Privacy Policy - lovely.gift

1. Who is responsible for your information?

lovely.gift, available at https://lovely.gift, is operated by Jakub Mielczarek, trading as Zew Software Jakub Mielczarek, a sole trader registered in Poland's Central Register and Information on Economic Activity (CEIDG), with business address Harcerska 40, 98-300 Gaszyn, NIP 8322104577. This person is the controller of the personal data described in this policy.

This policy applies to website visitors, gift purchasers, recipients and people who contact us. It explains our processing under the EU General Data Protection Regulation (GDPR). Additional mandatory rights under the laws applicable to you remain available.

2. What we collect and where it comes from

Gift and order information. The purchaser supplies a selected gift, sender display name, recipient display name and personal message. We create order identifiers, access tokens and payment-status records. A draft may be stored in the purchaser's browser; submitting it to checkout also creates a record on our server, even if payment is not completed. Use a first name or nickname where that is enough.

Recipient information. If someone sends you a gift, we receive the name and message they entered from that person, not directly from you. The message may contain information about other people. The sender is the source of that content; a displayed sender name is not proof of identity. You can contact us to ask about the source and the information held about you. The purchaser supplies the recipient's email address so we can send the gift link; we do not ask for a telephone number.

Payments. Payment details are entered into Stripe's hosted checkout, where Sold through Link, LLC, a Stripe affiliate, acts as merchant of record. Stripe and Link handle card information; our gift database does not store full card numbers or security codes. We receive or can access order/payment references, status, amount, tax, currency and the billing/contact information made available through Stripe, including the purchaser's email address and billing country. Required billing or tax details depend on the transaction. We send Stripe an order reference and product/payment information; our checkout integration does not put the personal gift message into Stripe metadata.

Website and security information. Requests to the site and its infrastructure may disclose IP address, request time, browser/device information, requested resources, errors and security events to us or our hosting providers. Our hosting provider derives your country from your IP address; we use it only to show the price in your currency and keep only the resulting currency with your order. Opening a gift retrieves the content associated with its link.

Correspondence. When you contact us or send a withdrawal notice, we process your contact details, message, relevant order details and information needed to handle the request. Please do not send card security codes, passwords or unnecessary identity documents.

3. Why we process information

Purpose	Information normally involved	GDPR basis
Prepare a requested purchase, take payment, supply the gift and support the purchaser	Purchaser/order details and necessary correspondence	Performance of a contract or requested pre-contractual steps, Article 6(1)(b)
Create and display a gift referring to someone who is not the purchaser	Recipient display name and personal message	Legitimate interests, Article 6(1)(f): enabling a limited, personal gifting service, balanced against the recipient's rights
Protect the site, investigate abuse and prevent fraud	Technical events and relevant order information	Legitimate interests, Article 6(1)(f): keeping the service and users secure
Meet accounting, tax, consumer-law and other binding legal duties, including handling complaints and withdrawals	Required transaction records, complaint and withdrawal records	Legal obligation, Article 6(1)(c)
Establish, exercise or defend legal claims	Relevant correspondence and limited evidence	Legitimate interests, Article 6(1)(f): resolving disputes and protecting legal rights
Answer a non-contractual question	Contact details and correspondence	Legitimate interests, Article 6(1)(f): responding to people who contact us

We do not rely on the purchaser's contract as the legal basis for processing a recipient's information. Where we rely on legitimate interests, you may object as explained below.

We do not use gift messages for advertising or to train AI models. We do not sell personal information or share it for cross-context behavioural advertising. The current service has no advertising or optional analytics integrations. If we introduce optional consent-based processing, we will explain it and obtain consent where required before it starts; consent can then be withdrawn without affecting earlier lawful processing.

4. Who can see a gift?

A gift link functions as an access key. Anyone who has the link may open the gift and read the names and message. There is no recipient login or password. A sender or recipient may forward the link, take screenshots or publish it elsewhere. Only share it with people you want to see the gift.

