Privacy Policy for Guests.

1. Who Is Responsible for Your Data

Chivent is operated by Chelodo B.V., registered in The Netherlands. Who is responsible for your personal data depends on how you use Chivent.

1.1. Events

The host decides how its event works: who can join, what guests can see and do, and what happens to the photos, videos and guest details collected for it. The host is responsible for that content and those details (as the “controller”), and we process them on the host’s behalf, following the host’s settings (as a “processor”). Questions about how a host uses them are best sent to the host, and we’ll help where we can (see section 9).

We are the controller for the personal data we use for our own purposes, such as keeping the Service secure and preventing abuse, technical logs, error monitoring and analytics, and meeting our legal obligations.

1.2. Visit Albums

The host of a place can’t open its visit albums. We run each album for its group, so we are the controller for the content of the album and the details you give us to start or join it, and for our verification emails, security checks and marketing sign-ups. The host receives a limited set of details about each album (see section 4.2) and is responsible for how it uses them.

2. Information We Collect

What we collect depends on what you do and on the host’s settings.

2.1. When You Use an Event

• Your uploads: the photos, videos and photo notes you upload, any captions you add, and the albums or hashtags you choose.
• File details: each file’s type, size and dimensions, when you uploaded it, and the date it was taken, which we read from the file. Files are stored as your device provides them, so they can include information your device embedded in them, such as the camera model and, if location tagging is on, where a photo was taken.
• Interactions: the comments, reactions and favorites you add.
• Name and email address: if the host turns on guest registration, we ask for your name and email address. We don’t verify the email address. Your details are added to the event’s guest list, which the host can see.

2.2. When You Use a Visit Album

• Name: shown to the members of your group, including next to your uploads. If you start the album, your name is also shown to the host, and if you don’t name the album (or the host doesn’t allow naming), the album is named after you.
• Email address: required to start an album and optional to join one. We confirm it with a 6-digit code and use it to send you emails about your album (see below).
• Album details: if you start the album, the album name you choose and the number of nights. The album name is shown to the host, to your group, and to anyone who opens the album’s invite link.
• Confirmation codes: while we wait for you to enter your code, we keep your request (including your name, email address and marketing choice) for up to 10 minutes, or up to 2 hours if the previous group’s visit hasn’t ended yet. We store the code itself only in hashed form.
• Your choices: when you accepted the Terms of Service for Guests, and whether you agreed to receive marketing emails.
• Membership: whether you started or joined the album, when you joined, whether you added an email address, and whether the creator removed you. If you’re removed, we keep a hashed version of your email address to stop it from joining that album again.
• Device identifier: a random identifier that your browser creates and stores (see section 11). It’s sent to us when you start or join an album.
• Security checks: when an album is started, we record keyed hashes (scrambled values that can’t be turned back into the original without our secret key) of the email address, device identifier and IP address used. We use them to notice when the same email address or device started an album at the same place in the last 30 days. If so, the host is asked to approve the new album and is told the reason, for example “this email started a visit here in the last 30 days,” but not your email address. These records are deleted automatically after 90 days.
• Your uploads and interactions: as for events, the photos, videos, photo notes, captions, comments, reactions and favorites you add, and the file details described in section 2.1.
• Emails we send you: confirmation codes, a welcome email with your album link and visit code, sign-in links you ask for, a reminder before your visit ends, the download link when uploads close, and a message if the host didn’t keep your album. Apart from confirmation codes, we send these only to confirmed email addresses.

2.3. Information Collected Automatically

• Technical and log data: our servers and hosting providers automatically record technical information when you use the Service, such as your IP address, browser and device type, the pages and files requested, and the date and time.
• Rate limiting: to stop people from guessing visit codes or sending too many requests, we count recent attempts using keyed hashes of IP addresses and email addresses. These counters expire after about an hour.
• Browser storage: we keep a sign-in token and a few technical settings in your browser (see section 11).
• Analytics: we use Mixpanel to understand how the Service is used and where it fails. On our pages, including event and album pages, it records events such as uploads that succeed or fail and technical errors, with details such as the event code, the file type and size and, for failed uploads, the file name and error message. Mixpanel also receives your browser and device type and the address of the page, may estimate your approximate location from your IP address, and uses a cookie with a random identifier. We don’t share your name or email address with Mixpanel.
• Error monitoring: we use Sentry to find and fix errors. When something goes wrong, an error report is sent with technical details, such as the page address, your browser and device type, the steps that led to the error, and your IP address.
• Google Tag Manager: our website, including event and album pages, loads Google Tag Manager, a Google tool that loads other scripts we configure, such as measurement tools. These may collect information about your visit and set cookies.
• Content added by the host: if an event page includes content from another service, such as an embedded Google Maps map, that service receives information such as your IP address when the page loads and may set its own cookies, under its own privacy policy.

