StepHouse's Policy on the Use, Collection, and Management of Images

Last updated: July 2026

At StepHouse, we want to showcase the real life at our residences: activities, events, sports, socializing, trips, residents’ experiences, and moments that are part of our community’s daily life.

To that end, during certain activities we may take photographs, record videos, or collect other audiovisual content featuring residents, participants, employees, collaborators, or attendees. This policy explains how these images are captured, used, stored, and managed, as well as the rights of the individuals who appear in them.

 

1. Data Controller

The data controller for personal data related to the collection and use of images is:

STEPHOUSE STUDENTS SLU
Tax ID: B75323006
Registered office: Calle Villanueva 2B, Escalera 1, Planta SM, 28001 Madrid
Trademark: StepHouse

When an activity is organized in collaboration with another entity, residence, provider, university, agency, partner, or external collaborator, StepHouse may, where appropriate, disclose the involvement of such third parties in the organization or dissemination of the content.


2. What We Mean by "Image"

For the purposes of this policy, “image” means any photograph, video, audiovisual recording, screenshot, visual testimony, or similar content in which a person can be identified or is identifiable.

It may also include, where applicable, other elements associated with the image, such as the person's voice, name, place of residence, team, activity in which they are participating, or the context of the event.


3. Purpose of Using Images

StepHouse may collect and use images for the following purposes:

  1. Showcase life at StepHouse residences by highlighting activities, events, moments of togetherness, sports, residents’ experiences, and initiatives organized by the brand.
  2. Promote StepHouse activities and experiences, such as sports leagues, trips, welcome events, cultural activities, workshops, wellness activities, parties, training sessions, tournaments, and get-togethers among residents.
  3. Create content for digital and corporate channels, including social media, the website, newsletters, internal presentations, business communications, corporate materials, and marketing campaigns.
  4. Document activities and events, creating a visual record of participation and the progress of the activities organized by StepHouse.
  5. Strengthen internal communication by sharing content with teams at the residence, headquarters, ambassadors, coordinators, collaborators, and others involved in organizing the event.
  6. Create promotional materials for StepHouse, always within the context of residential life, the college experience, organized activities, and brand communication.

4. Channels where the images can be posted

The images may be published or used on the following channels:

  • StepHouse website.
  • StepHouse's official social media accounts, such as Instagram, TikTok, LinkedIn, Facebook, YouTube, or other similar platforms.
  • Newsletters, emails, and digital communications.
  • Digital advertising campaigns.
  • Corporate or sales presentations.
  • Printed or digital communication materials.
  • Videos summarizing activities or events.
  • Internal content for teams, residences, or collaborators.
  • Other corporate channels related to StepHouse's business.

StepHouse will not use the images for purposes unrelated to its business or in contexts that are offensive, discriminatory, or derogatory, or that could negatively affect the dignity, honor, privacy, or reputation of the people appearing in them.


5. Legal Basis for the Use of Images

The collection and use of images will generally be based on the consent of the individual concerned.

This consent may be requested through registration forms, authorization documents, acceptance of terms and conditions of participation, event-specific communications, or any other means that allows for a record of acceptance to be kept.

In certain cases, StepHouse may take general photographs or videos of spaces, activities, or events for informational or documentary purposes, always respecting the rights of attendees and avoiding any use that could infringe upon their privacy or right to one’s own image.

When a person does not authorize the use of their image, StepHouse will take reasonable measures to prevent them from appearing prominently or in a way that makes them identifiable in the published content.


6. Consent for Activities and Events

For activities organized by StepHouse—such as sports leagues, welcome events, trips, parties, workshops, or special events—participants may be asked to provide express consent for the use of their image.

Consent may include authorization to:

  • Take photos during the activity.
  • Record videos during the activity.
  • Post content on social media.
  • Use images from the StepHouse website.
  • Include images in newsletters, presentations, or communication materials.
  • Use the content in promotional campaigns related to StepHouse.

Participation in an activity does not automatically imply authorization for the individual use of one's image. When necessary, the appropriate consent will be requested.


7. Minors

In the case of participants who are minors, StepHouse will implement additional protective measures.

If the participant is under 14 years of age, consent for the use of their image must be given by their mother, father, or legal guardian.

Individuals who are 14 years of age or older but under 18 may give their own consent regarding data protection, except in cases where applicable regulations require the involvement or authorization of their legal representatives.

However, StepHouse may request additional authorization from a parent or legal guardian when it deems it necessary based on the type of activity, the context of the post, or the nature of the content.

StepHouse will refrain from publishing images of minors in contexts that could affect their privacy, safety, reputation, or well-being.


8. Types of images that StepHouse may use

StepHouse may use images such as:

  • Group photos taken during activities or events.
  • Videos summarizing experiences.
  • Photographs of sports teams.
  • Photos of participants during tournaments, trips, or activities.
  • Spontaneous moments from life in the residence.
  • Images of common areas showing residents participating in activities.
  • Testimonials or voluntary on-camera appearances.
  • Content generated during internal or external events organized by StepHouse.

When it comes to close-ups, interviews, testimonials, videos featuring individuals, or particularly recognizable content, StepHouse will seek to obtain clear and specific authorization.


9. Duration of Use of the Images

Authorization to use an image will remain in effect indefinitely as long as the purpose for which it was obtained continues to exist, unless the individual concerned withdraws their consent or requests the removal of their image in accordance with the terms set forth in this policy.

