Privacy Policy

Last updated: 1 July 2026

1. Who We Are

21Pix is operated by:

We are the data controller for the personal data described below, under Regulation (EU) 2016/679 (GDPR).

2. What We Collect and Why

2.1 Your photos

• What: The 21 photos in each roll you order.
• Why: To print them on photo paper and ship them to you.
• Legal basis: Performance of a contract (GDPR Art. 6(1)(b)).
• Retained: Until 48 hours after your order has shipped, then permanently deleted from our systems.

2.2 Shipping & contact details

• What: Name, postal address, email address, optional phone number.
• Why: To deliver your prints and email you order/shipping confirmations.
• Legal basis: Performance of a contract.
• Retained: 7 years, as required by Dutch tax law (art. 52 AWR).

2.3 Payment data

• What: Order amount, transaction ID and payment status returned by Mollie. We never see or store your card number, IBAN, or PayPal credentials.
• Why: To take payment and reconcile orders.
• Legal basis: Performance of a contract; legitimate interest in fraud prevention (Art. 6(1)(f)).
• Retained: 7 years (tax law).

2.4 Device data

• Device-generated user ID: A random identifier created on your device the first time you launch the app. It lets us associate your rolls and orders without requiring an account. Not linked to your real identity.
• Push notification token: If you allow notifications, we store an Apple (APNs) or Google (FCM) push token so we can tell you when your film is "developed" and when your order ships. You can revoke this anytime in your device settings.
• Server logs: Like any web service, our server records request lines including IP address, briefly, for security and abuse prevention. Logs are rotated after 30 days. We don't use them to build a profile of you.

2.5 Anonymous usage analytics & ad measurement

• Usage analytics: Aggregate, anonymous usage events — for example app opens, that a photo was taken (and its number within the roll), that a roll was completed, steps of the checkout (order started, payment started, completed or failed), and that an order was placed and its total value, plus standard website page views and which app-store button was tapped. We use Google Analytics 4 for this, via Firebase Analytics inside the apps. This carries no advertising identifier.
• Website heatmaps & session replays: On our website only (never in the apps), we use Microsoft Clarity to see how pages are used — anonymized heatmaps and session replays of clicks, scrolls and mouse movement, with all text and form inputs automatically masked. It loads only after you accept the cookie banner and never sees your photos.
• Ad performance measurement: So we can run ads that bring new people to 21Pix, we measure how our own campaigns on Meta (Facebook / Instagram) and Google perform — for example whether an ad led to an app install or an order. On iOS this uses Apple's SKAdNetwork, plus your device advertising identifier (IDFA) only if you allow it in Apple's App Tracking Transparency prompt. On Android, in the EEA we ask for your consent with an in-app prompt before using your advertising identifier (GAID); you can grant or withdraw it any time under About → Privacy. On the website, a Meta Pixel and Google tag load only after you accept the cookie banner. Your photos are never part of this.
• What it is not: We do not build a profile of you from your photos, and your photos are never used for advertising. Order events carry only the order total and country — never your name, address, email or card details. We never sell your personal data.
• Why: To understand, in aggregate, how 21Pix is used so we can improve it, and to measure and improve the ads that bring people to the app.
• Legal basis: For usage analytics — on the website, your consent (GDPR Art. 6(1)(a)); in the apps, our legitimate interest in improving the product (Art. 6(1)(f)), on by default and switchable off under About → Privacy. For ad measurement that uses an advertising identifier — your consent (Art. 6(1)(a)), given through Apple's App Tracking Transparency prompt on iOS, an in-app consent prompt on Android in the EEA, or the website cookie banner; decline and we fall back to privacy-preserving aggregate measurement only.
• Retained: 14 months, after which event-level analytics data is automatically deleted by Google. Ad-measurement data is retained per Meta's and Google's advertising data policies.

3. What We Don't Do

4. Who Else Touches Your Data

We print and pack your photos ourselves, in our own facility, so your images are not handed off to any external printing partner. The only third parties involved are:

Service	Role	What they see	Location
Mollie B.V.	Payment processor	Order amount and your payment details (which we never receive)	Netherlands (EU)
Amazon Web Services	Server hosting & storage	Encrypted application data, in EU regions	EU
Apple (APNs)	iOS push notifications	Push token and notification payload (order status)	EU / US
Google (Firebase Cloud Messaging)	Android push notifications	Push token and notification payload (order status)	EU / US
Google (Analytics 4 / Firebase Analytics)	Anonymous usage analytics	Aggregate app & website usage events — no advertising ID, no photos	EU / US
Microsoft Clarity	Website usage analytics (heatmaps & session replays)	Anonymized on-site interactions — clicks, scrolls and mouse movement on our web pages, with text and form inputs masked; no photos, no cross-site tracking	EU / US
Google Ads	Ad conversion measurement	That an order completed and its value, plus a one-way hashed (SHA-256) form of your email to match the ad click — never your raw email or card details	EU / US
Meta Platforms Ireland	App-install & ad measurement (Facebook / Instagram ads)	Aggregate app & ad events (installs, key steps, purchases and value) and, only with your consent, your device advertising identifier — never your photos, raw email or card details	EU / US
PostNL and partner carriers	Shipping	Name and shipping address	EU

Apple and Google process push tokens under their own terms; transfers outside the EU rely on the European Commission's Standard Contractual Clauses. No other personal data is transferred outside the EU.

5. Data Retention Summary

Data	Kept until	Why
Photos	48 hours after shipment	Reprints in case of carrier loss/damage
Order, shipping & payment records	7 years	Dutch tax law (art. 52 AWR)
Push token	Until you disable notifications or uninstall	Sending order updates
Anonymous usage analytics	14 months	Product improvement (auto-deleted by Google)
Website heatmaps & session replays (Microsoft Clarity)	Rolling window set by Microsoft	Understanding website usability
Ad-measurement data (Meta, Google)	Per Meta / Google advertising data policies	Measuring & improving our ads
Server access logs	30 days	Security & abuse prevention

6. Your Rights Under GDPR

You have the right to: access your data, correct it, delete it (subject to our legal retention obligations), restrict or object to processing, and receive it in a portable format. To exercise any of these rights, email info@21pixapp.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the supervisory authority in your country of residence.

7. Children

21Pix is not intended for users under 16. We do not knowingly collect data from children under 16. If you believe we hold data about a child under 16, contact us and we'll delete it.

8. Security & Breach Notification

Data in transit is protected with TLS. Data at rest in AWS is encrypted. Access is limited to personnel who need it to operate the service. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the supervisory authority within 72 hours and, where required, notify affected users directly by email.

9. Changes & Contact

If we make material changes to this policy we will update the date at the top and, where appropriate, notify recent customers by email. Continued use of 21Pix after a change constitutes acceptance.