Privacy Policy
Last updated: 2026
This Privacy Policy explains how Smiles & Tears Studio collects and processes personal data through this website, email, WhatsApp, Instagram, partner briefs, project communications and service delivery.
1. Data Controller
Smiles & Tears Studio is operated by Barys Rylou, an individual entrepreneur / sole trader registered in Portugal.
Tax identification number (NIF): 328245925
Business location: São Domingos de Benfica, Lisbon, Portugal
Contact email: hello@smilesandtears.studio
Full invoicing details may be provided to contracting clients where required for agreements, invoices and accounting purposes.
The controller is responsible for the collection and processing of personal data submitted in connection with inquiries, briefs, demos, orders and ongoing cooperation.
2. Personal data we may collect
- Business contact details, such as name, email address, phone number, company name, role and communication history.
- Project and event details, such as event type, date, language, mood, genre, deadline and production preferences.
- Personal stories, names, memories, phrases, photographs, videos, voice notes or other materials needed to create a personalized song or video.
- Billing and contract information required to issue invoices, manage agreements and comply with legal obligations.
- Technical data, such as browser type, device information, IP address, cookie preferences and website usage information where applicable.
3. Purposes of processing
We process personal data to respond to inquiries, prepare free partner demos, create personalized songs and videos, manage briefs and revisions, deliver final files, communicate with partners, issue invoices, maintain records, improve the website and protect our legal interests.
4. Legal basis under GDPR
Where the GDPR applies, we rely on one or more of the following legal bases: performance of a contract or pre-contractual steps, legitimate interest in operating and improving our business, consent where required, and compliance with legal obligations such as accounting and tax requirements.
5. Sensitive information
Clients should avoid submitting sensitive personal data unless it is truly necessary for the project. If sensitive information is intentionally included in a story, brief, photograph or video, the client confirms that it has the right to provide that information and that any necessary permissions have been obtained.
6. Sharing with service providers
We do not sell personal data. We may share limited data with trusted service providers when necessary for production, AI-assisted generation, editing, hosting, file delivery, communication, payment processing, analytics, website hosting, accounting or legal compliance. These providers may act as processors or independent controllers depending on the service.
7. International transfers
Some production, AI, cloud, communication or hosting providers may process data outside Portugal or the European Economic Area. Where required, we aim to rely on appropriate safeguards, such as adequacy decisions, standard contractual clauses or other mechanisms recognized under EU data protection law.
8. Retention
We keep personal data only for as long as reasonably necessary for the purposes described in this Policy. Project briefs and files may be retained for service delivery, revisions, partner cooperation, portfolio permissions, legal protection and accounting obligations. Data may be deleted or anonymized when no longer needed, unless retention is required by law.
9. Your rights
Depending on the situation and applicable law, you may have the right to request access, correction, deletion, restriction, portability, objection to processing, or withdrawal of consent. To exercise these rights, contact hello@smilesandtears.studio.
10. Complaints
You may also have the right to lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados (CNPD), or with another competent supervisory authority in the EU.
11. Security
We use reasonable technical and organizational measures to protect data against unauthorized access, accidental loss, misuse or disclosure. However, no online transmission or storage method can be guaranteed to be completely secure.
12. Children
Our services are intended for business clients and adult event professionals. If a project includes information, images or videos of minors, the client or partner is responsible for obtaining the necessary parental or legal permissions before submitting such materials.
13. Contact
For privacy questions or data requests, contact hello@smilesandtears.studio.