90 Day Challenge · 90DC B.V.
Effective Date: April 1, 2025 · Version 1.0
Important: This document explains how 90DC B.V. collects, uses, and stores the progress photos you upload in the 90 Day Challenge app. Please read it carefully before uploading any photos. Your consent is voluntary and can be withdrawn at any time.
1. What we collect
When you choose to use the progress photo feature in the 90 Day Challenge app, you may upload photographs of yourself (“Progress Photos”). These may include:
Before-and-after photographs documenting your physical transformation
Photos in which your face and/or body may be clearly visible and identifiable
Photos accompanied by optional captions, dates, or other metadata you provide
Uploading progress photos is entirely optional. You are never required to upload photos to use the app.
2. How we use your photos
By consenting to this policy, you grant 90DC B.V. a non-exclusive, royalty-free licence to use your Progress Photos for marketing and promotional purposes. Specifically, we may use your photos for:
2.1 Marketing & Promotional Materials
Promotional campaigns, digital advertisements, and sponsored content
Before-and-after transformation features to illustrate the effectiveness of the 90 Day Challenge
Press releases, case studies, and brand storytelling
2.2 Digital Channels
Social media posts and stories (Instagram, Facebook, TikTok, and similar platforms)
The official 90 Day Challenge website and landing pages
Email newsletters and marketing campaigns
Paid advertising (e.g. Facebook Ads, Google Display, Instagram Ads)
In-app success stories and testimonial features
We will not sell your photos to third parties or use them for any purpose other than those described above without obtaining separate, explicit consent from you.
3. Where your photos may appear
Your Progress Photos may be displayed publicly or semi-publicly across the following channels:
Online & Social Media: Instagram, Facebook, TikTok, YouTube, Pinterest, and similar platforms operated by 90DC B.V.
Website: the90dc.com and any related subdomains or microsites.
Email: Marketing and newsletter emails sent to subscribers.
Paid Advertising: Sponsored posts and ads served across digital advertising networks.
In-App: As success stories within the 90 Day Challenge app.
Because photos may be shared on third-party platforms (e.g. Instagram), we cannot guarantee removal from those platforms after a post has been published. We will make commercially reasonable efforts to remove content upon a valid deletion request (see Section 5).
4. How long we keep your photos
We will retain your Progress Photos for as long as you maintain an account with the 90 Day Challenge app, or until:
You withdraw your consent (see Section 5), or
You request deletion of your photos, or
Your account is permanently deleted.
Upon a valid withdrawal or deletion request, we will remove your photos from our internal systems within 30 days. However, please note that photos already published on third-party platforms (such as Instagram or Facebook) may take additional time to be removed and are subject to those platforms’ own data retention policies.
Anonymised, aggregated, or otherwise non-identifiable data derived from your photos (e.g. general engagement statistics) may be retained for longer periods for analytical purposes.
5. Your rights
As a data subject under the General Data Protection Regulation (GDPR) and applicable EU/EEA law, you have the following rights regarding your Progress Photos:
5.1 Right to Withdraw Consent
You may withdraw your consent to the use of your Progress Photos at any time, without affecting the lawfulness of any processing carried out before the withdrawal. To withdraw consent, contact us at support@the90dc.com.
5.2 Right to Erasure (“Right to Be Forgotten”)
You may request that we delete your Progress Photos from our systems. We will process deletion requests within 30 days of receipt.
5.3 Right of Access
You may request a copy of the Progress Photos we hold about you, along with information on how they are being used.
5.4 Right to Rectification
If any information associated with your photos (e.g. name, caption) is inaccurate, you may request that we correct it.
5.5 Right to Object
You have the right to object to the use of your photos for marketing purposes at any time.
5.6 Right to Lodge a Complaint
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the supervisory authority in your EU/EEA member state. In the Netherlands, this is the Autoriteit Persoonsgegevens (AP): autoriteitpersoonsgegevens.nl.
6. Legal basis for processing
We process your Progress Photos on the legal basis of your explicit consent (Article 6(1)(a) GDPR). Because progress photos may reveal information about your physical condition, they may also constitute special category data under Article 9 GDPR. We therefore obtain your explicit consent before processing such data.
You are under no obligation to provide consent. Withholding or withdrawing consent will not affect your ability to use the core features of the 90 Day Challenge app.
7. Data security
90DC B.V. implements appropriate technical and organisational measures to protect your Progress Photos against unauthorised access, accidental loss, destruction, or damage. Access to your photos is restricted to authorised personnel only and is governed by our internal data protection policies.
8. Contact us
For any questions about this policy, to exercise your rights, or to withdraw your consent, please contact our support team:
Company: 90DC B.V.
App: 90 Day Challenge
Email: support@the90dc.com
Subject line: “Progress Photo Consent – [Your Name]”
We aim to respond to all data-related requests within 30 days.