The short version
We ask for the minimum needed to send invitations, reminders and draw notices, and for organizers to sign back in. We use Google AdSense to help fund the service, which is free; Google may use cookies, similar identifiers and ad-related signals to serve, measure and protect ads, including personalized ads where your consent or settings allow. We don't sell Cuchumbo exchange data, and we don't send names, emails, hints, draw results, budgets or gift days to Google for ads. Draw results are encrypted at rest; the service decrypts one only to show a verified participant who they got. Every Cuchumbo is automatically deleted about six months after its gift day. We record the address each person connects from and the day they did, so a report of abuse can be looked into; it's deleted when the Cuchumbo is.
What we collect
Organizers give a verified email address; that email lets them sign in with one-time links and receive organizer notices. Participants give one email so the service can send invitations, reminders when they're on, the draw notice, personal-page links and a thank-you note once their gift is delivered. They also provide the name they want to appear under and any hints they choose to share. Gift day, budget and the Cuchumbo's name are the other fields the organizer enters. We don't collect postal addresses. For ads, Google AdSense may process technical or ad data such as IP address, browser or device information, page URL, ad interactions, cookies or similar identifiers. Cuchumbo doesn't add names, emails, hints, draw results, budget, gift day or Cuchumbo contents to ad requests. When someone opens a Cuchumbo they organize or were invited to, we also record the address they connect from and the calendar day: one entry per person, address and day. It exists so a report about the names or hints someone typed can be looked into, and it's deleted with the Cuchumbo.
Messages you send through “Write to us”: what you write, the page you wrote from, your browser line and, if you leave it, the address to reply to, which is stored encrypted. They are kept for about six months.
How contact data is protected
Contact details (the organizer's email, each participant's email) are stored in two forms: a one-way hash to recognize returning invitations, and an encrypted copy so the service can send messages. Draw results are encrypted at rest with a per-Cuchumbo key wrapped by the site key; they're not shown to organizers or listed in any dashboard.
How long we keep it
Each Cuchumbo, with its participants, hints and draw results, is scheduled to be deleted automatically about six months after its gift day; copies may remain in backups until they are deleted in their ordinary rotation. Organizer sign-in sessions last thirty days and then expire on their own. If you ask us to delete an account or a Cuchumbo sooner, we will; see your rights below.
Messages between a giver and their person
After the draw, a participant and whoever drew them can exchange short messages without the giver being named. The messages are encrypted at rest with the exchange's own key and filed under a code that names neither person, so the stored data does not reveal who gives to whom. Only the two of them see the conversation; the organizer never does. Each message is emailed to the other person and, like other texts, may be checked for compliance with our rules. The messages are deleted with the Cuchumbo.
Checks for compliance with our rules
To keep Cuchumbo safe for everyone, pictures and texts submitted to an exchange may be checked for compliance with our rules, partly with the help of service providers that process only the content itself, never your email address or account. Content that breaks the rules may be withheld or removed, and repeated violations can lead to an address being refused. Records of these decisions are kept for up to one year; a refusal lasts until our team lifts it.
Counting which gifts people ask for
To choose which gift suggestions and shopping links to show, we count the words that appear in participants' hints across many exchanges: for example, how many different exchanges mention headphones. Only words written in several different exchanges by several different people are counted this way, and nothing is linked to a name, an email address or an exchange. We may ask a service provider to group and categorise these counted words; it receives only the words and their counts, never the hints themselves.
Who sees it
We don't sell exchange data. Infrastructure providers such as hosting and email delivery process only the data needed to operate the service. Google AdSense is our advertising provider and may process ad-related data under Google's advertising terms and your consent or settings. Draw results, names, emails, hints and Cuchumbo contents are not shared with Google for ad targeting. To answer a report of abuse, whoever operates Cuchumbo can open one Cuchumbo and read what was typed into it: its name, participant names, hints, emails and the recorded addresses. Draw results are not part of that review, and they stay encrypted at rest.
Your rights
You can ask to see, correct, export or delete the data we hold about you, or object to how we use it: write to the contact below. You can also complain to the data protection authority where you live.
Cookies
We use strictly necessary cookies for organizer sessions, CSRF protection, language preference and the consent choice itself. We also use Google AdSense, which may set or read advertising cookies, local storage or similar identifiers to serve ads, prevent fraud and abuse, measure ad performance and, when allowed, personalize ads. On your first visit we show a consent choice; where consent is required, advertising storage and personalized ads are used only according to that choice. You can change browser settings or Google ad settings, or leave before using the service.
Learn more: How Google uses data · Google Ad Settings
Contact
Write to privacy@cuchumbo.com for any privacy question, access request, or deletion request.
