Privacy policy

Last updated: 26 October 2026

1. Controller

2. In short

• There are no user accounts and we never ask for email addresses.
• The application does not store IP addresses and uses no analytics or tracking tools.
• All data of a room is deleted automatically and permanently on its expiry date (after 365 days at the latest).

3. Hosting

The website is hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, in a data centre in Germany, under a data processing agreement pursuant to Art. 28 GDPR. When you open the site, your IP address is transmitted for technical reasons in order to deliver the page. Our web server keeps no access or error logs containing IP addresses; we do not store IP addresses. The legal basis is our legitimate interest in secure and efficient operation (Art. 6(1)(f) GDPR).

4. Data in a Secret Santa room

When you create or join a room, we process:

• the room name and the chosen lifetime,
• your (freely chosen) name,
• your PIN – exclusively as a cryptographic hash (salted scrypt); the PIN itself is never stored,
• exclusions set by the admin and, after the draw, the assignments,
• timestamps of creation, draw and expiry, and failed login attempts.

The purpose is to run the Secret Santa draw you request by using the service (Art. 6(1)(b) GDPR). Your name is visible to all participants of the room who know the room link and log in. The room's admin can look up single assignments, for example when someone forgot their PIN. The room link is a secret: anyone who knows it can join the room. Only share it with the people who should take part.

A name and a PIN are required to take part; without them you cannot join a room. The draw assigns participants at random. There is no automated decision-making or profiling within the meaning of Art. 22 GDPR.

All data of a room is deleted automatically on the expiry date and overwritten in the database. The room's admin can remove the room at any time via “Delete room”, which immediately deletes all participants, exclusions and assignments. As a participant without admin rights you can request earlier deletion from the admin or from the controller by providing the room link.

5. Cookies

We only use strictly necessary cookies (§ 25(2) no. 2 of the German TDDDG):

• secret-santa – encrypted session cookie that keeps you logged in to the rooms you joined. Lifetime 90 days.
• i18n_locale – remembers the chosen language. Lifetime 1 year.

6. No analytics, no tracking

We use no web analytics services, no social media plugins and no third-party fonts or scripts.

7. Contact by email

If you email us, we process your email address, your name if given, and the content of your message in order to answer your request. The legal basis is our legitimate interest in replying (Art. 6(1)(f) GDPR) and, for requests about your data protection rights, our legal obligations (Art. 6(1)(c) GDPR). The mailbox is operated by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany, under a data processing agreement pursuant to Art. 28 GDPR. We delete emails once the request has been dealt with. Requests about data protection rights are kept for up to three years as evidence.

8. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You may withdraw any consent at any time. Please use the contact details above. You also have the right to lodge a complaint with a data protection supervisory authority, for example the one responsible for your place of residence.

Note: as we store no accounts and no email addresses, we can only identify your data if you tell us the room link and your name in the room.

9. Security

The connection is encrypted end-to-end with TLS. PINs are stored only as hashes, logins are rate-limited against guessing, and deleted data is overwritten in the database.