This means that an image posted as part of a campaign, on social media, in a video, on a website, or in corporate materials may remain posted as long as the content remains relevant to StepHouse and no request has been made to remove it when appropriate.


10. Withdrawal of Consent

The data subject may withdraw their consent at any time.

To request the withdrawal of consent or the removal of an image, please write to:

luciaguzman@stephoouse.es

The application should include, whenever possible:

  • First and last name.
  • Residency or activity in which he participated.
  • Description of the image or video.
  • Channel where it is published.
  • Link to the post, if available.
  • Reason for the request, if you wish to provide one.

StepHouse will review the request and take reasonable steps to remove, hide, delete, or stop using the image, as appropriate.

Withdrawal of consent will not affect any use that occurred previously while the consent was in effect. In the case of content that has already been shared by third parties, reposted, downloaded, or disseminated outside of StepHouse’s official channels, StepHouse will take action on its own channels but cannot guarantee the complete removal of copies beyond its control.


11. Use of Images on Social Media

StepHouse may post images and videos on its official social media accounts.

People who appear in content posted on social media should be aware that these platforms are managed by third parties and may be subject to their own terms of use, privacy policies, and distribution systems.

StepHouse is not responsible for actions taken by third-party users outside of official channels, such as screenshots, reposts, comments, downloads, or unauthorized use of content.

However, StepHouse is committed to managing its posts responsibly and to responding to requests for removal when appropriate.


12. Content generated by residents or participants

Occasionally, residents or participants may submit photos, videos, or other content to StepHouse to be shared on social media, the website, or corporate channels.

By voluntarily submitting content to StepHouse, the individual declares that:

  • She is the author of the content or has permission to share it.
  • The people appearing in the content are aware of and consent to its possible publication.
  • The content does not infringe on the rights of third parties.
  • Authorize StepHouse to use it in its communication channels.

StepHouse may freely decide whether or not to publish the content it receives, as well as adapt it to the format required for social media, the website, newsletters, or communication materials, without altering the original meaning of the content in an offensive or inappropriate manner.


13. Restrictions on the Use of Images

StepHouse agrees not to use images in the following cases:

  • Uses that may be offensive, discriminatory, or derogatory.
  • Uses that affect a person's privacy, honor, or reputation.
  • Posts unrelated to StepHouse or its activities.
  • Transfer of images to third parties for unrelated purposes without consent, when necessary.
  • Actions that could harm the person being represented.
  • Use of images of minors without the appropriate safeguards.

14. Transfer of Images to Third Parties

StepHouse may share images with vendors or partners when necessary for the management of its activities or communications, for example:

  • Communications or marketing agencies.
  • Designers, video editors, or photographers.
  • Photographers or videographers hired to cover events.
  • Digital publishing platforms.
  • Technology providers.
  • Event organizers or contributors.
  • Companies within the group or entities affiliated with StepHouse.

Such disclosures will be made only when necessary for the stated purposes and in accordance with applicable legal safeguards.

StepHouse will not sell images of residents or participants to third parties.


15. Image Preservation

The images may be retained for as long as necessary to fulfill the purposes for which they were captured, as well as to maintain StepHouse’s historical, corporate, and communications archives.

When an image is no longer needed, it may be deleted, archived, or anonymized, as appropriate.

In the event of a withdrawal of consent or a request for deletion, StepHouse will review the request and act in accordance with applicable regulations.


16. Rights of Data Subjects

Interested individuals may exercise their data protection rights, including:

  • Right of access.
  • Right to rectification.
  • Right to erasure.
  • Right to object.
  • Right to restrict processing.
  • Right to withdraw consent.
  • The right to file a complaint with the competent supervisory authority.

To exercise these rights regarding the use of images, please write to:

luciaguzman@stephoouse.es

The request must include the information necessary to identify the requester and locate the affected content.


17. Photos or videos taken during activities open to the general public

For events or activities open to the general public, StepHouse may provide advance notice that photographs or video recordings will be taken.

Whenever possible, this information may be communicated through:

  • Registration forms.
  • Signage at the event.
  • Informational emails.
  • Terms and Conditions.
  • Signs at the entrance or reception desk.
  • Internal communications at the residence.

If a person does not wish to appear in photographs, they may notify the organizing team so that reasonable measures can be taken.


18. Photos of employees, contributors, and ambassadors

In the case of employees, collaborators, brand ambassadors, coordinators, vendors, or individuals professionally affiliated with StepHouse, the collection and use of images will take place within the context of their relationship with the company or their collaboration with the brand.

In the case of promotional content, testimonials, campaigns, interviews, or featured appearances, StepHouse may request specific authorization.


19. Recommendations for Participants

To protect everyone's privacy, StepHouse recommends that residents and participants:

  • Do not post pictures of other people without their permission.
  • Avoid sharing content that might be uncomfortable, offensive, or intrusive.
  • Do not record private or sensitive situations.
  • Respect those who do not want to appear in photos or videos.
  • Notify the StepHouse team if you come across a post that needs to be reviewed.

The StepHouse community is based on respect, harmony, and mutual care among residents.


20. Updates to This Policy

StepHouse may update this policy as necessary to adapt it to legal changes, new communication channels, new activities, or improvements in the internal management of images.

The updated version will be available on the website or through the channels that StepHouse deems appropriate.