Privacy Policy for Snapveil

1. Data Controller

The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

Pivoda GbR (German civil-law partnership)

Partners: Daniel Wagner, Jens Schwoon Friedensstraße 7 48151 Münster Germany

Email: office@snapveil.com

2. General Information

Snapveil is a platform for creating and managing private event photo galleries. Organizers can create galleries, and guests upload photos and videos directly in their browser via a QR code or link and can leave greetings in the gallery's guest book.

Who is responsible for what

• Website, user account, payment, emails: For this data, Pivoda GbR is the controller within the meaning of Art. 4(7) GDPR.
• Gallery content: The organizer decides which photos and videos are collected in a gallery, whether guests can write in the guest book, who is invited and how long the gallery exists. For this content the organizer is the controller; Pivoda GbR processes it on the organizer's behalf as a processor under Art. 28 GDPR. For companies and other organizers subject to the GDPR we provide a Data Processing Agreement (DPA). Anyone celebrating privately, such as a wedding or a birthday, generally does not have to meet any GDPR obligations as an organizer (Art. 2(2)(c) GDPR). For us, all commitments in this policy apply unchanged.

We do not sell data, we do not show advertising in galleries, and we do not pass photos or videos on to third parties for advertising purposes.

3. What Data We Process

3.1 Visiting Our Website

When you visit our website, the following data is processed automatically:

• IP address (shortened or anonymized)
• Date and time of access
• Browser type and version
• Operating system
• Referrer URL
• Pages accessed

This data is used for technical provision, security, and error analysis.

Legal basis: Art. 6(1)(f) GDPR.

Audience measurement

To evaluate website usage statistically, we use self-hosted analytics software in the EU; no external analytics provider receives any data. It works without cookies and without storing any other information on your device, does not build cross-site or cross-device profiles, and does not store your IP address in clear text. It records pages viewed, referrer, device type, browser, operating system and the country derived from the IP address. No consent is required, because your device is not accessed and no link to you as a person is established.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is improving our service on the basis of aggregated usage figures.

Error logging

We log technical errors on our own systems in the EU. The logs contain technical details about the error and are limited to what is needed to fix it; IP addresses and cookie contents are not included. No external provider receives any data.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is the stable and secure operation of the service.

Protection against automated access

We protect individual abuse-prone functions against automated access with Cloudflare Turnstile. Cloudflare processes technical characteristics of your browser and your IP address to tell humans from bots.

Legal basis: Art. 6(1)(f) GDPR.

Free design tools

Our free tools, for example for QR code cards, table numbers, place cards and welcome signs, run entirely in your browser. Links, names and texts you enter there are not transmitted to us and are not stored.

3.2 User Account

When you register an organizer account, we process:

• Username
• Email address
• Password (stored only as a hash, never in clear text)
• Event information

Alternatively, you can sign in with your Google account. In that case we receive your name, email address and profile picture from Google.

The logged-in organizer area includes a feedback and support window by Featurebase. When you open the organizer area, your account identifier, your email address and the selected language are transmitted to Featurebase, and additionally your message if you use the window. Gallery guests never come into contact with it.

Legal basis: Art. 6(1)(b) GDPR; for the feedback widget Art. 6(1)(f) GDPR.

3.3 Guests

Guests can use galleries without full registration. In this case, we process:

• Username
• Email address (optional)
• Optionally, consent to receive product information (see section 8.2)
• Uploaded content
• Guest book entries, if the organizer has switched the guest book on

A guest book entry consists of your text, your guest name and the time of posting. It is visible to everyone who can open the gallery. You can delete your own entries at any time; the organizer can delete entries and export them as a file. Guest book entries are stored on servers of Hetzner Online GmbH in Germany.

Legal basis: Art. 6(1)(b) GDPR; for consent to product information, Art. 6(1)(a) GDPR.

4. Uploaded Photos and Videos

When you upload photos or videos, we process:

• Image and video files
• Upload time
• Association with the respective user
• The capture data stored in the file, such as camera model, time of capture and, where present, GPS position

We store photos, videos and the preview versions generated from them with Cloudflare in storage that is restricted to data centers within the European Union. Account and event data as well as the details of the files are kept on servers of Hetzner Online GmbH in Germany.

