Privacy Policy

This version is effective from: 30 October 2026 · Previous version: policy effective before 30 October 2026

This policy describes what personal data the GiftWeGo service (the giftwego.com website, the Android and iPhone mobile apps, the Chrome extension and the connection to AI assistants) processes, why, to whom we pass it, how long we keep it and how you exercise your rights. We describe what the app actually does. The rules of the service are set out in the Terms of Service.

1. Controller and contact

1.1 Controller

Ondřej Smutný, sole trader, company ID (IČO): 75343533, registered office Libichov 73, 294 42 Dobrovice, Czech Republic (“we” or “GiftWeGo”) Email for all data protection questions: info@giftwego.com

We have not appointed a data protection officer – we are not required to (Art. 37 GDPR). We answer your questions ourselves.

1.2 When we are not the controller

• Vouchers for business: customer data that a business enters into the tool (e.g. the email to which it sends a voucher, customer identification on redemption) is processed by us as a processor for that business. The business is the controller; please address requests to it.
• AI assistant connected via MCP (e.g. Claude): data that the assistant reads from your account on your instruction is processed by the assistant’s provider as an independent controller under its own policy.
• Shops and payment services our links lead to or where you buy (e.g. Google Play or the App Store) process data under their own policies.

2. What data we process

2.1 Account

• Registration by email: email, name and password stored only as a one-way hash (bcrypt).
• Sign-in with Google: email, name, optionally profile photo and Google account identifier. We do not receive your Google password or your contacts.
• Sign in with Apple (in the iPhone app and on the website): from Apple we receive the identifier of your Apple account, your email address – or, if you choose “Hide My Email”, only a hidden relay address in the form …@privaterelay.appleid.com from which Apple forwards emails to your real address – and, on the first sign-in, your name if you allow Apple to share it. We do not receive your Apple ID password. We store the Apple account identifier (so that we recognise you the next time you sign in; if a GiftWeGo account with the same verified email already exists, Sign in with Apple is linked to it) and, when you sign in in the app, the refresh token Apple issues to us. We use the token only to revoke GiftWeGo’s access to your Apple ID with Apple when you delete your account (Apple requires this); it is not included in the data export.
• Optionally in your profile: first name and surname, phone, date of birth, billing details (address, company name, company ID, VAT ID), your own blacklist.
• Settings: language, currency, time zone, date format, email and notification settings, the first-run guide.
• Account status: credits and their history, subscriptions, Christmas Pass, voucher bundle, use of limits, date of creation and last change.
• Usage overview: the date of your last sign-in and last activity on the website and in the app (we record at most once a day only that and when you used the service – not what you did), usage milestones (when you added your first person, when you had 3 people with a date, your first idea or gift, the first event reminder sent and your first purchase) and an evaluation group: programme or control group. About 10% of accounts, selected at random from a hash of the account ID, belong to the control group; they receive no extra e-mails or push notifications – not even the getting-started messages in Art. 2.10 (welcome e-mail, in-app tip, tips by e-mail) – so that we can fairly tell what really helps people. Reminders you set up, e-mails about purchases, payments and account security and everything in the app are received by everyone. For accounts created earlier we estimated this data once from data we already hold (when people, gifts and purchases were created). We evaluate it mainly in aggregate (counts and shares) and it is not used for decisions with legal or similarly significant effects.
• Password reset: a one-time link valid for 1 hour.

2.2 Purchases and payments

• Purchase data: product, price, currency, date, Stripe payment, customer and subscription identifiers, receipts.
• Card details are entered only into the Stripe payment gateway. We only receive display data for a saved card (type, last 4 digits, expiry) – never the card number.
• Consent to immediate performance (Section 1837(l) of the Czech Civil Code): date and time, exact wording, language, version of the Terms of Service, product and price, IP address and browser identification (in the mobile app, app identification); for a purchase through Google Play or the App Store also the purchase the consent relates to (Google Play order number or App Store transaction ID).
• Withdrawal from the contract and cancellation of a subscription without signing in: data from the form and the outcome (for cancellation see the chapter Cancelling a subscription without signing in).
• Purchases in the Android app (Google Play): the Google Play order identifier (starting with “GPA.”) and the purchase identifier, product, quantity, date and purchase acknowledgement status; for a GiftWeGo Plus subscription also the subscription status as reported by Google (e.g. active, grace period, cancelled, paused, expired, refunded), start and end of the period, automatic renewal and records of acknowledgement, cancellation of renewal and refunds. So that the purchase can be assigned to the correct account, when you buy Plus the app passes Google a pseudonymous account identifier – a hash created from the internal ID of your account, without your email or name. We do not receive your card details or your Google account details. For each purchase we also store the record of the consent to the start of performance you gave in the app before the purchase (with the version of the Terms of Service), or that the consent is missing (older version of the app), and whether the confirmation of the contract has been sent. After verifying the purchase, we send the confirmation by email to the address of your GiftWeGo account (via Resend, Art. 5.3); it contains the purchase details, the price according to Google Play if known to us, and the record of your consent.
• Purchases in the iPhone app (App Store): credits, a single gift voucher, lifetime GiftWeGo Plus and the annual GiftWeGo Plus subscription. From Apple we receive signed transaction data: the transaction ID and original transaction ID, product, quantity, purchase date, price and currency, environment (live or test purchase) and, for a subscription, the end of the period, automatic renewal and the status as reported by Apple (e.g. active, renewal turned off, billing grace period, expired, refunded, revoked). Apple sends us changes of status (renewal, renewal turned off, failed payment, end of the subscription, refund, revocation of the purchase) in App Store Server Notifications; for each notification we record its identifier, type, processing result and time so that it is not processed twice. So that the purchase can be assigned to the correct account, when you buy the app passes Apple a pseudonymous account identifier – a UUID derived from the internal ID of your account, without your email or name; we also store it with your account. We do not receive your card details or your Apple ID details. As with Google Play, for each purchase we store the record of the consent to the start of performance you gave in the app before the purchase (with the version of the Terms of Service), or that the consent is missing, and whether the confirmation of the contract has been sent. After verifying the purchase, we send the confirmation by email to the address of your GiftWeGo account (via Resend, Art. 5.3); it contains the purchase details, the price according to the App Store if known to us, the transaction ID and the record of your consent.

