Privacy Policy

Last updated: February 27, 2026

1. Introduction

Welcome to Secret Gifts ("we", "our", or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services.

We are based in the United Kingdom and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

Information you provide to us:

  • Account Information: Name, email address, and password when you register
  • Profile Information: Gift preferences, interests, sizes, and wishlists you choose to share
  • Group Information: Group names, member emails, spending limits, and exchange dates
  • Communications: Anonymous messages sent through our platform

Information collected automatically:

  • Log Data: IP address, browser type, operating system, referring URLs, and access times
  • Device Information: Device type and unique device identifiers
  • Cookies: See our Cookie Policy for details

3. How We Use Your Information

We use your information to:

  • Provide, operate, and maintain our services
  • Create and manage your account
  • Process Secret Santa matching and assignments
  • Facilitate anonymous messaging between matched participants
  • Send email notifications about your groups, matches, and messages
  • Send reminder emails about upcoming exchange dates
  • Respond to your enquiries and provide customer support
  • Detect and prevent fraud or abuse
  • Comply with legal obligations

4. Legal Basis for Processing (UK GDPR)

We process your personal data on the following legal bases:

  • Contract: Processing necessary to provide our services to you
  • Legitimate Interests: To improve our services, prevent fraud, and ensure security
  • Consent: Where you have given explicit consent for specific processing
  • Legal Obligation: Where we are required to process data by law

5. Information Sharing

We share your information only in the following circumstances:

  • With Group Members: Your name and gift preferences are shared with your Secret Santa match within your group
  • Service Providers: We use third-party services for email delivery, hosting, and analytics
  • Legal Requirements: When required by law or to protect our rights

We do not sell your personal information to third parties.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. You may request deletion of your account and associated data at any time. After deletion, we may retain certain information as required by law or for legitimate business purposes.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

  • Encryption of data in transit (HTTPS/TLS)
  • Secure password hashing
  • Regular security assessments
  • Access controls and authentication

8. Your Rights

Under UK GDPR, you have the right to:

  • Access: Request a copy of your personal data
  • Rectification: Request correction of inaccurate data
  • Erasure: Request deletion of your data ("right to be forgotten")
  • Restriction: Request restriction of processing
  • Portability: Request transfer of your data in a machine-readable format
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us using the details below.

9. International Transfers

Your data may be transferred to and processed in countries outside the UK. Where this occurs, we ensure appropriate safeguards are in place in compliance with UK GDPR.

10. Children's Privacy

Our services are not intended for children under 16. We do not knowingly collect personal information from children under 16. If you believe we have collected such information, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at:

  • Email: privacy@secretgifts.app

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.