Location Information

On the "Ultra" plan, location detection is switched on by default; the organizer can switch it off for each event. If a photo contains GPS coordinates, we transmit only those coordinates and the desired language to HERE Global B.V. (Netherlands) in order to obtain a human-readable place name. The photo itself and any details about you are not transmitted.

5. AI Features

AI features are available exclusively on the "Ultra" plan. There they are switched on by default; the organizer can switch each of them off per event. No AI analysis takes place on the "Free" and "Pro" plans. Videos are not analyzed with AI on any plan.

What the AI does

• Tagging and image description: For each photo, tags and a short description are generated.
• AI search: A search index is built from the description, tags, place name and file name, which makes photos findable through free-text search.

Which data is transmitted to whom

We access the AI models through the interface of OpenRouter, Inc. (USA). OpenRouter forwards the requests to the respective model provider:

• OpenAI for tagging and image description. What is transmitted is a downscaled copy of the photo without capture and location data. The original file, names, email addresses or account data are not transmitted.
• Google for AI search. Only text is transmitted: the photo's description, tags, place name and file name, and, when searching, the search term entered. Google does not receive any images.

We store the results (tags, descriptions, search index) on our own systems in Germany.

No training on your photos

The use of your content for training AI models is excluded vis-à-vis the AI service providers we use. We do not train any models on your content ourselves either.

Deletion

AI results are deleted together with the respective photo or gallery.

Legal basis: Art. 6(1)(b) GDPR (providing the feature booked by the organizer); with regard to guests Art. 6(1)(f) GDPR. For the transfer to the USA see section 10. An overview is available on the AI features page.

Face grouping (planned, currently not available)

Snapveil currently has no feature for detecting or grouping faces; no biometric data is processed. We are planning such a feature. It will be switched off by default, can only be switched on per event, and will process biometric data (Art. 9 GDPR) only on the basis of explicit consent under Art. 9(2)(a) GDPR. The results are used solely within the respective gallery and are deleted with it. We will update this Privacy Policy before the feature is introduced.

6. Payment Processing

For paid services, we use Stripe as our payment service provider. Payment data is processed exclusively by Stripe. Snapveil does not store any credit card or account numbers, only the record of the payment.

Legal basis: Art. 6(1)(b) GDPR.

7. Email Notifications

To provide the service, we send, among others:

• Registration confirmations
• Notifications about available galleries
• Notices regarding storage periods
• Export notifications
• Information about activity within a gallery

Emails are sent via Amazon Web Services in Ireland.

Legal basis: Art. 6(1)(b) GDPR.

8. Newsletter and Product Information

8.1 Newsletter via our website

If you sign up through the form on our website, we will send you information about new features, offers, and product news. You can withdraw your consent at any time with effect for the future.

Legal basis: Art. 6(1)(a) GDPR.

8.2 Product information for gallery guests

When you join an event gallery as a guest and provide your email address, we ask you separately whether we may occasionally send you tips and product news. The checkbox is not pre-selected and providing it is optional. Without your active consent, we use your email address only for the gallery itself and the related service emails described in section 7.

If you have consented, you will receive at most one email about that event, a few days after it takes place. It shows you how to set up your own gallery for your own celebration.

Consent applies to that particular gallery. If you later join another event, we ask again.

You can withdraw your consent at any time with effect for the future. Every one of these emails contains an unsubscribe link. A withdrawal applies to every gallery holding the same email address. Service emails about your own events, and about galleries you take part in, continue regardless.

Legal basis: Art. 6(1)(a) GDPR in conjunction with Section 7(2) no. 2 UWG (German Act Against Unfair Competition).

9. Service Providers and Recipients

We use the following service providers. No other recipients receive your data unless we are legally obliged to disclose it.

• Hetzner Online GmbH, Gunzenhausen, Germany. Purpose: hosting of the application and the associated databases. Place of processing: Germany.
• Cloudflare, Inc., San Francisco, USA. Purpose: storage of photos, videos and preview versions in the EU, delivery and protection against attacks. Place of processing: storage in the EU; delivery takes place through the worldwide network from the nearest location.
• Stripe Payments Europe, Ltd., Dublin, Ireland. Purpose: payment processing. Place of processing: Ireland; parent company in the USA.
• Amazon Web Services EMEA SARL, Luxembourg. Purpose: sending service emails. Place of processing: Ireland.
• OpenRouter, Inc., USA. Purpose: technical interface to AI models, only on the "Ultra" plan with AI features enabled. Place of processing: USA. Accessed through OpenRouter: OpenAI (tagging and description of photos) and Google (search index), both USA.
• HERE Global B.V., Eindhoven, Netherlands. Purpose: converting GPS coordinates into place names, only on the "Ultra" plan with location detection enabled. Only coordinates are transmitted. Place of processing: EU.
• Google Ireland Limited, Dublin, Ireland. Purpose: optional sign-in with a Google account. Place of processing: Ireland; parent company in the USA.
• Featurebase. Purpose: feedback and support window, exclusively in the logged-in organizer area. Guests are not affected.