2.3 Recipients

You enter the data about the people you give gifts to: name or nickname, age or date of birth, gender, relationship to you, interests, personality, place of residence (type of place, city, country), favourite brands, budget and occasions with dates, restrictions (e.g. allergies, diets, things they do not want), gift history with ratings, and notes. You are responsible for being entitled to enter this data (Terms of Service, Art. 5.2). Enter health data (e.g. allergies) only to the extent necessary and with the permission of the person concerned – we process it only so that the AI does not suggest an unsuitable gift. If the person concerned (the recipient) exercises their rights with us, we will comply and may inform you.

2.4 AI Advisor and other AI features

• History of suggestions: the input (recipient, occasion, budget, settings), the generated suggestions and the time; at most the 500 most recent records.
• Ratings of suggestions (thumbs up/down, rating, note), if you give them.
• AI usage: the number of AI ideas and AI actions in the month and the AI costs your requests caused (for monthly limits and the cost cap). We keep aggregate AI consumption (tokens by month and feature) without any link to you.
• AI in the editor: the prompt for an AI text or AI image and the number of generations in the month.
• Quick AI tips without an account (on the gift-idea pages): the input (type of gift, age, occasion, budget, interests) and, for the daily limit (3 requests per browser, 12 per network), only a fingerprint (hash) of the IP address and a fingerprint of the IP address together with the browser identification (User-Agent, language), with the date and number of requests – not the IP address itself; nothing is stored on your device.

2.5 Voucher editor and Cloud

• Templates and voucher designs (layout, texts, images), uploaded images, AI images with their prompts and custom fonts, with metadata (name, size, date) and storage usage.
• Paid vouchers: the design and preview of each paid voucher, number of downloads (at most the last 100).
• Voucher in progress and an e-mail about it: with GiftWeGo Plus, vouchers in progress are saved in your account (design, preview, time of the last edit) so that you can finish them on another device. Without Plus, a voucher in progress stays only in your browser or phone. If you are signed in on the web and have allowed the “Marketing” category in the cookie banner, the editor sends us only the design identifier after you edit a voucher, and we record the time of the last edit (and only if we may send you news and tips) – the content of the voucher is not sent to us for this. We record it at most once an hour and only for the latest design; we delete it after sending the voucher e-mail, after payment, immediately when you withdraw consent in the cookie bar on the website, otherwise at the latest after 7 days. Without consent, or after you withdraw it, the editor sends nothing, and the Android and iPhone apps never send anything of the kind. Based on the time of the last edit, we may send you the e-mail “Your voucher is almost ready” (Art. 2.10).
• Temporary images from the editor (e.g. during upload) are kept for at most 7 days.

2.6 Buying a voucher without an account, reminders and adding to an account

• The email from the payment, website language, number and dates of purchases, payment identifier, and whether you declined marketing messages or unsubscribed.
• Reminders you set yourself: recipient’s name or nickname, type of occasion and day and month (without year), date last sent.
• Adding a voucher to an account: payment identifier, voucher identifier, the email from the payment and a hash of a random key created by your browser before the payment.

2.7 Vouchers for business

Vouchers (name, type, value, currency, validity, status, notes), codes and their status, redemption history (date, amount, balance, optionally customer identification and a note), template activations and the emails to which the business sends vouchers. See Art. 1.2.