3. How We Use Your Information and Our Legal Bases

Under the General Data Protection Regulation (GDPR), we only use personal data when we have a legal basis. For event content and guest details that we process on a host’s behalf (section 1.1), the host decides how they are used and is responsible for the legal basis. For everything else, we rely on the following grounds:

• Performance of a Contract: to run the visit album you start or join, confirm your email address, keep you signed in and send you the emails described in section 2.2, and to provide the features you use under our Terms of Service for Guests.
• Legitimate Interests: to keep the Service secure and prevent abuse, for example with technical logs, rate limits and the security checks in section 2.2; to give hosts the limited details they need to manage their place and approve albums (section 4.2); to find and fix errors and understand how the Service is used; and to establish, exercise or defend legal claims. You can object to this use (section 9).
• Consent: to send you marketing emails if you opt in (section 8), and where the law requires consent for cookies or similar technologies. You can withdraw your consent at any time.
• Legal Obligation: to comply with applicable laws and lawful requests from authorities.

Smart tagging: if the host of an event turns on smart tagging, photos and videos uploaded to that event are sent to our AI provider, Google LLC (Gemini model via Google Cloud), to suggest descriptive tags. We do this on the host’s behalf. We do not use your content to train our AI models. Smart tagging isn’t used in visit albums.

We do not sell or rent your personal data.

4. Who Can See Your Information

4.1. Events

• The host and its co-hosts can see and download everything uploaded to the event, see comments and reactions, and see the guest list with the names and email addresses guests entered. The host can delete uploads and comments.
• Other guests and people viewing the event may see your uploads, captions and comments, and how many reactions a file has, depending on the host’s settings. For example, the host can require a password, approve uploads before they appear, or let each guest see only their own uploads. If you entered your name and the host shows guest names, your name appears with your uploads and comments.
• People at the venue may see your uploads if the host shows them on a photo wall.

4.2. Visit Albums

• Members of your group can see everything in the album, together with the name of the person who uploaded it. The creator can also see each member’s name, when they joined and whether they added an email address, but not the address itself.
• Anyone with the visit code or invite link can join the album while the visit is running, and then see it. Anyone who opens the invite link can see the album name and the place.
• The host of the place can never see the album’s photos, videos or other content. The host (and whoever it chooses to receive its approval emails) receives only the album name, its dates and status, the creator’s name, how many members it has, how much storage it uses, and whether it needs approval and why. If you try to start an album while the previous group’s visit is still running, the host is emailed your name so it can end that visit.

4.3. Chivent and Others

• Anyone with a direct link to a file: media files are accessible via their unique URLs, so anyone who has the link to a photo or video can view it without signing in.
• Our staff access personal data only when needed, for example to provide support, handle a report, keep the Service secure or comply with the law.
• Service Providers: the providers that help us run the Service (see section 5).
• Legal Compliance: we may disclose your information if required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: in connection with a merger, acquisition, or sale of assets, your information may be transferred.

5. Service Providers

We work with trusted service providers to run the Service. They may only use personal data to provide their services to us and must protect it. Our main providers for the guest features are currently:

• Cloudflare: hosts our website, delivers content, and stores photos and videos in the storage region the host chose.
• Google (Google Cloud): runs our servers and background jobs, keeps system logs, and stores the ZIP files for visit album downloads until the album is deleted. Google also provides Google Tag Manager and, for events with smart tagging turned on, our AI model (Gemini).
• Mailgun: sends our emails, such as confirmation codes and download links, from its EU region.
• Brevo: manages our mailing list, if you sign up for marketing emails.
• Mixpanel: product analytics.
• Sentry: error monitoring, using its EU data region.
• Database and infrastructure providers that host our databases and other systems.

Services whose content a host adds to its event page, such as Google Maps, are not our service providers. They handle your data under their own privacy policies.

6. International Data Transfers

Your data is stored by default on secure servers located in the European Union. The host can choose where an event’s or visit album’s photos and videos are stored: in the European Union (the default), North America or Australia. Some of our providers process data in other countries. For example, Mixpanel and our AI provider (Google) process data in the United States, and Cloudflare’s global network may handle your requests in a data center near you. When personal data is transferred outside the European Economic Area, we ensure it is protected by appropriate safeguards, such as Standard Contractual Clauses or the EU-U.S. Data Privacy Framework.

7. How Long We Keep Your Data

7.1. Events

• Uploads, comments, reactions and guest details are kept while the event exists. The host can delete them, or the whole event, at any time.
• When the storage period of the host’s plan ends, the event’s photos and videos are deleted automatically, after any grace period.
• Other event data, such as the guest list, comments and reactions, is deleted when the host deletes the event or closes its Chivent account.
• Favorites are removed automatically after 30 days.

7.2. Visit Albums

• The album, including its photos, videos and other content, and members’ names and email addresses, is deleted 30 days after uploads close. After that we keep only anonymous counts, such as how many members, photos and videos the album had.
• If the host rejects an album, or doesn’t confirm it before the visit ends, we email the members who have a confirmed email address and then delete the album.
• If the host closes its Chivent account, its places and visit albums are deleted too, which can happen before uploads close.
• Requests waiting for a confirmation code are kept for up to 10 minutes, or up to 2 hours while waiting for the previous group’s visit to end.
• The security records described in section 2.2 are deleted after 90 days.
• The download link stops working on the date given in the email. The ZIP file is deleted together with the album.