This is not an end-to-end encrypted messaging service. Authorised personnel and service providers may access information where needed for hosting, support, security or legal compliance. Contact contact@lovely.gift if a gift exposes your information or is abusive, or if you want us to consider disabling access. We may need proportionate information to verify and assess the request; possession of a public link alone does not establish ownership of every person's information in it.

5. Providers and other disclosures

We disclose only information needed for the relevant purpose. Our providers are:

Provider	Role and data involved
Stripe Payments Europe, Limited (Ireland) and Sold through Link, LLC (USA), a Stripe affiliate	Payment processing and, as merchant of record, receipts, invoices, indirect tax, payment support, payment refunds and disputes, together with fraud prevention; payment/billing information, purchaser email address, billing country and transaction references. Stripe and Link act as independent controllers for their own services and, for some activities, on our behalf. Address suggestions on Stripe's checkout page are provided by Stripe using Google Maps. See stripe.com/privacy and link.com/privacy.
Cloudflare, Inc. (USA)	Website delivery, application execution, database storage (Cloudflare D1, kept in Cloudflare's EU jurisdiction), logs and infrastructure security; gift/order data and request information. Processor acting on our behalf. See cloudflare.com/privacypolicy.
Plus Five Five, Inc., trading as Resend (USA)	Sending the gift link, order confirmation, recipient notice and withdrawal acknowledgements; purchaser and recipient email addresses, display names, gift link and order details. Processor acting on our behalf. See resend.com/legal/privacy-policy.
Zoho Corporation B.V. (Netherlands)	The mailbox for contact@lovely.gift and gifts@lovely.gift; support correspondence, complaints, withdrawal notices and replies to gift emails. Processor acting on our behalf. See zoho.com/privacy.
Accounting office and legal advisers engaged by us	Necessary financial records, compliance advice and dispute handling, subject to applicable confidentiality duties. We name them on request.

We may disclose relevant information to courts, regulators, law-enforcement bodies or other parties when legally required, or where lawfully necessary to protect rights. A business transfer involving personal data would require an appropriate legal basis, safeguards and notice; it is not an unrestricted permission to sell your information.

6. International processing

Some providers process information or permit access outside the European Economic Area. The arrangements used for this service are:

Cloudflare, Inc. and Resend (Plus Five Five, Inc.), USA: both are certified under the EU–US Data Privacy Framework, covered by the European Commission's adequacy decision of 10 July 2023, and their data processing agreements also contain the Commission's standard contractual clauses. Resend stores email content and delivery logs in the United States. Cloudflare handles requests across its global network, while our order database is kept in Cloudflare's EU jurisdiction.
Stripe and Link, USA and other countries: Stripe transfers data under the Commission's standard contractual clauses and, for Stripe, LLC, the EU–US Data Privacy Framework.
Zoho, India and USA: mailbox data is stored in Zoho's EU data centres; Zoho group companies, including in India and the United States, may access it under an intra-group agreement based on the Commission's standard contractual clauses.

A US provider's participation in the EU–US Data Privacy Framework can be relied upon only where the relevant entity, certification and processing are covered and the decision remains valid. You can request information about the safeguards, including an appropriately redacted copy where applicable, at contact@lovely.gift.

