Privacy Policy
Last updated: 3 November 2026
Tronche! attaches the utmost importance to the protection of your personal data. This privacy policy describes the data we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR / RGPD — EU 2016/679).
1. Data controller
The legal entity in charge of the processing is:
- Karl Cosse — sole trader (micro-enterprise)
- Address: 10 chemin de la Sablière, 33650 Saucats, France
- SIRET: 512 678 822 00044
- Contact: contact@tronche.net
Tronche! plays two distinct GDPR roles depending on the category of data:
- Data controller for: user account, IAP purchases, security logs and technical data (cf. §2).
- Processor within the meaning of article 28 of the GDPR for: the photos collected through the event galleries. The data controller for these photos is the event organiser (the account holder who created the event), in accordance with the Terms of Use §4.
2. Data collected
| Category | Data | Legal basis | Retention period |
|---|---|---|---|
| User account | Email address, hashed password | Performance of the contract | Lifetime of the account + 30 days after deletion |
| Events | First names of the couple, date, event settings | Performance of the contract | Lifetime of the account + deletion on gallery expiry |
| Photos | Image files (EXIF stripped), metadata (date, size) | Performance of the contract | 30 days (Free plan) to 90 days (Premium plan) from the date of the event, extendable by cumulative extensions; definitive erasure 37 days after expiry |
| Guest emails | Email address of photo recipients | Explicit consent (see §3) | 30 days after sending, then automatic deletion |
| Server logs | IP, user-agent, request timestamp | Legitimate interest (security, abuse prevention) | 30 days |
| Server access log | Date, visitor's IP address, address and source port of the Cloudflare relay, protocol, method, site, address of the requested page, status, size and duration of the response | Legitimate interest (security, investigation after an incident) | Set to 180 days at most; the oldest data goes sooner if traffic fills the allotted space |
| Technical data (OS, OS version, app version) | OS type, OS version, application version | Legitimate interest (diagnostics, quality of service) | Lifetime of the account |
| Crash reports | Error type, message, code trace, OS and app version, IP address | Legitimate interest (diagnostics, quality of service) | IP erased after 30 days; report deleted after 12 months |
| Purchases (IAP) | Apple/Google transaction identifier, amount, currency, date | Performance of the contract + legal obligation (accounting) | 10 years (art. L123-22 of the French Commercial Code) |
Audit log. Sensitive operations (deleting an account or an event, changing a password, handling a GDPR request) are recorded in a log with their date, their type and the email address of the account concerned. This log is used to prove what was deleted and when. It is not erased with the account: each entry, email address included, is kept for 3 years and then deleted.
Server access log. The entry server, which receives requests before the application does, keeps its own log, separate from the "Server logs" above. This log is used only for security and for investigating an incident: no statistical or commercial use. It keeps no request or response headers (cookies, authentication token, referring page, browser…) and no TLS information. In a page address, the values of sensitive parameters (token, code, password…) are masked, but an identifier placed in the path of the address, such as a gallery code, remains visible. This log is stored on the Hostinger server (§6). It contains no account identifier and no email address: it is not erased with the account or on request, and each line disappears on its own within the period stated above.
Technical data
To ensure quality of service and diagnostics, the application transmits on each change:
- The operating system type (iOS or Android);
- The operating system version;
- The version of the Tronche! application.
This information is technical data: it does not contain any direct personal data (no device identifier, no IMEI, no location). It is used to diagnose incidents and adapt features to OS capabilities.
If the app crashes, a technical report (error type, message, code trace) is automatically sent to our servers to diagnose the problem, together with the operating system and app version mentioned above. This report is not linked to your account and does not contain your name, email or photos. The connection IP address stored with the report is erased after 30 days.
3. Guest emails — consent and use
Guest emails are collected solely to send a specific photo, at the explicit request of the person photographed.
The photobooth participant enters their own email address in the application to receive their photo. This email:
- Is used exclusively to send the requested photo
- Is never used for marketing or commercial purposes
- Is not shared with third parties
- Is automatically deleted 30 days after sending
The email message sent contains a clear statement indicating that the address was used solely for this delivery.
4. Photo processing and EXIF
During upload, the EXIF metadata of photos (which may contain GPS location information, device data, etc.) is automatically removed by our processing. Only the visual data of the photo is retained.
