Legal information

Publisher

Registered name

Berenger.dev SRL, trading as Visionlab

Registered office

Rue Sainte Anne Termes 8, 6813 Chiny, Belgium

Company number (BCE/KBO)

0787.693.448

VAT number

BE 0787.693.448

Responsible publisher

Bérenger Stasse

Contact

hello@berenger.dev

Hosting

The site and the application are hosted by Hostinger, UAB, Švitrigailos str. 34, LT-03230 Vilnius, Lithuania.

Intellectual property

The copy, the visuals, the Pindao name and its logo belong to the publisher. Blog articles may be quoted with a link back to the original page; reproducing one in full needs written agreement.

What users put in — guest names, wishlists, messages to guests — stays theirs. We use it only to run the draw.

Berenger.dev SRL is the controller for the data described below, within the meaning of the General Data Protection Regulation (GDPR). Any question about this document goes to hello@berenger.dev.

What we collect

A draw brings two roles together, and we know different things about each.

Organiser

The email address they sign in with, their interface language, when they signed in, and the events they create.

Guest

The first name, last name and email address the organiser entered, the wishlist the guest writes themselves, and when they opened their card.

What we cannot see

Assignments are encrypted the moment they are drawn. One service in the application can decrypt them, and only to answer the guest concerned. They appear in no log, no error report, and not in the organiser’s dashboard, which shows progress alone.

A wishlist is readable only by the person giving to its author. The organiser sees how many items it holds, never what they are.

Why, and on what basis

Running the draw

Performance of the service requested (Article 6(1)(b)) for the organiser; legitimate interest (Article 6(1)(f)) for guests, who are taking part in an exchange they were invited to.

Sending the draw’s email

Same basis. These messages are the service: without them nobody receives their card. They are not marketing and carry no commercial offer.

Measuring the site’s audience

Legitimate interest, in a form that identifies nobody: no cookie, no persistent identifier. Sessions are recorded with every text masked, and a guest’s pages are never recorded at all.

Preventing abuse

Legitimate interest: a cap on sign-in attempts, and bot protection on the form.

Cookies

The marketing site sets no cookie at all. Audience measurement keeps its counters in memory for the length of the visit, and nothing is written to your machine — which is why you will never meet a consent banner here.

The application does set one strictly necessary session cookie: it is what keeps you signed in. It is exempt from consent and goes when you sign out.

Who receives the data

We sell nothing and pass nothing to third parties for advertising. Only the technical providers the service needs are involved:

Hostinger, UAB

Servers and database hosting — France

Cloudflare, Inc.

DNS and bot protection on the sign-in form — European Union

Resend, Inc.

Delivery of transactional email — United States

PostHog, Inc.

Cookieless audience measurement — European Union (Frankfurt)

Transfers outside the European Union

Our servers and our database are in the European Union. One provider is established in the United States, the one that delivers the email; that transfer rests on the European Commission’s standard contractual clauses.

For how long

An event’s data is deleted automatically three months after its date: the guests, their wishlists, the state of their cards and the encrypted assignments all go together, with nothing for you to do. A draw with no agreed date counts from the draw itself, and a draft that never ran from its creation.

Your account outlives them, for as long as you keep it. You can ask us to delete it at any time; we do so within thirty days, along with everything attached to it.

One exception, and it is deliberate: addresses that returned a permanent delivery failure, or whose owner reported us as unwanted, are kept separately so that they are never contacted again. That is the only way to keep the promise, and the list holds nothing but the address and the reason.

Your rights

You may ask for access to your data, its correction, its erasure, a restriction on its processing, its portability, and you may object to processing based on our legitimate interest. One address for all of it: hello@berenger.dev. We answer within a month.

If you are a guest and want out of a draw already under way, write to us directly — you do not have to go through the organiser.

You may also lodge a complaint with the Belgian Data Protection Authority, Rue de la Presse 35, 1000 Brussels — contact@apd-gba.be.

Minors

The service is meant for adults. A draw run in a classroom is created by an adult, and it is for them to obtain the families’ agreement before entering any address.

Purpose

These terms govern the use of Pindao, a service published by Berenger.dev SRL. Creating an account or taking part in a draw means accepting them.

The service

Pindao runs gift draws: one event, a list of guests, secret assignments and a scratch card for the reveal. Guests have no account to create.

The service is free. Were it to stop being free, draws already under way would run to their end on the terms they started under.

Your account

Signing in works through a single-use link sent to your email address: there is no password to remember, and none to entrust to us. That link is personal to you and opens your events.

What the organiser undertakes

By entering your guests’ details you state that you are entitled to give them to us and have told those people they will hear from us. That is what makes the draw lawful, and it rests with you: we have no way of checking it.

You undertake not to use the service to send unsolicited messages, and to enter only people who know they are joining an exchange.

What you write

Wishlists and messages to guests are written by you. Unlawful, hateful or harmful content is not allowed. We may remove content reported as such and close the account behind it.

Links in a wishlist are shown with their domain visible: they lead to third-party sites we do not answer for.

Availability

We run the service carefully, without guaranteeing it will be available without interruption. Maintenance, an incident at a host, or a failure can put it briefly out of reach.

We may change what the service does. A change affecting a draw already under way would be announced to you by email.

Liability

We cannot be held liable for a gift that does not arrive, an email filtered by a third-party mail service, or what a guest does with what they learn. Our liability cannot in any event exceed what you have paid us — which is nothing, for a free service.

Nothing here excludes our liability for fraud, gross negligence, or harm to life or physical integrity.

Ending

You may delete your account at any time by writing to hello@berenger.dev. We may close an account that breaches these terms, having warned you first except in an emergency.

Governing law

These terms are governed by Belgian law. Should a dispute arise we will look for an amicable answer first; failing that, the courts of the district of the publisher’s registered office have jurisdiction. If you are a consumer, this clause does not deprive you of the right to bring proceedings where you live.

Any change to these terms is published on this page, with its date. A substantial change is announced by email to organisers with a draw under way.