7. How long we retain information

Information	Retention period or criterion
Browser checkout draft	Stored in session storage until cleared by the application or browser. Browser session restoration may preserve it longer than a single visit. You can clear the site's browser storage yourself.
Unpaid or abandoned server-side orders	Deleted automatically 7 days after creation. If a refund was issued, we clear gift text, email addresses and billing country after 7 days and keep a minimal transaction record (order number, amounts, tax, dates and payment reference) until the end of the sixth calendar year after the purchase, when it is deleted automatically. A payment held for our review is kept until we resolve it.
Paid gift names, messages and access links	The gift is available for 30 days from payment confirmation. After expiry, the app clears gift text and email addresses. A minimal order record (order number, gift type, amounts, tax, billing country, dates, payment reference and the copy of the Terms you accepted) remains until the end of the sixth calendar year after the purchase, when it is deleted automatically.
Accounting/tax records	Until the tax liability becomes time-barred: 5 years from the end of the calendar year in which the tax payment deadline expired (Polish Tax Ordinance, art. 70 and 86). Receipts and tax invoices for the transaction are issued and kept by Link as merchant of record. Personal gift messages are not retained merely because an invoice must be kept.
Support, complaints, withdrawal notices and claims evidence	Until the end of the sixth calendar year after the matter is closed, matching the general limitation period for claims under the Polish Civil Code (art. 118), or longer during an ongoing dispute; only relevant evidence is retained.
Technical/security logs	Our application logs in Cloudflare are kept for up to 3 days and contain technical events and order numbers, not gift messages or email addresses. Our email provider keeps delivery logs under its own retention settings. Selected records may be kept longer to investigate an incident or meet a legal obligation.
Backup copies	Database point-in-time recovery data is kept by Cloudflare for up to 7 days and then overwritten; access and use remain restricted.

Where a legal duty or dispute requires longer retention, we limit it to the necessary records and period. We then delete or irreversibly anonymise the information. Providers acting as independent controllers may apply their own lawful retention rules, described in their notices.

8. Cookies and browser storage

The gift flow uses session storage, including a checkout draft and order-recovery identifiers, so it can restore a checkout and retrieve the paid gift link. This is used for the requested purchase flow, not advertising. Disabling necessary storage or JavaScript can prevent that flow from working.

This website does not set its own cookies and does not use analytics or advertising technologies. Stripe's checkout page (checkout.stripe.com) and Link set their own cookies for payment, fraud prevention and security, as described in Stripe's privacy policy. Cloudflare may set strictly necessary security cookies when protecting the site from automated traffic. We request permission before setting non-essential technologies where required. We do not treat accepting our Terms as consent to advertising or optional tracking.

We remember your chosen language in localStorage under lovely-language until you change it or clear site storage. The lang URL parameter preserves the selected language in shared links. Switching languages temporarily saves your unfinished gift form in sessionStorage so you do not lose your message. These features are not used for advertising.

9. Your rights

Subject to applicable conditions, you can request access to your personal data, correction, deletion, restriction of processing and a portable copy of data processed automatically on the basis of consent or your contract. You may object to processing based on legitimate interests for reasons relating to your situation. If processing is based on consent, you can withdraw it at any time. These rights may be limited where, for example, records must be retained by law or another person's rights must be protected.

Contact contact@lovely.gift. We may request proportionate verification. We normally respond without undue delay and within one month. Where permitted for complex or numerous requests, we may extend this by up to two further months and explain the extension within the first month. Requests are ordinarily free; statutory exceptions for manifestly unfounded or excessive requests remain applicable.

You may complain to the President of the Personal Data Protection Office in Poland (Prezes Urzędu Ochrony Danych Osobowych), https://uodo.gov.pl, or another competent supervisory authority, including in the EEA country where you live or work. You need not contact us first.

We do not make solely automated decisions with legal or similarly significant effects about you in the gift application. Stripe may use automated fraud or payment-risk processes under its own applicable arrangements and privacy information.

10. Required information, children and sensitive content

We need the order information marked as required to provide the selected gift and process payment. Without it, we may be unable to complete the purchase. Optional content can be omitted where the form permits. We do not need recipients' full legal names or postal addresses; the recipient's email address is required so we can send them the gift link.

Purchases are intended for adults aged 18 or over. The service is not directed at children. Do not include a child's full identifying details, location, contact information or sensitive information. If you believe a child's information has been used inappropriately, contact us for assessment and appropriate action.

Do not include medical records, payment credentials, identity documents, or information revealing another person's health, sexual life, religion or other sensitive matters. The gifting service is not designed to collect special-category data. Contact us if such information appears in a gift without an appropriate basis.

11. Changes to this policy

We update this policy when our processing changes or legal requirements change. This version is effective from 4 October 2026. Where required, we provide additional notice or obtain consent before a material new use. A policy update does not retrospectively authorise otherwise unlawful processing.