We run audience measurement and error logging (see section 3.1) ourselves in the EU; no external provider receives any data.

Data processing agreements pursuant to Art. 28 GDPR are in place with the processors. Stripe and Google process payment and sign-in data partly under their own responsibility.

10. Transfers to Third Countries

As a rule, we store data within the EU: application and databases in Germany, photos and videos with Cloudflare in storage restricted to the EU. In the following cases personal data may reach a country outside the EU and the EEA, in particular the USA:

• Cloudflare: Media is stored in the EU. Delivery takes place through the worldwide Cloudflare network; if a guest opens the gallery from outside the EU, the data is delivered from a location near them. As a US company, Cloudflare may also have access to connection data in the course of operations and support.
• OpenRouter, OpenAI and Google: With AI features enabled on the "Ultra" plan, the data described in section 5 is processed in the USA. Anyone who does not want this can use the "Free" or "Pro" plan or switch off the event's AI features.
• Stripe and Google (sign-in): The contracting parties are the Irish entities; processing by the US group companies is possible.

These transfers are based on Art. 44 et seq. GDPR. Where the respective recipient is certified under the EU-US Data Privacy Framework, we rely on the European Commission's adequacy decision under Art. 45 GDPR. Otherwise the European Commission's Standard Contractual Clauses under Art. 46(2)(c) GDPR apply. You can request a copy of the safeguards at office@snapveil.com.

11. Cookies

Snapveil uses only strictly necessary first-party cookies, for example for signing in, the guest session in a gallery, the protection of forms and the chosen language. We do not use analytics or marketing cookies; our audience measurement works without cookies. Individual embedded services may set their own strictly necessary cookies when you use them.

No consent is required for strictly necessary cookies (Section 25(2) no. 2 TDDDG). That is why Snapveil has no cookie banner. A complete list with purpose and lifetime is available on the Cookies page.

Legal basis: Section 25(2) no. 2 TDDDG; for the subsequent processing Art. 6(1)(b) and (f) GDPR.

12. Storage Duration

Event Data

The storage period depends on the event's plan and starts when the event is created:

• Free: 2 months
• Pro: 12 months
• Ultra: 24 months

The storage period can be extended by 12 months at a time for a fee. Before it expires, we send the organizer several reminder e-mails so that the content can be downloaded in time. After expiration, images, videos, guest book entries, metadata and AI results are deleted. The organizer can delete a gallery or individual items at any time before that.

Account Data

When you delete your account, you still have 30 days to download your content. After that, account data and content are removed, unless statutory retention obligations apply. We retain invoices and payment records for the periods required by commercial and tax law.

Backups

We create regular backups within the EU, which are overwritten on a fixed cycle. Deleted data is removed from them at the latest when that cycle ends.

13. Your Rights

You have the right to:

• Access (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object (Art. 21 GDPR)
• Withdraw consent (Art. 7 GDPR)

To exercise your rights, please contact: office@snapveil.com

If you appear in a photo or video in a gallery and want it deleted, you can contact the organizer or us directly. We forward your request to the organizer and support them in carrying it out.

14. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority.

Responsible for North Rhine-Westphalia:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia) Kavalleriestraße 2–4 40213 Düsseldorf

15. Data Security

We protect your data through technical and organizational measures, in particular encrypted transmission and storage, private galleries with optional password protection and per-guest permissions, strong authentication for all administrative access, access limited to a tightly restricted group of people, and regular backups within the EU.

Details are available on the Security page.

16. Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy if legal, technical, or organizational changes make it necessary. The current version published on Snapveil shall apply in each case.

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This is a courtesy English translation of the German Datenschutzerklärung. In the event of any discrepancy between the English and German versions, the German version shall prevail.

Last updated: 1 October 2026