2.8 Chrome extension

• The extension recognises a product page only in your browser. It sends data to our server only after you act (click): for the AI check, the product name, price, currency, shop, description and product link (without tracking and affiliate parameters), the selected recipient, occasion, budget and language; for saving to ideas for the chosen person or to My wishes (also in one click without a form), the name, price, currency, shop, image address, link, size and optionally the EAN. We do not download the image.
• “Already in your ideas”: if you have Gift Manager, the extension sends only the link to that product (without tracking and affiliate parameters) when you open the toolbar panel or the window from the button on a product page. We compare it with the ideas and gifts in Gift Manager (only those you can see yourself) and with your My wishes and show any match; we do not store the link itself. Nothing is sent while you browse without taking an action.
• A saved idea or wish is an ordinary part of Gift Manager (Gift Manager chapter). From the extension you can change the status of a matching idea (Ordered, Bought) just as on the website, and undo an idea you have just saved (it is deleted).
• The history of AI checks (product, result, time) is saved to your account.
• The browser (Chrome Storage) stores the sign-in state, the account name and e-mail, the credit balance, language, settings, the list of recipients, the person you chose last and recent checks; they are deleted when you disconnect the account or uninstall the extension.
• We do not send your browsing history and the extension does not change shop pages.

2.9 Connection to AI assistants (MCP)

When you connect your account to an AI assistant, we store the assistant’s app registration, authorisation codes (valid for 10 minutes), access tokens (1 hour) and refresh tokens (30 days), or API keys, and a usage log (which tool the assistant used and through which connection, when, whether it read data, changed data or used AI, whether it concerned your data or a shared household, the result (an error code, if any) and how long it took, the names of the parameters used, the MCP protocol version and the name and version of the assistant’s app – without the content of the parameters, IP address or browser data). The log is deleted automatically after 90 days; from older entries we have removed the content of the parameters, the IP address, browser data and error message texts. You can see and revoke connections in Settings › AI assistants.

2.10 Notifications and emails

In-app notifications (the bell; deleted after 90 days), records of account emails and reminders sent (so that they do not arrive twice; deleted after 400 days) and subscription settings.

Getting-started messages. After you sign up, we send you one welcome e-mail about your account (how to start and what the service does). On the second day, if you have allowed notifications in the app and have not yet added at least 3 people with a date, one in-app notification with a tip on how to start. On the fifth day – if you did not decline tips and news at sign-up (accounts created from 29 October 2026; for an account via Google or Apple only after you answer “That’s fine” to the notice after your first sign-in), have turned on news by e-mail or have bought something from us – one e-mail with tips on what the service can do (a commercial communication; you can unsubscribe with one click). As soon as you use the service again or add 3 people with a date, no further messages from this series are sent. We send at most 1 such extra e-mail every 14 days and 6 per year, and at most 2 in-app notifications per week, always only between 9 a.m. and 7 p.m. We record which message we sent, through which channel and when (so that it does not arrive twice; deleted after 400 days) – we decide based on your sign-up date, last activity and the milestones in Art. 2.1. Reminders and notifications that can be turned off can also be unsubscribed from via the link in the email footer or the “Unsubscribe” button in your email app – without signing in; the link contains only a signed identifier, not your email address.

Voucher e-mails. If you have not declined news and tips or unsubscribed, we may send you: as a customer who bought a voucher without an account, one e-mail about 14 days before the first anniversary of the purchase (not between 15 November and 26 December, and not if you have made a purchase in the last 30 days or have set a reminder close to that day); with an account, one e-mail about a day after your last edit of a voucher in progress that you have not paid for – based on the voucher saved in your account with GiftWeGo Plus, or on the information from the editor on the web with your consent to the “Marketing” category (Art. 2.5); once per voucher, at most once every 30 days. These are commercial communications – you can unsubscribe with one click – and they count towards the limit of 1 e-mail every 14 days and 6 per year, always only between 9 a.m. and 7 p.m.; the control group from Art. 2.1 does not receive them. We decide based on the dates of purchases and reminders (Art. 2.6), the time of the last edit of the voucher (Art. 2.5) and the record of messages sent (so that nothing arrives twice; deleted after 400 days).

Notice before an inactive account is deleted. We may delete a free account that nobody signs in to and that you don’t use no earlier than after 12 months and outside the gift season (October – January). At least 30 and 7 days before deletion we send you an account email (not a marketing message), with the deletion date, the number of people, gifts, ideas and wishes in the account and a “Keep my account” link. The link contains only a signed one-time identifier valid until the deletion date, not your email address. We record on the account when the notices were sent, the deletion date and whether you kept the account – this disappears when the account is deleted. For deleted accounts we keep only the number and date, without the email address. After deletion we send you a confirmation (Art. 4.2).

