Privacy Policy

1. Controller

The controller within the meaning of the EU General Data Protection Regulation (GDPR) is:

2. General information on data processing

Sakekeep lets you create collaborative memory books, collect contributions and photos, design book pages, and generate print-ready PDF files. We process personal data only to the extent necessary for these purposes, for secure operation of the service, or on the basis of your consent.

The applicable legal basis is stated for each processing activity below. Where no specific retention period is given, we delete personal data as soon as the purpose of its processing no longer applies and no statutory retention obligations or legitimate grounds require further storage.

3. Provision and hosting

The application is operated on infrastructure provided by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. When you access the service, technically necessary connection data may be processed. This includes in particular your IP address, date and time of access, the requested URL, the amount of data transferred, the HTTP status, the referrer URL, and browser and operating system information.

This processing serves the secure and reliable provision of the service, error analysis, and the prevention of abusive access. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure and uninterrupted operation of the application. We have entered into a data processing agreement with Hetzner pursuant to Art. 28 GDPR.

Security-related log data is stored only for as long as it is required for the purposes stated above and is then deleted, unless a specific security incident requires longer retention.

4. Domain Name System via Cloudflare

For the technical resolution of our domain we use DNS services provided by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Technically necessary DNS and connection information may be processed in this context. We do not use Cloudflare to create usage profiles, and our website traffic is not routed through Cloudflare's proxy.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the fast, resilient, and attack-protected availability of our service. Where data is transferred to the USA, Cloudflare relies in particular on the EU-US Data Privacy Framework and supplementary contractual safeguards. A Data Processing Addendum is in place with Cloudflare.

5. User accounts and sign-in with Clerk

For sign-in and the management of organizer accounts we use Clerk, a service provided by Clerk, Inc., 660 King Street, Unit 345, San Francisco, CA 94107, USA. The data processed may include in particular your email address, name, user ID, sign-in timestamps, IP address, device and browser information, and session and security data. Clerk sets technically necessary cookies and similar storage mechanisms to maintain your session and to protect against abuse.

This processing takes place to provide and secure your user account on the basis of Art. 6(1)(b) and Art. 6(1)(f) GDPR. The legitimate interest lies in protecting accounts and non-public project areas. Data processing by Clerk on our behalf is governed by Clerk's Data Processing Addendum, which forms part of our agreement with Clerk. Where Clerk processes certain data for its own purposes, such as managing its contractual relationship or complying with its own legal obligations, Clerk acts as an independent controller in that respect. Transfers of data to the USA are based in particular on the EU-US Data Privacy Framework and, where required, on Standard Contractual Clauses. For further information, see Clerk's GDPR notes and Data Processing Addendum.

Account data is generally processed for the lifetime of the user account and removed after its deletion, unless statutory obligations or security reasons require limited further retention.

6. Projects, contributions, photos, and exports

When you use Sakekeep, we process the project information and questions created by the organizer as well as the answers and photos submitted by contributors. Depending on their content, this data may include names, personal memories, opinions, links, and information about persons depicted or mentioned. We also process technical identifiers, submission timestamps, layout data, and the resulting book pages, preview images, and PDF exports.

This processing serves exclusively the collection, design, provision, and export of the respective memory book. For organizers, it is based on Art. 6(1)(b) GDPR. Content voluntarily submitted by contributors is processed on the basis of their consent pursuant to Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with effect for the future by email to the contact address stated above. The lawfulness of processing carried out before the withdrawal remains unaffected.

Contributors should not submit special categories of personal data within the meaning of Art. 9 GDPR and should only upload photos of, or information about, other persons if they are entitled to do so. Contributions are made via a project-specific link. This link must be treated confidentially and shared only with the intended contributors. Where contributions contain personal data about third parties, such as persons shown in photos, it is generally impossible or would involve disproportionate effort for us to inform those persons individually (Art. 14(5)(b) GDPR); this privacy policy therefore serves as the public source of information about the processing.

Project content remains stored until it is deleted by the organizer, consent is effectively withdrawn, or the purpose of the project no longer applies, unless overriding statutory grounds prevent deletion. When a project is deleted, the associated answers, images, preview files, and exports are scheduled for deletion as well.

7. File storage with Hetzner

Uploaded photos, the preview images generated from them, design files, and PDF exports are stored in S3-compatible object storage provided by Hetzner Online GmbH, Industriestraße 25, 91710 Gunzenhausen, Germany. Storage takes place to provide the features described in section 6.

Depending on the data subject, the legal basis is Art. 6(1)(b) or Art. 6(1)(a) GDPR. We have entered into a data processing agreement with Hetzner pursuant to Art. 28 GDPR. Files are removed in accordance with the deletion rules that apply to the respective project.

8. Local contribution drafts

Answers that have not yet been submitted and selected images may be stored locally in the contributor's browser. This allows a contribution to be resumed after a page reload or an interruption. Draft data is transferred to our servers only when the contribution is submitted.

This local storage is necessary for the draft feature expressly requested by the user and takes place in accordance with Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG) and Art. 6(1)(b) GDPR. It can be ended by deleting the website data in your browser.

9. Analytics and error reporting with PostHog

With your consent, we use PostHog, an analytics service provided by PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA, with data processed on servers in the European Union. PostHog helps us understand how the application is used (for example pageviews and feature usage) and to detect errors that occur in your browser. When analytics is active, PostHog stores identifiers in cookies and in your browser's localStorage for up to 365 days. If you are signed in, your account ID is linked to your analytics profile so that your usage can be attributed to one profile across devices; we do not transmit your email address for this purpose. Analytics requests are routed through our own servers, and we do not forward your IP address to PostHog.

Analytics only runs after you have given consent via the cookie banner. The legal basis is your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Your consent decision is stored in your browser for 365 days. You can withdraw or change your consent at any time with effect for the future via the “Cookie settings” link in the page footer. A data processing agreement pursuant to Art. 28 GDPR is in place with PostHog. For more information, see PostHog’s privacy policy and Data Processing Agreement.

Independently of your consent, technical errors that occur on our servers are reported to PostHog so that we can detect and fix faults. These server error reports do not contain user IDs, email addresses, or IP addresses. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the reliable operation of the service.

10. Recipients and processors

Personal data is shared only with those service providers that we need to operate the application and that are described above. Where these companies process data on our behalf, they have been contractually bound in accordance with Art. 28 GDPR. We do not share personal data for advertising purposes and we do not sell personal data.

11. Your rights

Subject to the statutory requirements, you have in particular the right to:

• access the personal data we process about you (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure of your data (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• object to processing based on Art. 6(1)(e) or (f) GDPR (Art. 21 GDPR), and
• withdraw consent with effect for the future (Art. 7(3) GDPR).

To exercise your rights, a message to the email address stated above is sufficient. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is generally the Hamburg Commissioner for Data Protection and Freedom of Information (Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit).

12. Right to object to processing based on legitimate interests

13. Updates to this privacy policy

We update this privacy policy when features, service providers, or legal requirements change. The version published on this page applies.