5. Deletion of photos
When you delete a photo, it is immediately hidden from your gallery and from those of the other guests. To allow you to reverse an accidental deletion, the photo is technically retained for 7 days on our servers before its definitive and irreversible erasure. During this period, only the Tronche super-administrator can access the photo, exclusively for technical support reasons in the event of an explicit request on your part.
6. Hosting and transfers
The data is hosted on a Hostinger VPS server located in France (Paris, Île-de-France). The list of processors is given in §7.
All traffic to the website and the app goes through Cloudflare (cloudflare.com), which protects the server against attacks and speeds up loading. Cloudflare therefore sees your IP address and the data exchanged, including photos. Cloudflare, Inc. is a US company certified under the EU-US Data Privacy Framework, and a data processing agreement (DPA) compliant with the GDPR governs this processing.
The Resend email service (resend.com) is used to send photos and transactional emails (verification, notifications). Although Resend Inc. is a company governed by US law, the email processing infrastructure is located in Ireland (eu-west-1 region). A data processing agreement (DPA) compliant with the GDPR governs this processing.
7. Data sharing
We do not sell, rent or transfer your personal data to third parties. Data may be shared with:
- Hostinger (server hosting): all hosted data, including the server access log — server located in France (§6)
- Resend (email sending): recipient email address + email body containing a secure link to the photo (the photo itself is not transmitted to Resend) — processing in Ireland
- Cloudflare (website security and delivery): IP address and data exchanged with the server, including photos, in transit. Cloudflare, Inc., United States (Data Privacy Framework)
- Apple App Store (iOS purchases): transaction identifier and amount — Apple Distribution International Ltd, Ireland
- Google Play Store (Android purchases): transaction identifier and amount — Google Ireland Limited
- Competent authorities: in the event of a legal obligation only
8. Gallery visibility
Each event gallery is accessible via a sharing link containing a unique 20-character code. The organiser can configure the visibility of their gallery:
- Public gallery (default): anyone with the link can view and download the photos, without authentication.
- Private gallery: only the organiser (the authenticated account holder) can access the photos via the link. The link does not work for other visitors.
The organiser is responsible for the choice of visibility and for controlling the distribution of the sharing link.
9. Your rights
In accordance with the GDPR, you have the following rights:
- Right of access: obtain a copy of your personal data by contacting us at contact@tronche.net (export in JSON format within 30 days)
- Right of rectification: correct your data via the account settings in the application
- Right to erasure: delete your account from the settings (effective deletion within 30 days)
- Right to portability: receive your data in a structured and commonly used format (JSON)
- Right to object: object to certain processing based on legitimate interest by contacting us
- Right to restriction: request the restriction of a contested processing
- Right to withdraw consent: for processing based on consent (in particular the sending of emails to guests), at any time and without retroactive effect on processing already carried out
10. Exercising your rights
To exercise your rights, contact us at: contact@tronche.net
We will respond within a maximum of 30 days. You also have the right to lodge a complaint with the CNIL (the French data protection authority) (www.cnil.fr).
11. Security
We implement appropriate technical and organisational measures to protect your data:
- Passwords hashed with bcrypt (cost 10)
- Encrypted communications via HTTPS/TLS
- Time-limited JWT tokens (24 hours for access tokens, renewable via refresh token)
- Automatic removal of photo EXIF data
- Data access limited to what is strictly necessary
12. Cookies
The Tronche! web interface (in particular the administrator area) uses only technical cookies strictly necessary for its operation:
- admin_token: short session token (24 hours), HttpOnly, SameSite=Strict
- admin_refresh: session renewal token (90 days), HttpOnly, SameSite=Strict
No tracking, advertising or behavioural analytics cookies (Google Analytics, Plausible, Matomo, etc.) are placed. The native mobile application does not set any cookies.
13. Data breach notification
In the event of a personal data breach presenting a risk to the rights and freedoms of users, Tronche! undertakes to:
- Notify the CNIL within a maximum of 72 hours after becoming aware of it, in accordance with article 33 of the GDPR;
- Inform the affected users as soon as possible when the breach is likely to result in a high risk, in accordance with article 34 of the GDPR.
14. Changes
This policy may be updated. Users will be informed by email of significant changes. The date of the last update is indicated at the top of the page.