News and offers by email. We store whether you want to receive them and a record of each decision: yes / no, date and time, where you decided (website, Android or iPhone app, link in an email), in which situation (registration, notice after your first sign-in via Google or Apple, question in the app, settings, unsubscribing), the exact wording you saw and the language (the last 20 changes). For accounts created from 29 October 2026 we likewise record whether you declined tips and news at sign-up (the “I don’t want to receive them” checkbox) or how you answered the notice after your first sign-in via Google or Apple (“That’s fine” / “I don’t want to receive them”) – until you answer, we do not send them. For each campaign we send, we record to whom and in which language the email was sent, the sending result and any unsubscribe – so that nobody receives the same email twice. If you unsubscribe or decline news, we add only a fingerprint (hash) of your email to the unsubscribe list. We do not track email opens or link clicks.

Push notifications in the Android app. When you allow notifications in the app, we store with your account a device identifier for notifications (a Firebase Cloud Messaging token), the platform, language and app version, and the date of registration and of the last refresh. We send to it the same notifications you see in the bell (according to the categories you have switched on in the notification settings); the text of a notification may contain a name – e.g. of a household member, of a giver who has reserved a gift, or of a recipient. We delete the identifier when you sign out in the app, choose “Sign out of all devices”, change your password on the website or reset it, delete your account, uninstall the app or do not use it for 60 days (Art. 4.3). You can also turn notifications off in your phone settings. We never include the device identifier in the data export or in operational logs.

Push notifications in the iPhone app. On iPhone the same works through the Apple Push Notification service (APNs): we store with your account an APNs device token with the same data (platform, language and app version, date of registration and of the last refresh) and send the notifications (title, text and technical data for opening the correct screen) through Apple’s servers. We delete the token in the same cases as on Android and also immediately when Apple rejects it as invalid (e.g. after the app has been uninstalled). We do not include the APNs token in the data export or in operational logs either.

2.11 Contact, feedback and feature suggestions

• Contact form: name, email and message – we receive them by email and reply.
• Feature suggestions: title and description of the suggestion, your account (if signed in) and votes. After review we may publish the suggestion on the roadmap without your name and translate it automatically (AI) for that purpose.

2.12 Affiliate programme

• Partners: data from the application (name, account email, website, description of promotion, traffic), referral code, payment details for payouts depending on the country (country, bank account number or IBAN and BIC if provided, account holder name, PayPal account e-mail, or the payout e-mail for Wise) and billing details (name or company, address, company ID, VAT ID), commissions, payouts and a record of consent to the terms (time, version, IP address, browser).
• Visitors from a partner’s link: partner code, time of the click, landing and referring page, browser identification and a hash of the IP address, not the IP address itself. The record is deleted automatically after 30 days. For an account we record any assignment to a partner. The gw_ref cookie only with your consent (Art. 8).

2.13 Technical data and security

• Server logs of the hosting provider (IP address, time, request address, browser) for operation and security.
• Operational and error logs: the error message or event description, technical details, page address, browser and, for signed-in users, account ID and email.
• Abuse protection: short-term request counters by IP address, link or account; for sign-in, registration and password reset, attempt counters only by a hash of the IP address and of the email entered, not by the address itself (all are deleted when the limit period ends, within 24 hours at the latest), and Google reCAPTCHA verification on forms.

2.14 Android and iPhone mobile apps

• The app uses the same account and the same data as the website. It stores a sign-in token in the phone’s secure storage (valid for 30 days; deleted when you sign out).
• Local reminders: the app schedules reminders of occasions, celebrations and deadlines directly on your phone from your account data. Scheduled reminders stay on the device – nothing is sent to us, to Google or to Apple for them, and they do not go through push notifications.
• Push notifications are described in Art. 2.10, purchases through Google Play and the App Store in Art. 2.2 and 5.2, Sign in with Apple in Art. 2.1.
• Data export and account deletion are also available in the app (Art. 7.1 and 7.3).

3. Purposes and legal bases

Where the basis is legitimate interest, you can object (Art. 7.6). You can withdraw consent at any time; withdrawal does not affect processing before it.

Automated decision-making: the AI suggests gifts and texts, but does not make decisions about you with legal or similarly significant effects (Art. 22 GDPR). Monthly limits and the AI cost cap apply automatically according to your plan and usage – this is a rule of the service, not an assessment of you.

4. How long we keep data

4.1 For as long as the account exists

We keep account data, recipients, the history of suggestions, files in the cloud, paid vouchers and Gift Manager data for as long as you have an account. We may delete a free account that nobody has signed in to and that you have not used no earlier than after 12 months, outside October – January (terms of service section 10.5, not before 28 November 2026); we notify you by email at least 30 and 7 days in advance. Accounts with any purchase, subscription or purchased credits are never deleted. You can also delete your account yourself at any time (Art. 7.3).

