Crumbtrail Privacy Policy
TEMPLATE, NOT LEGAL ADVICE. This is a starter draft. Fill in every
[PLACEHOLDER], make sure it matches what the website and upload page actually do, and have a licensed attorney review it before launch.
Effective date: [EFFECTIVE DATE] Version: [VERSION NUMBER, e.g. 2026-10-v1]
This Privacy Policy explains how [COMPANY LEGAL NAME], doing business as Crumbtrail ("Crumbtrail," "we," "us"), collects, uses, and protects personal information. It covers:
- Our website at https://crumbtrailhq.com (planned: crumbtrailhq.com) and our sign-up and checkout pages (the "Site"), and
- Customer upload pages at [UPLOAD DOMAIN, e.g. upload.crumbtrailhq.com]/s/[shop], which Diners reach by scanning a QR code at a restaurant, café, or other food business that uses Crumbtrail (a "Shop").
The short version:
- We collect only what we need to run our services.
- We don't sell your personal information, and we don't use it for targeted advertising.
- We strip location (GPS) and other hidden metadata from uploaded photos and videos.
- We store IP addresses only as scrambled ("hashed") values on the upload page.
- We delete uploads that aren't used after 6 months.
- You can ask us to delete your information or take down your photo at any time: [email protected].
1. Who's responsible for your information
- On the Site (for business owners and visitors), Crumbtrail decides how your information is used.
- On a Shop's upload page, we collect information for that Shop. We run the upload page and act on the Shop's instructions, as its service provider. The Shop sees your upload and anything you typed, and it decides whether to post your content. Each Shop is also responsible for how it uses your information, and it may have its own privacy policy. We name the Shop clearly on every upload page.
2. What we collect
2.1 From business owners (Site visitors, prospects, and clients)
| What | Examples | Where it comes from |
|---|---|---|
| Contact and business info | Name, business name, email, phone, address, role | You (forms, email, sign-up) |
| Account and service info | Services purchased, approvals, content you send us, account access we're given, messages with us | You, and our work with you |
| Payment info | Billing name, billing address, last 4 digits of card, payment status | Stripe (we never see or store your full card number) |
| Public business info | Menu, hours, public photos, public reviews | Public sources such as your website, Google, and social profiles, used for your free preview |
| Technical info | IP address, browser and device type, pages visited, timestamps | Automatically, through our hosting provider and essential cookies (Section 6) |
2.2 From Diners (customer upload pages)
| What | Required? | Why |
|---|---|---|
| Photos and videos you upload | Yes, at least one | So the Shop can review and repost them, with your permission |
| Consent record: that you checked the consent box, the exact consent wording and its version, the date and time, and the Shop | Yes | To prove permission was given before anything is posted |
| Caption, "what did you order?" | Optional | To help write the post |
| Social media handle (e.g. @yourname) | Optional | To credit you when your content is posted |
| First name and email | Optional (giveaway only) | To enter you in the Shop's giveaway and contact you if you win |
| Giveaway opt-in | Optional | To record that you chose to enter |
| Where you scanned (e.g. "table," "counter," "receipt") | Automatic | To help the Shop see which QR sign works |
| Hashed IP address | Automatic | To prevent spam and abuse (Section 4) |
We don't ask Diners to create an account, and we don't collect phone numbers, birth dates, or payment information on upload pages.
Please don't include sensitive information (health details, government IDs, other people's personal information) in captions or uploads.
3. Photo and video metadata (EXIF/GPS stripping)
Photos and videos taken on phones often carry hidden "metadata," such as the exact GPS location where they were taken, the date, and the phone model. When you upload, we automatically remove that metadata:
- Photos are re-saved without any EXIF metadata. This removes GPS location and device details. iPhone HEIC photos are converted to JPEG.
- Videos are re-packaged with their metadata removed, including location data.
If removal fails for a file, the file is flagged, and we won't post it until it's handled. [CONFIRM THIS MATCHES PRODUCTION BEHAVIOR.] Remember that the picture itself can still show where you are, such as a street sign or a storefront, and the people in it.
4. IP address hashing
To stop spam and abuse on upload pages, we briefly use your IP address to limit how many uploads can come from one connection. We don't store your raw IP address with your upload. We store only a salted, one-way hash of it: a scrambled code made with a secret key. We can use it to spot repeat abuse, but it isn't meant to be turned back into your IP address. Hashed IPs are deleted along with the upload record (Section 8), or after [IP HASH RETENTION, e.g. 90 days] if the upload is rejected. Our hosting and security providers may separately process raw IP addresses in short-term server logs to deliver and protect the site (Section 7).
5. How we use information
We use personal information to:
- provide, run, and improve our services, including building websites, preparing posts, replying to reviews, and running upload pages;
- let Shops review, approve, and post Diner content with credit where a handle was given;
- run giveaways for Shops: picking and contacting winners, and checking eligibility;
- process payments, send receipts, and manage subscriptions (through Stripe);
- respond to questions and requests, and send service messages;
- send business owners occasional marketing emails about Crumbtrail, which you can opt out of anytime (we don't send marketing to Diner emails);
- prevent fraud, spam, and abuse, and keep the services secure; and
- follow the law and enforce our terms.
We may use automated tools to help draft captions or replies, but people review content before a Shop approves it. We don't make decisions about you that have legal or similarly significant effects based solely on automated processing.
6. Cookies and similar technologies
- Essential cookies only, by default. We use cookies that are needed for the site to work, such as keeping a Shop owner signed in to their dashboard and protecting forms against forged requests (a CSRF token). The Diner upload page doesn't need an account, and it uses only cookies that are needed for security and to submit the form. [CONFIRM IN PRODUCTION.]
