Skip to content
CarnelyCarnely

Privacy policy

Who is the data controller?

ELVN, SAS with €100 share capital, 60 rue François Ier, 75008 Paris, France - SIREN 979 732 906.

For any question regarding your data: [email protected].

What this policy covers

This policy explains how the Carnely service - the carnely.com website and the app (web, iOS and Android) - handles your personal data.

Carnely is a private, ad-free place to keep what matters and share it with the people close to you. We do not sell your data, we show no advertising, and we use no recommendation algorithm.

Eligibility

Carnely is intended for adults or for people aged 16 or over. If you are under 16, signing up requires the prior consent of a parent or legal guardian.

Your account and identity

  • Your email address and, if you sign in with Google or Apple, the identifier and email those services share with us
  • Your first name (required) and last name (optional)
  • Your password, kept only in encrypted (hashed) form, never in clear text
  • Your language and time zone, to show Carnely in your language and respect your quiet notification hours

The memories you create

Your memories are yours. A memory kept to yourself is visible only to you; a memory you confide is visible only to the people you confide it to.

  • The titles, texts and dates you write
  • The photos, audio recordings (your voice) and videos you add
  • The place of a memory, if you choose to locate one on the map (geographic coordinates)
  • How you organise your memories into chapters and albums

Your circle and the people close to you

  • The email addresses of the people you invite
  • The mutual links that connect you to your circle once an invitation is accepted
  • The label you give to a person (for example "my mother"), visible only to you
  • The groups you create to choose whom to confide a memory to - these groups stay private, and the people concerned never know they have been grouped

Reactions

Someone close to you can place a reaction on a memory you confide to them, chosen from a fixed palette. A reaction is always named ("Marie was moved by your memory"), never counted or aggregated. There is no free-text comment.

Your subscription

If you subscribe to Carnely+, the purchase is handled by Apple's App Store or by Google Play, through our provider RevenueCat. We neither receive nor store your payment card details.

We keep only the status of your subscription (plan, renewal date, auto-renewal) in order to unlock the corresponding features.

Album orders (printing)

If you order a printed album, we process your delivery address and payment through our printing and payment providers. This data is used only to produce and deliver your order.

Notifications

To send you notifications (an accepted invitation, a reaction received, a recap), we store a notification token specific to your device. You can adjust or turn off these notifications at any time, in the app or in your phone settings.

The emails we send you

We send you emails related to your account and the service: address confirmation, invitations, your circle recap, security, subscription and orders. They are part of how Carnely works.

After you sign up, we also send a few getting-started emails to help you begin (write a first memory, invite a loved one). You are enrolled by default and can turn them off at any time: from your settings, under Notifications, or with one click via the unsubscribe link in each of these emails. Security emails are always sent.

Technical and security data

  • Session information (IP address, device and browser type) to keep you signed in and detect abnormal access
  • The source of your visit (UTM parameters), to understand how you found us
  • Security logs, to prevent fraud and protect accounts
  • Anonymised crash reports (via Sentry), to fix bugs. We use no advertising tracker.

What is the legal basis?

  • Performance of our terms of use: creating your account, saving your memories, sharing them with your circle
  • Legitimate interest: security, fraud prevention, bug fixing, anonymous audience analytics, getting-started emails to help you begin (which you can object to at any time)
  • Consent: notifications, access to the microphone, camera or location, advertising measurement cookies (permissions you grant and can withdraw)
  • Legal obligation: billing and accounting requirements related to subscriptions and orders

Who do we share your data with?

We rely on processors that handle data on our behalf, bound by a GDPR-compliant contract. We do not sell any data.

  • Neon (database) - Germany (Frankfurt)
  • Cloudflare R2 (storage of your photos, audio and videos) - global network
  • Vercel (hosting of the website and web app) - United States, under contractual safeguards
  • Resend (email delivery) - Germany
  • RevenueCat, Apple and Google (subscription management) - United States, under contractual safeguards
  • Stripe (payment for album orders) - United States, under contractual safeguards
  • Mistral (transcription of your voice memos, at your request) - European Union; the audio is not retained by this provider
  • Mapbox (map display, only if you locate a memory) - United States
  • Modal (technical video conversion) - United States
  • Lulu (album printing and shipping, only if you order) - United States
  • Sentry (crash reports) - United States

Transfers outside the European Union

Your data is hosted in the European Union (database in Germany). Some providers are located outside the EU; in that case, transfers are governed by the European Commission's standard contractual clauses.

How long do we keep your data?

  • As long as your account is active, your memories and account data are kept
  • When you delete your account, a 30-day period lets you change your mind; after that, your memories, media and personal data are deleted
  • Our security backups, which are kept encrypted, may still contain your data for up to 90 days after that deletion; they are used only to restore the service after an incident and are purged automatically
  • Export files of your data are deleted 24 hours after they are prepared
  • Security logs are pseudonymised when your account is deleted and kept only for as long as strictly necessary for security and our legal obligations

What are your rights?

  • Access, rectification, erasure, portability, objection and restriction
  • You can export all of your data directly from the app
  • You can delete your account from the app
  • To exercise these rights or for any question: [email protected]
  • You may also lodge a complaint with the CNIL (cnil.fr)

Deleting your account

You can delete your account at any time from the app. If you have an active subscription, please cancel it first with the App Store or Google Play, which alone can manage it.

Cookies and trackers

  • Umami: anonymous audience analytics, cookieless, GDPR-compliant without consent. Data hosted in the European Union.
  • Language preference (`carnely_locale`): a functional cookie that remembers the language you choose via the language switcher (French, English, German or Italian) so we can bring you back to it on your next visit. Duration: 1 year. No personal data, no consent required (strictly necessary cookie for the requested service, article 82 LCEN).
  • Google Ads (gtag.js): one advertising measurement cookie (`_gcl_au`, `_gac_*`) set only after your explicit consent via the cookie banner. Used to measure the performance of our Google Ads campaigns. Without consent, no cookie is set and Google only receives anonymous signals (Consent Mode v2).
  • You can withdraw your consent at any time by removing the `carnely_consent_v1` entry from your browser's local storage, or by writing to [email protected].

Withdrawing consent

You can withdraw your consent at any time, without justification. Every email we send you includes an unsubscribe link, and you can withdraw your consent to advertising measurement cookies by removing the `carnely_consent_v1` entry from your browser's local storage. You can also write to [email protected] to request deletion of your data.

Withdrawing your consent does not affect the lawfulness of processing carried out before that withdrawal.

Data security

  • Encrypted connections (TLS 1.2+) between your device and our servers
  • Database encrypted at rest on Neon (Frankfurt region)
  • Access strictly limited to authorised ELVN staff
  • Regular backups, access logging, passwords stored as hashes

No advertising, no automated decision-making

Carnely shows no advertising, does not track you for advertising purposes and does not resell your data. We take no decision producing legal effects concerning you based on automated processing, within the meaning of Article 22 of the GDPR, and we carry out no profiling.

Updates to this policy

We may update this policy. In the event of a significant change, we will inform you on the website or by email.