4.2 After account deletion

Account deletion is immediate. We delete the account data and all data belonging to it (recipients, history and ratings of suggestions, AI checks, templates, images and fonts in the cloud, paid vouchers, Gift Manager including shared links and reservations, notifications, device identifiers for push notifications, connections to AI assistants and the extension, AI usage data). We remove you from other people’s households. If you signed in with Apple, we ask Apple to revoke GiftWeGo’s access to your Apple ID. After deletion we send one account email (not a marketing message) to the account’s address confirming the deletion – what we deleted and what the law requires us to keep, and for an inactive account also why. We use the address only for this one email (via Resend, Art. 5.3) and don’t store it; we don’t send it to an address from which emails bounce as undeliverable.

We keep only what we must or what belongs to others:

• payment receipts and credit movements linked to payments, including records of purchases and subscriptions through Google Play and the App Store – for the period required by accounting and tax laws (up to 10 years),
• records of consent to immediate performance, withdrawals and cancellations – for the limitation periods (cancellations without signing in 3 years),
• business vouchers and codes sold to customers – so that their holders can redeem them,
• affiliate records (the partner account has its own deletion; commissions and payouts are accounting records),
• feature suggestions without your name and vote and claimed payments for vouchers bought without an account only as the payment ID (so that it cannot be claimed again),
• a fingerprint (hash) of your email in the news unsubscribe list, if you unsubscribed or declined news – so that you receive no more.

Operational and error logs, which may contain your account ID or email (Art. 2.13), are not deleted immediately when you delete your account but expire automatically within 90 days at the latest.

Deleted data may still be reflected in database backups for a limited time until the backups are overwritten in the regular cycle; we do not restore it from backups except when recovering from a failure.

4.3 Specific periods

4.4 Cookies

Cookie storage periods are listed in Art. 8.

4.5 Data for the defence of claims

We may keep data about purchases, consents and complaint communications after the contract ends for the limitation periods (usually 3 years), only where needed to defend legal claims.

4.6 Voucher purchases, reminders and paid vouchers

• Email of a customer without an account and reminders: until you unsubscribe, at most 3 years from the last purchase; then we delete them automatically.
• Declining messages / unsubscribing: we keep only the email and the fact that you declined, so that we send you nothing further.
• Paid vouchers: for as long as the account exists, at most the last 100; they are deleted when the account is deleted.
• Receipts and payment data: for the period required by tax and accounting laws.

5. Who we share data with

We do not sell data and do not pass it to anyone for their own marketing. It is handled only by the following processors and recipients, each only to the extent needed for its task:

5.1 AI providers

5.1.1 Anthropic (Claude)

• Task: AI Advisor, quick AI tips without an account on the gift-idea pages, AI product check in the extension, AI actions in Gift Manager, AI suggestions in reminders, translation of image prompts and feature suggestions.
• Data: what the task requires – data about the recipient (name or nickname, age, gender, interests, personality, restrictions, gift history including what they already received or have bought and from whom – section 13.3, blacklist), occasion and budget, product data; we do not send contact details. For quick AI tips without an account, only the form data (type of recipient, age, occasion, budget, interests) – we do not send the IP address or session identifier.
• Location: Anthropic, PBC, USA. Under its commercial API terms it does not use the data to train models.

5.1.2 Groq (AI texts in the editor)

• Data: the voucher text prompt (occasion, tone, your instructions), without contact details. Location: Groq LLC, USA.

5.1.3 Cloudflare Workers AI (AI images in the editor)

• Data: the text prompt for the image (translated into English where needed), without contact details. Location: Cloudflare, Inc., USA – the same provider as the R2 file storage (Art. 5.3). We store the generated image in R2 storage; the temporary copy is deleted after 7 days.

5.2 Payments

• Stripe (Stripe Payments Europe, Ltd., Ireland, and the Stripe group including Stripe, LLC in the USA) – processing payments, subscriptions and receipts; email, name, payment details, amount. For its own legal obligations (e.g. fraud and money-laundering prevention) Stripe is an independent controller.
• Banks – commission payouts to affiliate partners by bank transfer in CZK or SEPA transfer in euros (Art. 2.12): we pass the account holder name, account number or IBAN (and BIC if provided), the amount and the payment message with the payout number to the operator's bank; the operator's bank, the partner's bank and any intermediary banks process them as independent controllers under their own policies and legal obligations.
• PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg) – commission payouts to affiliate partners outside the EU/EEA (Art. 2.12): the partner's PayPal account e-mail, amount, currency and payout number (for PayPal Payouts batch payouts also the internal payout ID). For its own services and legal obligations (e.g. identity verification, anti-money-laundering) PayPal is an independent controller under its own privacy policy.
• Wise (Wise Europe SA, Rue du Trône 100, 1050 Brussels, Belgium) – only if we offer payouts via Wise and the partner chooses them: the partner's name or company name, payout e-mail, amount, currency and payout number. Wise sends the partner an e-mail with a link to claim the payment. For its own services and legal obligations Wise is an independent controller under its own privacy policy.
• Google Play (Google Commerce Limited, Ireland; outside the EEA and the United Kingdom possibly another Google company) – purchases of credits and the GiftWeGo Plus subscription in the Android app. The purchase is sold to you by Google, which processes the payment data and your Google account data as an independent controller under its own privacy policy; we do not receive your card details or Google payment account. From Google we only receive the purchase confirmation and the subscription status (Art. 2.2); we pass Google the pseudonymous account identifier (Art. 2.2) and instructions to acknowledge a purchase, cancel the renewal of a subscription or issue a refund.
• App Store (Apple Distribution International Ltd., Ireland; outside the EU possibly another Apple company) – purchases of credits, a single gift voucher, lifetime GiftWeGo Plus and the annual GiftWeGo Plus subscription in the iPhone app. The purchase is sold to you by Apple, which processes the payment data and your Apple ID data as an independent controller under its own privacy policy; we do not receive your card details or your Apple ID details. From Apple we only receive signed transaction data and notifications about the status of purchases and subscriptions (Art. 2.2); we pass Apple only the pseudonymous account identifier (Art. 2.2). Subscriptions from the App Store, their cancellation and refunds are managed by Apple – we cannot cancel them for you or refund App Store purchases.

