Privacy

Incognito is built to work with as little data as possible. No accounts, no emails, no phone numbers.

What is stored

• The name of the draw, the exchange date and the budget.
• The participants’ names exactly as the organizer types them. A nickname is fine.
• The result of the draw and the wish list each person chooses to write.
• Whether each slip has been opened or not, so the organizer knows who to remind.

Who can see it

• Each participant sees their own name, who they’re buying for and that person’s wish list.
• The organizer sees the names and which slips have been opened. They don’t see the result of the draw.
• The links are the key: anyone with the link to a slip can open it. Don’t forward it.

For how long

Each draw is deleted automatically 60 days after the exchange date (or after it was created, if no date was set). If you want it deleted sooner, write to us and include the link to the draw panel.

Where

The data is hosted on Google Cloud (Firebase), which acts as data processor. Like any web server, it temporarily logs the IP address of requests for technical and security reasons. If any data is processed outside the European Economic Area, this is done under the European Commission’s standard contractual clauses.

Cookies and storage on your device

Incognito doesn’t use cookies or any analytics or advertising tools. Your browser stores only the list of draws you created, so you can get back to their panels, the language if you pick one yourself, and a copy of the pages so they load faster. You can clear it from your browser settings.

Links to stores

The store buttons are affiliate links. When you click one you leave Incognito, and the store may use its own cookies to attribute the purchase, in line with its own policy. We don’t send stores any names or details from the draw: only the search text.

Data controller

• C2Developers S.I., NIF J71554372
• C/ de la Cultura 5-7, Oficina D, 31010 Barañain, Navarra, España
• info@c2developers.com
• Data protection officer: BM GESTDATA, S.L. (ONTIDATA), Avda. Albaida 19, 46870 Ontinyent (Valencia), dpd@ontidata.es

Data is processed in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights. The legal basis is the organizer’s legitimate interest in arranging a gift exchange among people who know each other. No automated decisions that affect you are made, no profiling is carried out, and no data is sold or disclosed to third parties.

Your rights

You can request access to, rectification or erasure of your data, restriction of or objection to its processing, or its portability, by writing to info@c2developers.com. If you believe your request hasn’t been handled properly, you can lodge a complaint with the Spanish Data Protection Agency (aepd.es).

This page is a translation. In case of any discrepancy, the Spanish version prevails.