Cookie policy

It is worth separating these, because most cookie policies blur them and the distinction is the whole point here.

3.1Strictly necessary

Required for the service to work at all. Under Article 5(3) of the ePrivacy Directive, as implemented in Dutch law through the Telecommunicatiewet, these are exempt from the consent requirement because they are strictly necessary to provide a service you explicitly asked for. You cannot turn them off and still use Twirl.

3.2Analytics on the marketing site

See section 4. The specific tool, what it stores, and whether consent is required are set out there rather than here, because the answer depends on the tool and we would rather state it once and properly.

3.3Never used

• Advertising, remarketing and social media pixels.
• Cross-site behavioural profiling.
• Sentry Session Replay, which would record screen content including event media. It is off and we have no plan to enable it.
• Any analytics inside the product.
• Email open tracking and click tracking.

4.1What we are trying to learn

How many people visit, which pages they read, and roughly where they came from. That is it. We are not building profiles, we are not following anyone across the web, and we are not interested in identifying individual visitors.

4.2The tool

We use [TOOL], hosted in the EU.

It sets no cookies. It writes nothing to your device, not a cookie and not a local storage entry. It does not identify you, does not build a profile, and does not follow you to other websites. The numbers it produces are aggregate counts, not records about individuals.

That is why you have not been shown a consent banner. Consent under Article 5(3) of the ePrivacy Directive is required for storing or reading information on your device, and this tool does neither. We would rather choose a tool that does not need a banner than build a banner.

4.3What analytics never covers

Whichever branch applies, analytics runs on public marketing pages only. It does not run in organizer dashboards, on guest event pages, or in upload and RSVP flows. What happens inside your event is not measured by us.

We send transactional and lifecycle email through Brevo from hello@twirl.photos, using mail.twirl.photos as the tracking subdomain.

We have turned open tracking and click tracking off. Brevo is capable of embedding an invisible image that reports when a message is opened, and of rewriting links to report clicks. We have disabled both. We do not know whether you read our email.

What we do keep is delivery and bounce reporting, meaning whether the message reached your mail server or was rejected. That is not optional for us: if a deletion warning bounces, we need to know, because someone is about to lose their photographs without ever having been told.

This is a deliberate choice rather than a technical limitation. Reading and writing information on a device through a tracking pixel falls under the same rule as cookies, even though no cookie is involved, and the argument that open tracking is strictly necessary to deliver a payment receipt is weak. Rather than construct that argument, we turned it off.

6.1The current position

Everything in section 3.1 is strictly necessary and exempt from consent. Whether a banner appears at all depends on the analytics decision in section 4.2. This page, linked in the site footer, satisfies the transparency obligation that applies either way.

6.2What would make a banner mandatory

• An analytics tool that stores or reads anything on the device, including a cookieless tool using local storage.
• Any advertising, remarketing or social media pixel.
• Sentry Session Replay, or any comparable recording feature.
• Stripe's script loading site-wide rather than only on checkout pages.
• Any A/B testing or personalisation tool.

6.3What the mechanism would need to look like

Minimum requirements under the GDPR and ePrivacy rules, as consistently interpreted by the EDPB and the Autoriteit Persoonsgegevens. Written down now so the requirement is not discovered late.

• Prior. Nothing non-essential is set before you act. No pre-loading of scripts "pending consent".
• Opt-in, not opt-out. No pre-ticked boxes. Continuing to scroll is not consent.
• Reject is as easy as accept. Both options on the first layer, equally prominent, with equal visual weight. No greyed out reject button, no extra click to refuse.
• Granular. Separate consent per purpose. One toggle covering everything is not valid.
• Withdrawable. A persistent way to change your mind later, at least as easy as giving consent. Usually a footer link.
• Documented. A record of what was consented to, when, and against which version of this policy.
• No cookie wall. Access to the site cannot be conditioned on accepting non-essential cookies.

You can block or delete cookies in your browser settings. If you block the strictly necessary ones in section 3.1, organizer login will not work and guest event access will ask for the event password repeatedly. Nothing else on the site depends on them.

This page is updated whenever what we use changes. The date at the top reflects the last change. Any change that introduces something requiring consent will be accompanied by a consent mechanism appearing before that thing is set, not after.

Questions about this policy: privacy@twirl.photos.

Ciceroni VOF, KVK 76619176, Franklinstraat 161, 2562 CD Den Haag, the Netherlands.