5.3 Infrastructure

• Vercel Inc. (USA) – hosting of the website and app, server logs, temporary images. Server functions (handling requests and the API) run in the Washington, D.C. (USA) region; static website files are delivered by Vercel’s global network from the node closest to you (including in the EU).
• MongoDB Atlas (MongoDB, Inc., USA) – the app database (all data under Art. 2); the database is stored in a data centre in the USA.
• Cloudflare R2 (Cloudflare, Inc., USA) – storage of files in the cloud (templates, images, fonts, photos of gifts and people, saved vouchers). The storage has a preferred location in Eastern Europe (location hint EEUR). This is only a preference, not guaranteed storage in the EU – the storage is not restricted to the EU jurisdiction, so Cloudflare may store and process files outside the EU as well, including in the USA.
• Resend (Plus Five Five, Inc., USA) – sending emails (email, name and content of the email, e.g. the recipient’s name in a reminder, or a data export you choose to have sent by email).
• Google Firebase Cloud Messaging (Google; data processed by Google LLC, USA, and companies of its group) – delivery of push notifications to the Android app: the device identifier, the title and text of the notification (may contain a name, e.g. of a household member, a giver or a recipient) and technical data for opening the correct screen (notification type, link, notification ID). We do not send your email or other account data. Google is a processor under the Firebase data processing and security terms.
• Apple (Apple Inc., USA, and Apple Distribution International Ltd., Ireland) – Sign in with Apple (verification of the sign-in, exchange of a one-time authorisation code for a refresh token and its revocation when you delete your account; Apple manages your Apple ID as an independent controller) and delivery of push notifications to the iPhone app through the Apple Push Notification service (APNs): the device token, the title and text of the notification (may contain a name, e.g. of a household member, a giver or a recipient) and technical data for opening the correct screen (notification type, link, notification ID). We do not send your email or other account data in notifications. Apple delivers notifications under the Apple Developer Program License Agreement.

5.4 Analytics, consent and form protection

• Google Analytics 4 (Google) – traffic statistics, only with your consent.
• Microsoft Clarity (Microsoft) – analysis of website use (session recordings and heatmaps), loaded only with your consent to analytics cookies; in the app, form fields and marked personal data are masked in recordings.
• CookieHub (CookieHub ehf., Iceland) – the cookie banner and storing your choice.
• Google reCAPTCHA v3 (Google) – protecting registration, the contact form, feature suggestions, the withdrawal form, the affiliate application and forms on shared Gift Manager links against bots. The script loads only on pages with these forms (not on other pages or when signing in); Google processes the IP address and browser and device data for this.
• Vimeo – playing video guides in “Do Not Track” mode.

5.5 Other recipients

• Other users – only what you share yourself (household, shared links in Gift Manager; see the Gift Manager chapter).
• Affiliate partners – do not receive your name or email, only information about the purchase (product, amount, commission status) and aggregate statistics.
• Shops and partner networks (Amazon, Heureka.cz, eHUB, AffiliatePort and others) that the links lead to – receive no personal data from us; after you click, they process data under their own policies.
• Pixabay – image search in the editor; we only send the search term.
• Public authorities – only where required by law.

6. Transfers outside the EU

Some processors are based in the USA or process data outside the European Economic Area (EEA). We transfer data to the USA on the basis of the European Commission’s adequacy decision for companies certified under the EU-U.S. Data Privacy Framework (DPF, Art. 45 GDPR). Where a recipient is not certified under the DPF or its contractual terms rely on another instrument, we transfer data on the basis of the standard contractual clauses approved by the European Commission (SCC, Art. 46(2)(c) GDPR), which form part of the processor’s contractual terms. We checked the certifications in the list at dataprivacyframework.gov as at the effective date of this policy.

