Who is responsible
DEVELU OÜ is the controller for the processing described here. It is registered in the Estonian e-Business Register under code 16305055. Its registered address is Pihlaka tn 15, Kõrveküla alevik, Tartu vald, Tartu maakond 60532, Estonia. Contact us at develu.oy@gmail.com.
This policy covers the public marketing site at giftfoxly.com, the authenticated app at app.giftfoxly.com, and optional reminder email. GiftFoxly is intended only for people aged 18 or older.
Data we process and where it comes from
Account and profile
Clerk handles sign-up, sign-in, sessions, account recovery, and authentication factors. From Clerk's verified account claims, GiftFoxly receives and stores a stable account identifier and may receive your email address, name, and profile image URL. GiftFoxly also stores your chosen timezone and whether reminder email is enabled. GiftFoxly does not receive or store your password.
Private planning data
You may enter information about people you know: name, relationship, email address, phone number, interests, and notes. For occasions, GiftFoxly stores the person, title, calendar date, yearly or one-time recurrence, and notes. For gifts, it stores the person, optional occasion, title, planning status, optional web link, and notes. Records also carry internal ownership links and creation or update times.
This information comes from you. Some of it may describe another person who does not use GiftFoxly. Keep entries proportionate, do not use GiftFoxly as an address book for people unrelated to gift planning, and do not enter sensitive information such as health, political, religious, biometric, or financial details.
Reminders and delivery history
A reminder rule stores its occasion, person, lead time, and internal scheduling details. If you opt in to email, GiftFoxly uses your account email, timezone, the person's name, the occasion title and date, and a link to the reminders page to prepare the message. Gift notes, gift links, phone numbers, and the person's email address are not placed in reminder messages.
The private delivery ledger stores the occurrence date, lead time, pending/sent/failed state, attempt count, broad failure category, timestamps, and internal Gmail message identifiers used for delivery integrity and deduplication. The app shows you only a limited delivery-history view.
Technical and correspondence data
Clerk, Convex, Cloudflare, Google, and—only for the configured SimpleLogin route—Proton/SimpleLogin may process technical records needed to authenticate users, serve requests, detect abuse, troubleshoot failures, and deliver email. These records can include IP address, request time, browser or device information, session identifiers, and service logs. If you contact us, we process your address, message, attachments, and our response.
Account identity is required to use the authenticated app. Planning fields other than the required record titles and links are optional. A saved timezone is needed for scheduling, and reminder email remains off unless you positively enable it.
Why we process data and our legal bases
- Provide the service and your account: authentication, private storage, owner-scoped views, editing, dashboards, timezone handling, and requested support are necessary to perform our contract with you.
- Send optional reminder email: we rely on your consent. The setting starts off and you can withdraw consent at any time on the reminders page. Turning email off cancels pending schedules and does not affect the rest of the app or processing already completed.
- Process information about people in your plans: we rely on our legitimate interest in providing the private planning tool you requested. We limit use to your account and service operations, do not contact those people, and do not use their data for advertising or marketing.
- Protect and operate GiftFoxly: access control, abuse prevention, debugging, delivery deduplication, incident response, and protection of legal claims rely on our legitimate interests in a secure and reliable service.
- Meet legal duties: we may process limited information where necessary to comply with applicable law or a binding request.
GiftFoxly does not use personal data for advertising, behavioral analytics, data brokerage, marketing email, or automated decisions that have legal or similarly significant effects. We do not sell personal data.
Service providers, recipients, and international transfers
- Clerk provides authentication and account management.
- Convex hosts and processes the application database, functions, and schedules. GiftFoxly's primary application database, backend functions, and schedules use Convex infrastructure selected in US East (N. Virginia), United States. Convex's Data Processing Agreement and public subprocessor list describe its processing and the entities it engages.
- Cloudflare serves both web frontends and provides network security.
- Google processes the sender account, recipient routing, message content, and delivery metadata through Gmail and the Gmail API.
- Proton/SimpleLogin additionally creates a routing contact and relays the message when the approved SimpleLogin route is configured. GiftFoxly does not silently switch between delivery routes.
We may also disclose the minimum necessary data to professional advisers, courts, regulators, or public authorities where there is a valid legal basis, or to protect users, the service, or legal rights.
Some providers and their subprocessors operate outside Estonia or the European Economic Area, including in the United States. For applicable European Economic Area-to-US processing on Convex, GiftFoxly relies on the European Commission's Standard Contractual Clauses (Module Two: controller-to-processor) provided under Convex's Data Processing Agreement, together with the documented transfer assessment and supplementary measures we rely on for that processing. Other providers may rely on different lawful mechanisms: depending on the provider and destination, transfers may be protected by an adequacy decision (including the EU–U.S. Data Privacy Framework where applicable to that provider), the European Commission's Standard Contractual Clauses, or another lawful safeguard. You may ask us for information about the safeguard relevant to your data.
How long we keep data and how deletion works
- Clerk account data and GiftFoxly application data remain while your account is open. Planning records you delete in the app are removed from the live application database. Deleting a person also removes that person's occasions, gifts, and reminder rules; deleting an occasion removes its reminder rule and unlinks associated gifts. A prior delivery-ledger entry remains until whole-account deletion so it can continue to support history and duplicate-send prevention.
- Reminder rules and the delivery ledger remain while your account is open because they support scheduling, history, and duplicate-send prevention. Opting out cancels pending email schedules but preserves delivery history.
- Copies of sent reminder messages in the GiftFoxly Gmail sender mailbox are removed on a rolling basis after 90 days. A delivered copy in your own mailbox is controlled by you and your email provider.
- Routine support correspondence is kept for up to 12 months after resolution. We may keep a minimal record of a privacy request and our response for up to three years where needed for accountability or legal claims.
- Security and operational logs follow the applicable provider configuration and retention schedule. Deleted data may remain temporarily in restricted backups until those backups rotate, and may be retained longer only where law or the establishment, exercise, or defense of legal claims requires it.
There is no in-app whole-account deletion button in this beta. To delete your account and GiftFoxly data, email develu.oy@gmail.com, preferably from the address on your Clerk account. We will verify the request, disable reminder delivery, and normally complete deletion from the live GiftFoxly database and Clerk within 30 days. We will explain if a legal exception or extra verification changes that timing.
Your privacy rights
Depending on the circumstances, you may ask for access to and a copy of your personal data, correction, deletion, restriction, portability of data you provided, or object to processing based on legitimate interests. You may withdraw reminder-email consent at any time without affecting earlier lawful processing.
These rights can also apply if a GiftFoxly user entered information about you in their private plans. Tell us enough to locate the relevant account without sending extra sensitive information. We will balance your request with the rights of the account holder and other people.
Send a request to develu.oy@gmail.com. We may ask for information needed to verify that the request concerns you or your account. We normally respond within one month, subject to lawful extensions or exceptions, and the first copy is ordinarily free.
You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), or to the supervisory authority where you live or work, if you believe your data-protection rights have been infringed.
Security, changes, and contact
GiftFoxly uses authenticated access, server-derived ownership, owner-scoped queries, limited browser projections, input validation, explicit email opt-in, and delivery deduplication. Access is limited to people and providers who need it to operate or protect the service. No online service can promise absolute security, and you remain responsible for your devices and authentication methods.
We may update this policy when the service, providers, or law changes. The date at the top shows the latest revision. We will provide appropriate notice of material changes and request fresh consent where the law requires it.
Questions and requests can be sent to DEVELU OÜ at develu.oy@gmail.com or by post to Pihlaka tn 15, Kõrveküla alevik, Tartu vald, Tartu maakond 60532, Estonia.