- Stripe sets its own cookies on checkout pages to process payments and prevent fraud. See Stripe's privacy policy.
- Fonts. Our pages load fonts from Google Fonts, which receives standard technical information such as your IP address and browser type. [OR: "We host our fonts ourselves." Update if you self-host.]
- Analytics. [CHOOSE ONE: "We don't use analytics or advertising cookies." OR "We use [ANALYTICS PROVIDER], a privacy-friendly analytics tool, to count visits. It [does / does not] use cookies."]
- No advertising cookies or cross-site tracking. We don't use advertising pixels or sell or share data for targeted advertising. Because we don't sell or share personal information, there's nothing to opt out of, but we also treat browser Global Privacy Control signals as an opt-out request.
You can block or delete cookies in your browser settings. If you block essential cookies, some features (like the owner dashboard) may not work.
7. Who we share information with
We do not sell personal information, and we don't rent it or trade it. We share it only:
- With the Shop, for Diner uploads and giveaway entries made on that Shop's page. The Shop can see your files, caption, handle, and giveaway entry. If your content is posted, it becomes public on the Shop's website or social accounts, credited to your handle if you gave one.
- With service providers who help us run our business, under contracts that limit their use of the data: hosting and storage ([HOSTING PROVIDER(S), e.g. Cloudflare]), payments (Stripe), email ([EMAIL PROVIDER]), and scheduling or social tools ([SOCIAL SCHEDULING TOOL]).
- With social platforms, when an approved post is published to Instagram, Facebook, TikTok, Google, or another platform. Those platforms handle that content under their own privacy policies.
- For legal reasons, if we believe in good faith it's required by law or legal process, or needed to protect someone's safety, rights, or property, or to stop fraud.
- In a business transfer, such as a merger or sale of our business, in which case this policy will continue to protect the information.
- With your permission, in any other case.
8. How long we keep information
| Information | How long |
|---|---|
| Diner uploads that are never posted (not approved or rejected) | Deleted after 6 months |
| Diner uploads that are posted | While the post is up and the Shop is a client. Then deleted within [POST-OFFBOARDING DELETION WINDOW, e.g. 90 days], unless the Shop keeps its own copy |
| Consent records for posted content | While the post is up, plus 1 year, to show permission was given |
| Giveaway entries (first name, email) | Until [GIVEAWAY ENTRY RETENTION, e.g. 90 days] after the drawing. Winner records for [WINNER RECORD RETENTION, e.g. 3 years] for prize and tax records |
| Hashed IP addresses | With the upload record, or [IP HASH RETENTION, e.g. 90 days] for rejected uploads |
| Business owner client records and content | While you're a client, then up to [CLIENT DATA RETENTION, e.g. 1 year] |
| Billing and tax records | As long as tax and accounting laws require (often 7 years) |
| Prospect info (for our sales outreach) | Until you ask us to stop, or [PROSPECT RETENTION, e.g. 2 years] without contact |
We may keep information longer if the law requires it, or to resolve a dispute.
9. Your choices and rights
Anyone, in any state, can ask us to:
- tell you what personal information we have about you, and send you a copy;
- correct it;
- delete it; and
- take down content you uploaded.
How to ask: email [email protected] with "Privacy request" or "Remove my photo" in the subject. For uploads, include the Shop name, roughly when you uploaded, and your handle or a description of the photo. We may need to confirm the request came from you, for example by replying from the email you entered. We'll respond within [RESPONSE TIME, e.g. 30 days], or sooner if your state's law requires.
Removal of posted content: we aim to remove content from the accounts we manage within 24 hours of confirming your request, and we'll ask the Shop to remove it anywhere else it was used. We can't pull back copies that other people have already shared, saved, or reposted.
State privacy rights. Depending on where you live (for example California, Colorado, Connecticut, Virginia, and other states with privacy laws), you may have additional rights. These include the right to opt out of the sale or "sharing" of personal information or targeted advertising (we don't do either), to limit use of sensitive information (we don't collect it on purpose), and to appeal if we deny a request (reply to our decision with "Appeal"). We won't discriminate against you for using your rights. You can use an authorized agent if your state allows it. [ATTORNEY: CONFIRM WHICH STATE LAWS APPLY AS THE BUSINESS GROWS.]
Marketing emails: business owners can unsubscribe using the link in any marketing email, or by emailing us.
10. Children
Our services are not directed to children under 13, and we don't knowingly collect personal information from them. Children under 13 may not use the upload page. Diners aged 13 to 17 should upload only with a parent or guardian's permission, and giveaways are open only to adults 18 and older. If we learn that we collected personal information from a child under 13, we'll delete it promptly. Parents or guardians who think their child sent us information, or who want content showing their child taken down, can email [email protected].
11. Security
We use reasonable safeguards. Uploaded files are private. They're shown only to the signed-in Shop owner and Crumbtrail staff, and they're never available at a public link until posted. We also use encrypted connections (HTTPS), hashed passwords, access controls, rate limiting, and security headers. No method of transmission or storage is 100% secure. If a data breach affects your personal information, we'll notify you as required by law.
12. Where data is stored
We're based in the United States, and we store and process information in the U.S. Our services are meant for people in the United States.
13. Changes to this policy
We'll update this policy as our services change. We'll post the new version with a new effective date. If the changes are material, we'll notify clients by email and add a notice on the Site.
14. Contact us
[COMPANY LEGAL NAME] d/b/a Crumbtrail [MAILING ADDRESS] Email: [email protected]