CookieHub (Iceland) is based in the EEA, so no data is transferred outside the EEA. Wise Europe SA is based in Belgium (EU) and PayPal (Europe) S.à r.l. et Cie, S.C.A. in Luxembourg (EU); transfers within their groups outside the EEA are governed by their policies as independent controllers. We send payouts to a partner outside the EU/EEA to the partner's own PayPal account at the partner's request (performance of the contract, Art. 49(1)(b) GDPR). Google Play and the App Store process in-app payments as independent controllers under their own policies (Art. 5.2). We will provide a copy of the safeguards (SCC) on request.

7. Your rights

You exercise your rights in the app or by email to info@giftwego.com. We will reply without undue delay, at the latest within 1 month (in complex cases this can be extended by a further 2 months, and we will inform you). For requests by email we may verify that you are the account holder.

7.1 Access (Art. 15)

You have the right to know what data we process about you and to receive a copy. In the app: Settings › Privacy and my data › Export data (JSON file). In the mobile app you can download the export or have it sent to you as an email attachment – always only to your account email (an export over 20 MB can be downloaded on the website); we do not keep a copy of the export. We will send you photos of gifts and people on request.

7.2 Rectification (Art. 16)

You correct account data, recipients and other data directly in the app; other data on request.

7.3 Erasure (Art. 17)

In the app: Settings › Delete account (with a confirmation phrase), on the website and in the mobile app (there, for an account with a password, you also enter your password). What is deleted and what we must keep is described in Art. 4.2. Deleting your account immediately cancels any active subscription (for Plus from Google Play, we cancel the renewal in Google Play); the price for the current period is not refunded (this does not affect your right to withdraw within 14 days). A Plus subscription from the App Store does not end when you delete your account – Apple does not allow us to cancel it for you; you cancel it on your iPhone in Settings › [your name] › Subscriptions or at apps.apple.com/account/subscriptions, ideally before deleting your account. Lifetime GiftWeGo Plus ends with the account, without a refund (Terms of Service, Art. 10.1 and 10.2). You can also delete individual items (a recipient, a file, a template).

7.4 Portability (Art. 20)

The data export in machine-readable JSON format contains your profile, recipients, history and ratings of suggestions, credits and purchases (including subscriptions from Google Play, without the purchase identifier, and purchases and the subscription status from the App Store), consents and withdrawals, vouchers, metadata of files in the cloud, Gift Manager data, notifications, devices for push notifications (without the device identifier), affiliate account and other account data (including the Apple account identifier, without Apple’s refresh token). Givers’ reservations of your own wishes are not included (they are other people’s data – see the Gift Manager chapter).

7.5 Restriction of processing (Art. 18)

On request by email we will restrict processing while we verify the accuracy of data or your objection, or when you need the data to exercise legal claims.

7.6 Objection (Art. 21)

You can object by email to processing based on legitimate interest. You can decline news and offers (including tips) right at sign-up (the “I don’t want to receive them” checkbox) or in the notice after your first sign-in via Google or Apple, and then at any time via the “I don’t want to receive news” link in every email, the “Unsubscribe” button in your email app or in Notification settings (on the website and in the app) – we then stop sending them.

7.7 Withdrawal of consent

You can change your cookie consent at any time in the cookie banner (the icon in the corner of the page). You delete a recipient’s health data by editing their profile. You withdraw your consent to news by email in Notification settings (on the website and in the app) or via the “I don’t want to receive news” link in every email.

7.8 Complaint

You can lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7, www.uoou.gov.cz, or with the supervisory authority of the EU state where you live or work. We would be glad if you contacted us first.

8. Cookies and browser storage

8.1 Cookies

We store analytics and marketing cookies only with your consent in the cookie banner. The Microsoft Clarity script loads only after you consent to analytics cookies; without consent, or after you withdraw it, it does not load (on withdrawal, Clarity deletes its cookies). You can change your choice at any time in the cookie banner. Consent to the “Marketing” category also covers the information from the editor about edits to a voucher in progress (Art. 2.5).

8.2 Affiliate programme cookie (gw_ref)

If you arrive via an affiliate partner’s link (?ref=), we store the HttpOnly cookie gw_ref (partner code, a random click ID and the date of the click, signed against tampering) only with your consent to the “Marketing” category, or later if you give consent during the visit. The helper cookie gw_ref_b contains your account’s internal ID as a marker that the assignment has been made. Without consent we store nothing on your device: the partner code remains only in the page address (?aff=, the same for all visitors of that partner), and if you register or sign in during the same visit, your account is assigned to the partner in our database. After you withdraw consent we delete the cookies (Section 89(3) of Czech Act No. 127/2005 Coll., Art. 5(3) of Directive 2002/58/EC).

8.3 Browser storage

The app stores helper data in your browser (localStorage) that is not sent to us: a voucher design in progress, the last selected recipient, hidden notifications and hints, keys to your reservations and contributions on shared links. Exception: if you are signed in and have allowed the “Marketing” category, the editor sends the identifier of the design in progress (not its content) after you edit a voucher – Art. 2.5. You delete them by clearing the website’s data in your browser.

