ask us to erase it. Invitations, reports, complaints and messages are kept for as long as we need them to deal with the matter and any claim that could follow. We keep the result of an age check for as long as you have your account, and the record that we showed you how the check works for six years after you close it. If a studio asked for the check and it confirmed your age, the studio keeps a record of that, with the method and the date, for seven years from the check, including after you close your account, so that it can show it checked your age before working with you; we hold that record for the studio. Logs are kept for as long as we need them to keep the service secure and working.

When you close your account, we erase your account details, your record and your photographs. We keep only what we need to show what was done and why, or to meet a legal duty: the record of what you consented to and when; codes we use to honour a request not to be contacted; a note that a studio once held a link to you, without your details; a studio’s record that your age was confirmed, as above; a waitlist entry with your name and email address removed; the log of actions on the register, which can include past details of your record and the IP addresses actions came from; and anything we must keep to deal with unlawful material or a legal claim. We keep the log for as long as we need to show what was done and why, and for any period the law requires. Copies in backups, logs and caches are not edited one by one; they are replaced or expire in the normal course, and a record page can take a short while to stop showing after it is closed.

To see what we hold. Members can download a copy of their record and account data from the account page. For anything it does not include, or if you are not a member, write to us.

To correct it. Edit your record at any time, or write to us.

To erase it. Members can close their account from the account page. Anyone else, including people on the waitlist, people whose record a studio started and people who appear in or are credited on a member’s photograph, can write to us. Section 10 says what remains.

To take it with you. The same download, in a machine-readable form.

To object, or ask us to restrict what we do. Write to us, and in particular to object to anything we do on the basis of our legitimate interests.

To stop marketing. You can tell us at any time to stop using your data to tell you about EqualFrame, and we will stop.

To withdraw consent. Use the link in any message we send on that basis, or write to us.

For what we hold for a studio, you can go to the studio or to us, and we will pass your request on. We answer within one month; if a request is complex we may take up to two months more, and we will tell you. You can complain to the Information Commissioner’s Office at ico.org.uk. We would rather you wrote to us first, at privacy@equalframe.com.

We set only essential cookies: to keep you signed in, to keep the register secure and let your browser load the images you are allowed to see, and to remember your cookie choice. Details are in our cookie policy.

Counting visits. We count visits to our public pages, such as the home page and the application form, to see how people find the register and where they stop. The service we use sets no cookie and stores nothing on your device; its script checks one setting in your browser, used only to switch counting off, and never sends it. It counts only our public pages, the application form and the sign-up and sign-in pages, whether or not you are signed in, never a record, your account or anything you edit. It receives the page’s address without the part of a link that can carry a code (a campaign tag such as the source of an advert can stay), the site you came from, your browser and device type, how far down the page you scroll and how long it is open, that you started and sent the application form and whether you chose model, creator or studio, and your IP address, which it uses only to work out your country, region and city and to tell one day’s visits apart, and does not keep. We see totals only. Our basis is our legitimate interest in knowing how people find and use EqualFrame. To be left out, choose “Don’t count me” on the cookie notice or in our cookie policy. Section 15 names the service.

EqualFrame is for people aged 18 and over. We do not knowingly hold data about anyone younger, except what we need to refuse or close their account and to protect them, and we close any account we learn belongs to someone under 18.

We update this notice as EqualFrame changes; the date at the top is the date of this version. If we make a significant change to how we use data you already gave us, we will tell you before it takes effect, by email or on the site.

This section names the age-check provider that section 4 describes and the service that counts visits (section 12). We update it before a new provider starts running checks for us, and the page that sends you to a check names the provider it sends you to. For any other provider in section 8, write to us and we will tell you who it is.

Age checks: VerifyMy. When we ask you to confirm your age, including for a studio, VerifyMy runs the check as our processor. We sign a contract with it before it runs any check for us. Where it keeps anything for its own legal duties or purposes, it is a controller for that part. It is based in the UK and runs the check in the European Union, on servers in Belgium.

When we work out your country for an age check, we use IP geolocation by DB-IP, under its Creative Commons Attribution 4.0 licence. The lookup runs on our own servers, so DB-IP does not see your address.

Counting visits: Plausible Analytics. Plausible counts visits to our public pages for us as our processor, under its data processing agreement, which applies from the day we start using it. It is a company based in the European Union and keeps the data on servers in Germany.

This section was last changed on 10 November 2026.

From 10 November 2026 sections 6, 12 and 15 say that we count visits to our public pages without cookies, with Plausible Analytics, and how to be left out. From 4 November 2026 section 4 says that when you start a check we tell the provider which country’s check to use and how methods differ, and section 15 names our country data source. From 3 November 2026 section 10 says how long photographs a studio sends you are kept, and section 8 says what the studio can see. From 27 October 2026 a new section 15 names the provider that runs our age checks and says where it runs them; before that, section 4 named it (from 18 October) and said where it runs the check (from 21 October). From 25 October 2026 the notice makes clear that a check runs only when we ask you for one, and says how a check a studio asks for differs and how long the studio keeps its record of it (sections 4, 5 and 10). From 18 October 2026 it says what we keep from an age check and for how long (sections 4 and 10). This notice used to cover the early-access waitlist only. From 26 September 2026 it covers everyone whose data we hold, including members and people a studio has brought to us.