Privacy policy
This page explains what data Festiroll processes, why, where and for how long. It follows the Swiss Federal Act on Data Protection (FADP). For people in the European Union, it also follows the General Data Protection Regulation (GDPR).
1. Data controller
Christian Bromley, 10 Chemin de Vers, 1228 Plan-les-Ouates, Switzerland.
For any question about your data: contact form, or by post to this address.
2. Data processed
2.1 Organisers
To create and manage an album, you sign in with your e-mail address, through a link sent to that address. There is no password.
We keep your e-mail address, your language, the day of your last sign-in, your albums and their settings (name, dates, mode), and your payments.
2.2 Guests
A guest enters the album by scanning the QR code. They need neither an account nor an e-mail address. A cookie recognises their phone in this album.
We keep what they send: photos, captions, guest book messages (written or voice), likes, completed challenges, and their nickname if they choose one. We also record that they accepted the album rules, with the date and version.
If they ask to be notified by e-mail (tick box), we keep their address for this album only.
2.3 Photos
Each photo is kept as it was sent, with a thumbnail for display. The thumbnail contains no metadata (no EXIF data, no GPS position). The original keeps the file's metadata: a photo imported from the phone's gallery may show the date, the device and sometimes the place.
We do not use any facial recognition.
Festiroll's administration does not see the photos. Who sees what in the album: album rules.
2.4 Payments
Payment takes place on the myPOS page. You enter your card details and contact details there.
myPOS confirms the payment to us: amount, currency, date and transaction references. We receive neither your card number nor the payer's name, e-mail or phone number.
2.5 Contact form
Your name (optional), your e-mail address, the subject and your message reach us by e-mail. They are used only to reply to you and are not stored in the service's database.
The sending log keeps only the subject, the language and the result of the sending, without your address or your message.
2.6 Suggestion box
Your message, its category and the language. Your e-mail address only if you give it and agree that we reply to you.
2.7 Requests to remove a photo
A person who does not use the album can ask for a photo to be removed. They describe the photo and leave an e-mail address for the reply.
2.8 Technical logs
Our logs contain no IP addresses. The server keeps no log of visits.
Your IP address is only used, in memory, to limit the number of requests and to block abuse. It is not stored.
For each e-mail sent by the service, we keep its type, its date and its result, with the address masked.
2.9 Audience measurement without cookies
To know which pages of the site are viewed, our server counts page views per day: page, language, type of device (phone, tablet or computer), name of the site you came from (for example “google”) and, where relevant, name of the campaign.
No cookie, no IP address, no identifier: we cannot recognise you from one page or one visit to the next. If your browser sends the “Global Privacy Control” or “Do Not Track” signal, nothing is counted.
3. Why we process this data
We use this data to:
- provide the album and your account (performance of the contract);
- collect payments and keep the accounts (contract and legal obligation);
- send the service's e-mails: sign-in link, receipt, reminder before deletion (contract); to guests, only if they asked for it (consent);
- reply to your messages (consent);
- protect the service against abuse and handle reports (legitimate interest);
- measure the site's audience, without personal data.
No advertising. We do not sell your data.
4. Hosting and providers
Photos and the database are hosted in Switzerland. We use:
- Infomaniak, in Switzerland: servers, database, photo storage and backups;
- myPOS Payments Ltd, in London (United Kingdom): online payment;
- an e-mail sending service, for the service's e-mails.
For price estimates in euros, pounds or dollars, our server reads the rates published by the European Central Bank. No data about you is sent to it.
The site loads no script, no font and no image from another site.
5. Retention periods
We keep data as long as needed, then delete it:
- photos, captions and guest book messages: until the album's deletion date (plan duration plus extensions, at most 5 years after the guests first see the photos);
- e-mail address of a subscribed guest: until they unsubscribe or until the album is deleted;
- prepared downloads (ZIP files): one hour;
- organiser account, album settings, nicknames and reports: until the album or the account is deleted;
- payments: 10 years (accounting obligation), even after the account is deleted, which is then anonymised;
- sign-in link: 15 minutes; organiser sign-in: 30 days;
- suggestion box: the e-mail address is deleted 90 days after our reply, or after 12 months without a reply; the message is deleted after 24 months;
- log of e-mails sent: 90 days;
- audience measurement (no personal data): 25 months;
- database backups: encrypted, kept for at most 6 months. Deleted data may therefore remain there for up to 6 months. Photos are not in these backups.
6. Cookies and storage on your device
We only use the cookies needed for the service to work:
- “session”: keeps the organiser signed in, 30 days;
- “ap_…”: recognises a guest's phone in an album, 180 days;
- “langue”: remembers the chosen language, 1 year.
The phone also keeps, in its local storage, the photos waiting to be sent. Each photo leaves it as soon as the server has received it.
No measurement or advertising cookies. That is why the site shows no cookie banner.
7. Your rights
You can ask for access to your data, its correction or deletion, and receive a copy. In the European Union, you can also ask for a processing to be restricted or object to it.
You can withdraw your consent at any time, for example by unsubscribing from an album's e-mails.
To exercise these rights, write to us through the contact form or by post.
A guest can delete all their photos themselves, at the bottom of the album. A person who was photographed and does not use the album can ask for a photo to be removed.
You can also contact the Federal Data Protection and Information Commissioner (FDPIC) or, in the European Union, the data protection authority of your country.
8. Security
Exchanges with the site are encrypted (HTTPS). Photos are in private storage; each access link to a photo expires after 5 minutes at most. Backups are encrypted.
9. Changes to this policy
We may change this policy. The new version is published on this page, with its date.