⚠️ DRAFT TEMPLATE: not legal advice, not reviewed by an attorney, and not yet in effect. Highlighted [PLACEHOLDERS] still need to be filled in.

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:

The short version:


1. Who's responsible for your information

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:

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:

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

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:

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:

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]