7.3. Other Data

• Rate-limit counters expire after about an hour.
• Technical logs, error reports and analytics data are kept only as long as needed for security, troubleshooting and analytics.
• If you sign up for marketing emails, your name and email address stay on our mailing list until you unsubscribe, even after your album is deleted.
• Information in your browser stays there until it expires or you delete it (see section 11).
• We may keep data for longer where the law requires it, or where we need it to handle a report, a dispute or a legal claim.

8. Marketing Emails

When you start or join a visit album, or add your email address to one, you can tick a box to receive occasional tips and offers from Chivent. The box is never ticked in advance, and you don’t need to tick it to use the album. If you tick it and confirm your email address, we add your name and email address to our mailing list, which is managed by Brevo.

You can withdraw your consent and unsubscribe at any time, using the unsubscribe link in our marketing emails or by emailing contact@chivent.com. Unsubscribing doesn’t affect your album or the service emails about it.

Entering your name and email address for an event’s guest registration doesn’t sign you up for marketing emails from us.

9. Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data:

• Right to Access: You can request copies of your personal data.
• Right to Rectification: You can request that we correct any information you believe is inaccurate.
• Right to Erasure: You can request that we erase your personal data, under certain conditions.
• Right to Restrict Processing: You can request that we restrict the processing of your data.
• Right to Object to Processing: You can object to our processing of your personal data, including processing based on our legitimate interests.
• Right to Data Portability: You can request that we transfer the data we have collected to another organization, or directly to you.
• Right to Withdraw Consent: Where we rely on your consent, you can withdraw it at any time.

9.1. How to Exercise Your Rights

Email us at contact@chivent.com. Tell us which event or place your request is about, for example by including the event link or the place name, and if possible write from the email address you used. We may ask for more information to confirm it’s you. We’ll respond within the time limits set by the GDPR, normally within one month.

• Events: because the host is responsible for event content and guest details, we may pass your request on to the host and help them respond. You can also contact the host directly, for example to ask them to delete a photo. We handle requests about the data we control ourselves (section 1.1) directly.
• Visit albums: we handle your request ourselves. Deleting your details may mean removing you from the album.
• If you appear in a photo or video that someone else uploaded, you can ask the host of the event, or us, to remove it.

You also have the right to lodge a complaint with a data protection authority, such as the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the authority in the country where you live.

10. Children’s Privacy

Our Terms of Service for Guests require guests to be at least 18 years old. Our Service is not directed to individuals under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will take steps to delete it.

Photos and videos of children are often part of events. Only a child’s parent or guardian, or someone with their permission, should upload them. A parent or guardian can ask the host, or us, to remove a photo or video of their child.

11. Cookies and Browser Storage

We use cookies and similar technologies, such as your browser’s local storage, to run the Service. Some are essential; others help us measure and improve the Service.

11.1. Essential

• Sign-in token (_egu_ followed by the event code, as a cookie and in local storage): keeps you signed in to an event or album. It contains the name and email address you entered, if any. For events, the cookie lasts 5 days and the token is valid for up to 60 days. For visit albums, both last until 31 days after uploads close. The local storage copy stays until you clear your browser data or sign out of an event.
• Album pointers (_visit_ and _egp_ keys, local storage): remember which visit album on this device belongs to which place, so scanning the QR code takes you back to your album.
• Device identifier (_chivent_device, local storage): the random identifier used for the visit album security checks in section 2.2.
• Update recovery (session storage): a short-lived flag that helps the page reload once after we release an update.

11.2. Analytics and Monitoring

• Mixpanel sets a cookie with a random identifier to measure how the Service is used (see section 2.3).
• Sentry sends error reports (see section 2.3).
• Google Tag Manager may load measurement tools that set their own cookies.
• Content added by a host, such as an embedded Google Maps map, may set cookies from that provider.

11.3. Your Choices

You can instruct your browser to refuse cookies, or delete cookies and local storage, in your browser settings. If you block or delete the essential ones, you’ll be signed out. At an event, you may need to enter the password or your details again. For a visit album, use “Already joined? Get a sign-in link” (this needs a confirmed email address), or join again with the visit code as a new member. Blocking analytics or monitoring tools shouldn’t affect your use of events or albums.

12. Security

We implement appropriate technical and organizational measures to protect your personal data, such as encrypted connections (HTTPS), access controls, and storing confirmation codes, sign-in links and the security records in section 2.2 only in hashed form. However, no method of transmission over the Internet is 100% secure.

Your sign-in is stored in your browser, so keep your device secure and don’t forward emails that contain links to your album. We are not responsible for unauthorized access resulting from the sharing of links to files or albums.

13. Changes to This Privacy Policy

We may update this Privacy Policy for Guests from time to time. We will post the new policy on this page and update the “Last updated” date. If a change is significant, we’ll take reasonable steps to let you know. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy for Guests or wish to exercise your data protection rights, please contact us:

Email: contact@chivent.com

Address: Chelodo B.V., Lekpoort 9, 2152 HT Nieuw-Vennep, The Netherlands