**1. Introduction**

We live in a world dominated by images. In certain sectors such as advertising or fashion these are used to send attractive messages and thus encourage for the purchase of goods or services. There is a grea<sup>t</sup> number of models who, besides inducing you to buy, present an example of what is considered an appropriate way of being or living, thus inspire eagerness to imitate them within the target audience.

Photography then becomes the basic tool not only to capture an image, but to modify it through technical mechanisms. There are, on the one hand, the rights of the subject who is involved in getting the image and, on the other, the rights of the person photographed. Firstly, questions related to photography and the photographer will be developed throughout these pages.

Then, in the second part of this paper, as personal image has developed such a significance that cannot be ignored by Law, there will follow an analysis about the concept of the image.

Protection of the image in di fferent legislation from around the world di ffers, and for that reason, examples of the diversity of treatments will be illustrated from both a legal and a more specific perspective. The development of the legal protection of images has been deep, wide and controversial around the world, so in this paper we cannot go further than simply enumerating the relevant di fferences in legislation and the treatment of the courts of the jurisdictions chosen by way of example. To show the complexity of the issue, it is worth mentioning that American law has developed the concept of right of publicity out of the right of privacy, which is conceptually di fferent from the protection granted in countries of continental tradition and even in other common law countries. Consequently, a special analysis will be made in this paper. Additionally, within the United States

of America, regulations are governed by each state, thus overlapping with common law and certain national legislations, as indicated, all of which renders the analysis increasingly di fficult.

Finally, after dealing with photo retouching, a legal concept of modeling will be chosen to show the importance of image in that business and to demonstrate that manipulating images of models may lead, in some circumstances, to infringements of their rights.

Conclusions open a path for future reflections and propose certain actions for Photoshop to be used reasonably with respect to the body of the models.
