Privacy Policy

1. General

We process your personal data when you use our app or website. The processing takes place in accordance with the GDPR and the Austrian Data Protection Act in its current version.

The following data protection provisions explain which data we store for what and for how long. It also describes which analytics software we use and to whom the data is passed on.

2. Responsible

The person responsible for data processing is Juri Seelmann, who can be reached at the email address .

3. What data do we collect and process

We process personal data that you provide to us as a user of the app or the website. These data are listed below:

These data are processed only for sending and displaying the Secret Santa results and are stored exclusively for this purpose.

4. Use of External Services

4.1. Google Analytics:

This website uses the “Google Analytics” service offered by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to analyze website usage by users. The service uses "cookies" - text files that are stored on your device. The information collected by the cookies is usually sent to a Google server in the USA and stored there.

IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area. This abbreviation eliminates the personal reference to your IP address. As part of the contract data agreement, which the website operators have concluded with Google Inc., Google Inc. uses the information collected to compile an evaluation of website usage and website activity and provides services related to internet usage.

You have the option of preventing the storage of cookies on your device by making the appropriate settings in your browser. There is no guarantee that you will be able to access all functions of this website without restrictions if your browser does not allow cookies. You can also use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to Google Inc. and used by Google Inc. The following link takes you to the corresponding plugin:

You can find more information on data usage by Google Inc. here:

4.2. Google Analytics for mobile devices (Firebase):

We use Google Analytics for mobile devices for our app on Android. You can find more information here:

The data is forwarded to Google in encrypted form. We use this to analyze and improve the use of the app.

4.3. Google Analytics Remarketing, AdWords, Double Click:

Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

This function enables the advertising target groups created with Google Analytics Remarketing to be linked with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-related, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have given your consent, Google will link your web and app browser history to your Google account for this purpose. In this way, the same personalized advertising messages can be displayed on every device on which you log in with your Google account.

To support this function, Google Analytics collects Google-authenticated user IDs, which are temporarily linked to our Google Analytics data in order to define and create target groups for cross-device advertising.

You can permanently object to cross-device remarketing / targeting by deactivating personalized advertising in your Google account; follow this link:

Further information and the data protection provisions can be found in Google's data protection declaration at:

4.4. Amazon Associate:

We may use the Amazon Associate program to link some content to Amazon. These Amazon links are clearly marked as affiliate link (e.g., "Amazon Affiliate-Link"). As an Amazon Associate we earn from qualifying purchases.

Each user can decide on his/her own, whether to used/follow these links or not. We are not collecting any information for Amazon or sharing information with Amazon. Nevertheless, after following these links Amazon is responsible for their website and the corresponding privacy information.

4.5. Cookies:

Our website uses so-called cookies. These are small text files that are stored on your device with the help of the browser. They do no harm.

We use cookies to make our offer user-friendly. Some cookies remain stored on your device until you delete them. They enable us to recognize your browser the next time you visit.

If you do not want this, you can set up your browser so that it informs you about the setting of cookies, and you only allow this in individual cases. Deactivating cookies may restrict the functionality of our website.

5. Devices and location information

When using the Secret-Santa-App and our website, we receive the following data:

6. Why we process data

We process the data to ensure smooth use of the app and website.

6.1. Provision of services:

Feedback: We process feedback in order to process and answer user concerns. The feedback is also used for further app development.

Advertising: The effectiveness of the advertisements for registered users is measured. The information provided is used to display local and relevant advertisements to each user individually.

Contact: We use user information to contact the user in the event of a complaint or other matters.

7. Minors

Minors may only download and use the app when accompanied by an adult.

8. Transfer of data to third parties

We pass on data to third parties if this is necessary for the purposes described above, at the request of a national authority, on the basis of a court judgment, if required by the law, if necessary in order to defend ourselves against any claims or allegations of third parties in order to protect the rights and to exercise or protect the safety of us, our members, staff or employees.

We will try to inform you of legal requirements regarding your data when we deem it appropriate, unless prohibited by law, court order, or an emergency. We can challenge such claims if we believe the claims are excessive, vague, or inadequate.


Your data will be released to the people you have selected so that they can be notified of the result of the drawing by email.

Passing on to service providers

We share your information with third parties who help us deliver and improve our products (e.g. maintenance, analysis, payments, fraud detection, marketing and development). Service providers have access to your data insofar as this is necessary for the performance of these tasks on our behalf and are obliged not to pass them on or use them for other purposes. We use processors like Adjust and Google.

9. How long will your data be stored

Your data will be saved until you delete it yourself. As soon as you delete your data, only data that is required by law (due to warranty, statute of limitations or retention periods) or otherwise required will be saved.

Simply uninstalling or deleting the app does not delete your saved data.

10. Your rights

10.1. information desk

You have the right to request information from us about how we use which of your data. You can request a copy of your data processed by us. Exercising your right to information must not affect the rights of other people.

10.2. Rectification

You have the right to request that your data be corrected. If, despite our efforts to ensure that the data is correct and up-to-date, incorrect information is stored, we will correct it at your request.

10.3. deletion

You have the right to request the deletion of your data, provided that it is not processed on a legal basis that prevents the deletion. If the legal requirements for deletion are met, we will carry out the desired deletion immediately.

10.4. Restriction

You have the right to request that processing be restricted for the same reasons as with a right to erasure. In this case, the data must remain stored (e.g. to preserve evidence), but may no longer be used for any other purpose.

10.5. Data portability

You have the right to receive the data that you have made available to us in a commonly used machine-readable format if the processing is based on your consent or the performance of a contract.

10.6. Contradiction

You have the right to object to data processing that is carried out on the basis of a legitimate interest. We are legally obliged to weigh your interests against our own in this case. If the result is an outweighing of our interests, we will reject the objection with justification. Otherwise, we will stop the corresponding data processing immediately.

10.7. Complaint

If you are of the opinion that we have violated Austrian data protection law when processing your data and have thereby violated your rights, we ask you to contact us in order to be able to clarify any questions. Of course, you also have the right to complain to the Austrian data protection authority.

10.8. Revocation

Consents given can be revoked at any time in writing and free of charge. To do this, please send an email to the office to which you have given your consent.

Please contact Juri Seelmann with your data protection concerns,

Knollerstrasse 5, 6020 Innsbruck, or to

11. Other important information

According to the GDPR, we are required to have data minimization. This means that we are only allowed to receive data that is also relevant for our services and for which there is a reason to receive it from the users.

Due to the data protection laws, we are only allowed to save and process your data if we have a legal basis for processing. The legality of the data processing results from:

Our interests are your protection and protection against security threats or fraud, compliance with laws, the further development and improvement of our products through analysis and statistics.

12. Data protection

We undertake to protect your data and to take appropriate technical and organizational security measures to protect it from unauthorized or unlawful processing and from accidental loss, destruction or damage. These security measures are constantly adapted to the latest technological developments.

13. Changes to the privacy policy

We can change these data protection regulations at any time.

If significant changes have been made, we will expressly inform you via the app or an e-mail so that you can review the changes.