Draft: This text has not been legally reviewed yet. Passages marked in yellow will be completed before launch. Only the German version is legally binding.
Privacy policy
1. Controller
[PLACEHOLDER: Name and address of the controller (as in the imprint)]
Email: admin@feldner.it
2. Overview
SnapShare is a platform on which the guests of an event upload photos and videos into a private gallery. We only process the data needed for that. We use no trackers, no analytics or advertising services, and load no content (such as fonts) from third parties.
3. Hosting and server location
All data is stored and processed on our own servers in Germany. [PLACEHOLDER: Add future hosting providers as processors (e.g. Hetzner) once applicable]
4. Visiting the website
When you visit the site, the server processes technically necessary data (IP address, timestamp, address requested, browser identifier) to deliver the pages and defend against abuse. Retention period of the server logs: [PLACEHOLDER: Retention period of the server logs]. Legal basis: [PLACEHOLDER: Have the legal basis reviewed (likely Art. 6(1)(f) GDPR)]
5. Event guests
- Uploaded photos and videos including their metadata (e.g. capture time, camera model, location if present). We strip location data from preview images; the original file is left unchanged.
- Optionally a self-chosen name.
- A technically necessary session cookie so the gallery stays reachable without scanning again and your own uploads can be matched to you.
The hosts of the event decide on the content of a gallery. [PLACEHOLDER: Define the role split between operator/customer (processing or joint controllership) and the legal basis]
6. Customers (hosts)
We process the email address for sign-in via link, the event's data, and order and invoice data. We retain invoices for eight years in line with statutory retention periods. Legal basis: [PLACEHOLDER: Have the legal basis reviewed (likely Art. 6(1)(b) and (c) GDPR)]
7. Cookies
We use only technically necessary cookies for customer sign-in and guest sessions. There are no tracking or marketing cookies.
8. Emails
Customers only receive contract-related emails (sign-in link, reminders before expiry, deletion confirmation). Guests receive no emails. [PLACEHOLDER: Name email delivery via iCloud (Apple) as a service provider; review processing and third-country transfer]
9. Retention and deletion
An event's media is kept for 12 months on the Standard plan and 24 months on the Pro plan, each extendable. After expiry, a 14-day grace period follows; after that, we automatically delete all of the event's media. Individually deleted media stays in the recycle bin for 30 days before being permanently deleted. So that videos start faster, a guest's browser may cache videos they have watched locally on their device. These copies remain on the device after a deletion in the gallery until the guest clears them or the site data in the browser, or the browser discards them to free up space; we have no access to them. [PLACEHOLDER: Add retention periods for backup copies]
10. People shown in media
Anyone shown in a photo or video who wants it removed can contact the event's hosts or us (email above). The hosts decide on the content of their gallery; in justified cases we intervene ourselves.
11. No biometric analysis
We do not perform facial recognition or any other biometric analysis.
12. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability and objection (Art. 15–21 GDPR), as well as the right to lodge a complaint with a supervisory authority. [PLACEHOLDER: Competent supervisory authority with address]
13. Version
[PLACEHOLDER: Date of this version]
Checklist before publication (removed after review)
- ☐ Business registration; German small business rule (§ 19 UStG): invoices without VAT with a note, watch the turnover limit
- ☐ Imprint (§ 5 DDG) complete: name, postal address, email
- ☐ Privacy policy: servers in Germany, self-hosted, later Hetzner as processor, email delivery via iCloud (Apple)
- ☐ Terms: service description, retention periods, deletion concept, availability without guarantee, liability, withdrawal for digital content
- ☐ Data processing agreement (Art. 28 GDPR) template for business, agency and photographer customers
- ☐ Record of processing activities and technical and organisational measures
- ☐ Upload notice (image rights, people shown) and removal request channel: customer decides, operator may intervene
- ☐ Cookie notice: only strictly necessary cookies, mentioned in the privacy policy
- ☐ Invoices with sequential numbers, retained for 8 years
- ☐ No biometric processing (face search) without separate consent
- ☐ Confirm the contact address (currently admin@feldner.it)