This policy explains how [company or full name] ([legal form], SIREN [SIREN], [address]) (“we”), as controller under the General Data Protection Regulation (GDPR), processes personal data of users of bookeh.app and my.bookeh.app. Contact: [privacy email].
1. Whose data and in what role
- Your data as a Bookeh user — we are the controller.
- Data about your clients, contractors and gallery visitors that you put into your workspace — you are the controller and we are your processor (Art. 28 GDPR), under the Data Processing Agreement.
2. What we process, why, and on what basis
| Data | Purpose | Legal basis |
|---|---|---|
| Email, name, password (hashed) | Account, sign-in, service emails | Contract — Art. 6(1)(b) |
| Phone number | Confirming sign-up, one demo per number | Contract; legitimate interest in preventing abuse — Art. 6(1)(f) |
| Passkeys (public part only) | Sign-in with Face ID, Touch ID, Windows Hello | Contract |
| IP address, country derived from it, sign-in times, browser | Security, rate limiting, checking the regional site | Legitimate interest — Art. 6(1)(f) |
| Payment history, payment method ID and masked card | Subscription, auto-renewal, invoices | Contract; legal obligation (accounting) — Art. 6(1)(c) |
| Language, theme, settings | Running the interface | Contract |
We do not process special categories of data. Face ID and Touch ID work on your device; we only receive the key’s signature. We do not make automated decisions with legal effect about you.
3. Where data is stored
Databases and files of the international site are hosted in France by OVHcloud (OVH SAS).
4. Who receives data
- OVH SAS — hosting, France.
- [payment provider] — payments. Card details are entered with the provider and never reach us.
- [email service] — sending service emails.
- [SMS provider] — the phone number and a one-time code, if you confirm your number by SMS.
- Telegram — only if you choose Telegram to confirm your number: you send your number to our bot yourself. Telegram is established outside the EU and processes it under its own policy.
- Public authorities — only when the law requires it.
Emails to your clients are sent from your own mailbox that you connected, through your own email provider. We do not sell personal data or share it for advertising.
5. Cookies and browser storage
The site and the app use no cookies and no advertising or analytics trackers, so there is no cookie banner. The browser stores only what the interface needs to work:
- your sign-in session;
- chosen language and theme;
- a flag that passkey sign-in is set up on this device;
- a copy of your workspace data for fast start-up, encrypted with a key kept on the server. It cannot be read without a valid sign-in and is erased when you sign out, after 30 days without sign-in, or when another user signs in. You can turn it off in settings or choose “Someone else’s computer” on the sign-in screen.
6. How long we keep data
- Account and workspace data — while the account exists.
- After you delete the account — erased, except an irreversible hash of your phone number (so the demo is not granted twice) and payment records we must keep by law.
- Change log for syncing your devices — 14 days.
- Backups — a limited period, after which they are overwritten.
7. Security
See the Security page: isolation of workspaces in the database, HTTPS, hashed passwords, rate limiting, role-based access.
8. Your rights
You have the right to access, rectify and erase your data, to restrict or object to processing, to data portability, and to withdraw consent where processing is based on it (Arts. 15–21 GDPR). Some of this is available directly in the app: editing your details, signing out on all devices, deleting your account. Write to [privacy email]; we reply within one month. You may also lodge a complaint with the CNIL (cnil.fr) or the authority of your country.
9. Changes
We publish new versions on this page and email you about significant changes.