9. Security

• Encrypted connection (HTTPS) across the whole website, passwords only as a bcrypt hash, sign-in using signed tokens.
• Each user’s data is separated in the database; only authorised household members and people you share a link with have access.
• Links to shared pages are long and cannot be guessed; search engines do not index them.
• We remove metadata, including location, from photos of gifts and people.
• Only the operator has access to the data; we have data processing agreements with processors.
• In the event of a security breach that could endanger your rights, we will notify the Office for Personal Data Protection within 72 hours and, if there is a high risk, you as well.

10. Children

Anyone over 16 can create an account. Children’s data (e.g. as recipients, in a wish list or in a Letter to Santa) is entered by a parent or another person with a parent’s consent; we process it only for the purpose for which it was entered. If we find that a child under 16 gave us data without a parent’s consent, we will delete it.

11. Changes to this policy

We update the policy when the way the app handles data changes. We publish the new version on this page with its effective date and a link to the previous version. If we wanted to use your data for a new purpose, we will inform you in advance and, where the law requires, ask for your consent.

12. Contact

Ondřej Smutný · company ID (IČO): 75343533 · Libichov 73, 294 42 Dobrovice, Czech Republic · info@giftwego.com

GiftWeGo Plus – processing of data for the subscription

• What data: subscription status (source, start, end of period, cancellation), for Lifetime Plus the purchase date and payment identifier, subscription and customer identifiers in Stripe, currency, invoices, a record of your consent to the start of performance (time, wording, language, version of the terms, IP address and browser) and a counter of fair-use limit usage (number of vouchers per subscription year, AI per month).
• Payments are processed by Stripe (Art. 5.2) – your payment card details never reach us.
• Plus bought in the app via Google Play: the payment is processed by Google as an independent controller (Art. 5.2). We store the purchase and subscription status data received from Google and a pseudonymous account identifier (Art. 2.2); payment receipts are sent to you by Google. We also store the consent to the start of performance given in the app before the purchase (with the version of the Terms of Service and the order number), and after the first purchase we send you the confirmation of the contract by email.
• Plus bought in the iPhone app via the App Store (annual subscription and lifetime Plus): the payment is processed by Apple as an independent controller (Art. 5.2). We store the signed transaction and subscription status data received from Apple and a pseudonymous account identifier (Art. 2.2); payment receipts are sent to you by Apple. We also store the consent to the start of performance given in the app before the purchase (with the version of the Terms of Service and the transaction ID), and after the first purchase we send you the confirmation of the contract by email. You can cancel a subscription from the App Store only with Apple (in your iPhone settings › Subscriptions); deleting your GiftWeGo account does not cancel it.
• Purpose and legal basis: providing and renewing the subscription (performance of a contract, Article 6(1)(b) GDPR), accounting and tax records (legal obligation, Article 6(1)(c) GDPR) and evidence of your consent to the start of performance (legitimate interest, Article 6(1)(f) GDPR).
• Subscription e-mails (welcome, renewal reminder 30 and 7 days in advance, failed payment, cancellation confirmation) are transactional – we always send them because they relate to the contract.
• Retention period: subscription data for as long as the subscription lasts and thereafter for the limitation periods (usually 3 years after it ends); invoices and accounting records for the period required by accounting and tax regulations (up to 10 years).
• The Gift Manager export and backup is created on request and downloaded directly to your device; we do not keep a copy of the export.

Cancelling a subscription without signing in

• What data: the data you enter in the Cancel subscription form (name, account e-mail, which subscription you are cancelling, optionally an invoice or contract number, type of notice, for an extraordinary notice its reason, and the requested end date), the date and time of receipt, the notice number and the result of processing (whether and until when we cancelled the subscription). We do not store your IP address or browser details with the notice; to prevent abuse we use the IP address only briefly (about one hour) to limit the number of submissions.
• Purpose and legal basis: processing your notice, confirming it and proving that and when we received it – performance of the contract and legal obligation (Art. 6(1)(b) and (c) GDPR, e.g. Section 312k of the German Civil Code, BGB) and our legitimate interest in defending legal claims (Art. 6(1)(f) GDPR).
• Recipients: we send the confirmation via Resend; when cancelling a subscription we pass the instruction to Stripe, or to Google for a subscription from Google Play (see processors above). We cannot cancel a subscription from the App Store for you (Apple does not allow it) – we accept the cancellation notice and send you instructions on how to cancel it in your iPhone settings; we do not pass anything to Apple because of it. We do not share the data with anyone else.
• Retention: 3 years from receipt of the notice (general limitation period); after that the record is deleted automatically.
• The form uses neither cookies nor reCAPTCHA – protection against bots is a short calculation performed in your browser.