Privacy Policy

1. Controller

For privacy requests, please use the contact form and choose a clear subject such as “Privacy request”.

2. How SnapKey works

A Host creates a photo space and may connect a personal Google Drive or Dropbox account. Guest images pass through SnapKey only for the technical upload process and are stored in the connected Host account. SnapKey stores the metadata required to operate QR access, permissions and sharing, but does not use its own permanent image storage.

When managed storage is selected, images are stored under a separate project prefix in a private Cloudflare R2 bucket configured for EU jurisdiction. Booked capacity, actual file sizes, storage assignment, expiry and deletion dates are recorded for quota and retention enforcement.

Depending on the event and purpose, the Host may separately be responsible for deciding why images of guests are collected and shared. Guests should contact the Host first about the Host’s intended use of event photos.

3. Data we process

4. Purposes and legal bases

• Providing requested functions: creating photo spaces, authenticating Masters, transferring images, applying permissions and delivering protected galleries (Art. 6(1)(b) GDPR where a contract applies).
• Payment processing: creating, verifying and documenting PayPal payments for managed storage (Art. 6(1)(b) GDPR and, for statutory accounting records, Art. 6(1)(c) GDPR).
• Security and reliable operation: preventing misuse, diagnosing failures and protecting accounts, QR links and infrastructure (Art. 6(1)(f) GDPR).
• Contact and support: responding to enquiries and documenting their resolution (Art. 6(1)(b) or Art. 6(1)(f) GDPR).
• Legal obligations: retaining or disclosing information where required by applicable law (Art. 6(1)(c) GDPR).
• Consent: where a Host or guest is expressly asked to consent, processing is based on Art. 6(1)(a) GDPR and consent may be withdrawn for the future.

5. Cloud storage and OAuth

Connecting a provider redirects the Host to that provider’s official authorization page. SnapKey requests only the scopes shown there and uses the resulting tokens to create or use an application folder, upload files, retrieve authorized images and process requested deletions. Tokens are encrypted at rest and removed from SnapKey when the Host disconnects the provider.

Managed storage currently uses a private Cloudflare R2 bucket configured for EU jurisdiction. Personal customer storage uses Google Drive or Dropbox connected by the Host. Provider availability and capacity remain subject to the selected service and configuration.

SnapKey’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

Google and Dropbox process data under their own privacy policies: Google and Dropbox.

6. Hosting and recipients

SnapKey is delivered using Cloudflare infrastructure. Cloudflare may process network, security and request data to deliver and protect the service. See the Cloudflare Privacy Policy.

Data is disclosed only where needed to operate the service, at the Host’s direction, with service providers acting for us, or where legally required. SnapKey does not sell personal data and does not use uploaded photos to train artificial-intelligence models.

Payments for managed storage are handled by PayPal. PayPal receives the information required to create, approve and capture the transaction and processes it under its own Privacy Statement. SnapKey receives only the transaction details needed to verify payment and prevent reuse.

7. International transfers

Cloudflare, the selected cloud provider and PayPal may process data outside Germany or the European Economic Area. Depending on the provider and service configuration, transfers may rely on an adequacy decision, the EU–US Data Privacy Framework, standard contractual clauses or another lawful safeguard. The provider’s privacy policy contains current details.

8. Cookies and local identifiers

SnapKey uses only technically necessary cookies and local storage:

• snapkey_guest_[project]: recognizes a guest’s own uploads for one photo space on that browser; up to one year.
• snapkey_master: keeps a Master authenticated; up to 12 hours.
• snapkey_share: remembers successful access to a protected gallery; up to 6 hours.
• snapkey_guest_shared: remembers successful access to host-selected guest photos; up to 6 hours.
• snapkey_admin: protects the global administration session; up to 12 hours.
• snapkey-language: stores the expressly selected interface language in local storage until it is changed or browser storage is cleared.

These identifiers are required for access control, service security, and the requested language preference. They do not require prior consent. No analytics, advertising, profiling, or cross-site tracking technologies are used.

9. Retention and deletion

Data is retained only as long as necessary for the photo space, support request, security purpose or applicable legal duty. Application activity-log entries are automatically removed after 30 days. Master and protected-gallery sessions expire automatically. Protected sharing links currently expire after the period shown when created.

Completed DPA records are retained as immutable contract evidence for the applicable statutory limitation and legal-defense period, even if the related photo space is later deleted. They are access-restricted and are not reused for marketing.

Payment identifiers and accounting records are retained for the periods required by tax and commercial law and for payment reconciliation, fraud prevention and legal defense.

Managed-storage projects use the active and grace periods shown during creation and in the Master dashboard. Guest and public sharing access ends at expiry. During the grace period, authenticated Master export remains possible. Managed photos and sharing records are automatically deleted after the grace period. Customer-controlled cloud files remain under the Customer’s control until the Customer or an authorized SnapKey function deletes them.

Deleting a photo through SnapKey removes its SnapKey metadata after requesting deletion from the cloud provider. Disconnecting a cloud account deletes stored OAuth credentials from SnapKey but does not delete files in that provider account. Contact us to request deletion of a photo space or support message. Provider backups and recovery windows remain governed by the selected provider.

10. Security

SnapKey uses encrypted HTTPS connections, random access tokens, password hashing, encrypted OAuth tokens, time-limited sessions, permission checks and private-by-default guest galleries. No internet service can guarantee absolute security. Hosts should use strong, unique passwords and protect Master QR codes and sharing credentials.

11. Your rights

Subject to the legal requirements, you may request access, correction, deletion, restriction, portability or objection to processing. You may withdraw consent for future processing and lodge a complaint with a competent data-protection supervisory authority. We may need information to verify your identity and locate the relevant photo space or upload.

12. Children and images of other people

SnapKey is not directed at children acting independently. Hosts and uploaders must ensure that any required permission from parents, guardians or depicted persons has been obtained before collecting or sharing their images.

13. Changes

This policy may be updated when the service, providers or legal requirements change. The current version and effective date will remain available on this page.