How Unseenly processes personal data

1. Data controller

A Data Protection Officer (DPO) will be appointed only if and when required by law.

2. Who this policy applies to

This policy concerns website visitors, registered users, recipients who open a self-destructing message and, where applicable, people whose data a user may enter in their private content.

3. Data processed, purposes and legal bases

Creating and managing a Space

We process the email address, cryptographic password hash, Space status, technical creation and verification dates, and temporary cryptographic tokens for email verification, password recovery and email changes.

Purpose: to create, authenticate and manage the Space and its credentials. Legal basis: Article 6(1)(b) GDPR.

Private content

Web Addresses, People, Notes and Events are stored as encrypted content in the database. Information is decrypted on the server only when required to provide requested features.

Purpose: to provide the requested personal space. Legal basis: Article 6(1)(b) GDPR. Unseenly does not use this content for advertising, profiling, commercial segmentation or matching users.

Self-destructing messages

For the sender, we process the encrypted message content, an optional private label, technical creation and expiry data and, after opening, a minimal technical receipt. The passphrase is not stored in recoverable form. The recipient does not need to create a Space.

Purpose: to create, deliver and destroy the message, prevent abusive attempts and display the technical receipt. Legal bases: Article 6(1)(b) for the service requested by the sender and Article 6(1)(f) for security and abuse prevention.

Minimised Beta telemetry

During the Beta we record only numerical and time-based indicators associated with the Space’s internal identifier: registration and verification dates, first useful activity, reaching numerical item thresholds, distinct days of use, use of Quick Save and self-destructing messages, and aggregate counts of those actions.

This telemetry does not contain text, URLs, names, aliases, keywords, notes, places, participants, message content, IP addresses, browser identifiers or a list of visited pages.

Purpose: to assess how the Beta works in practice, improve the service and understand which features could support a future business model without analysing personal content. Legal basis: the controller’s legitimate interest, Article 6(1)(f) GDPR. You may object to this processing by contacting the controller.

Voluntary reports

The “Help us improve Unseenly” feature stores the category, report text, administrative status and date/time. The report record does not store the sender’s user ID, email address or IP address.

Purpose: to fix problems and improve the product. Legal basis: the controller’s legitimate interest, Article 6(1)(f) GDPR.

Messages sent through Contact

If you use the Contact form, we process the email address you provide and the message text. This data is sent to the support mailbox and is not added to the content of your Space.

Purpose: to receive and handle the request and, where necessary, reply. Legal basis: Article 6(1)(b) GDPR when the request concerns the service; in other cases, the controller’s legitimate interest in managing communications, Article 6(1)(f) GDPR.

Cloudflare Turnstile anti-bot check

During sign-up and in the Contact form, we use Cloudflare Turnstile to distinguish human requests from automated ones and protect the service from abuse. Turnstile may process technical browser and connection signals, including IP address, User-Agent header, TLS fingerprint, Site Key and associated origin. Unseenly does not use Turnstile for advertising or commercial profiling.

Purpose: security and prevention of automated registrations or submissions. Legal basis: the controller’s legitimate interest, Article 6(1)(f) GDPR.

Technical browsing and security data

Web systems and the hosting provider may process data required for Internet operation and security, such as IP address, request date/time, requested resource, response outcome and technical connection parameters. The application also uses cryptographically transformed identifiers to limit repeated attempts at sensitive operations.

Purpose: operation, security, abuse prevention and error diagnosis. Legal basis: the controller’s legitimate interest, Article 6(1)(f) GDPR.

4. Data concerning other people

A user may choose to enter information about other people in their Unseenly. Unseenly does not create profiles of those people, attempt to identify them, connect them to other users or use that data for its own marketing or profiling purposes. This content remains part of the user’s private space and is processed only as needed to provide the service.

5. Encryption and security

Permanent personal content is encrypted in the database. The encryption key is separate from the database and the site’s public path. Passwords are stored using a modern hashing function and never in plain text.

Unseenly also uses HTTPS in production, HttpOnly/Secure session cookies, CSRF protection, parameterised queries, authorisation checks, rate limiting, security headers and deletion/restoration procedures.

Please note: the server holds the key required to decrypt content to provide the service. We therefore do not claim that the content is “zero knowledge”.

6. Cookies and technical tools

Unseenly does not use advertising cookies, profiling cookies or advertising pixels. It uses technical cookies required for sessions, authentication and security. Cloudflare Turnstile is also loaded during sign-up and in the Contact form solely as an anti-bot measure.

Prior consent is not required for tools strictly necessary for security and service provision. Details are available on the Cookies and similar technologies.

7. Recipients and providers

Data may be processed by strictly necessary technical providers, appointed or classified in the role required by law where applicable.

• Hosting: IONOS (European Union / EEA).
• Transactional email and support mailbox: IONOS (European Union / EEA).
• Anti-bot check: Cloudflare, Inc. through Turnstile.

We do not sell personal data or disclose it to advertisers. Payments are not active in the current Beta.

8. Transfers outside the European Economic Area

Hosting service: Processing within the European Union / EEA; IONOS declares no transfer to third countries for the Hosting service.

Cloudflare Turnstile: Cloudflare may also process data outside the EEA. Cloudflare states that, where applicable, it uses the European Commission’s Standard Contractual Clauses and other transfer mechanisms provided by law.

If other providers involving transfers to third countries are introduced in the future, this policy will be updated to identify the transfer and applicable safeguards.

9. Retention periods

• Space and email: until the Space is deleted, unless otherwise required by law.
• Permanent content: until deleted by the user or the entire Space is deleted. After the short restoration period provided by the interface, deletion becomes permanent in the operational database.
• Email verification/recovery/change tokens: expire according to the requested function and are removed periodically.
• Rate-limiting data: short technical retention; obsolete rows are periodically deleted.
• Beta telemetry linked to the Space: until the Space is deleted or telemetry is discontinued earlier.
• Unread self-destructing message: up to 7 days under the current Beta configuration.
• Read message: the server copy is destroyed when the message is successfully opened; the copy already loaded in the browser remains visible for 20 seconds.
• Technical message receipt: up to 30 days.
• Technical server logs: 56 days.
• Technical backups: 14 days.
• Messages sent through Contact: stored in the support mailbox for as long as required to handle the request and, where necessary, protect rights or fulfil obligations connected with the communication.

Technical deletion ledgers retain non-reversible identifiers only for as long as needed to prevent an old backup from restoring previously deleted data.

10. Automated decisions and profiling

Unseenly does not make automated decisions that produce legal or similarly significant effects on users and does not commercially profile content or users.

11. Rights of the data subject

Where provided by the GDPR, you may request access, rectification, erasure, restriction of processing and data portability; you may also object to processing based on legitimate interest.

You can already delete individual items or your entire Unseenly yourself. For other requests, contact: privacy@unseenly.me.

You also have the right to lodge a complaint with the Italian Data Protection Authority, under Article 77 GDPR.

12. Changes to this policy

This policy may be updated when the service, providers, features or applicable law change. Material changes will be made clearly available on the website.