Privacy Policy
 

Last updated: 22 October 2026
 

At PhotoNudge, we believe that life's most meaningful moments deserve to be remembered, and that your personal information deserves to be protected.
 

Your privacy matters to us. This Privacy Policy explains how PhotoNudge collects, uses, stores and protects your personal information when you visit our website, subscribe to our mailing list, join our early-access waitlist or express interest in testing our app.

We are committed to protecting your privacy and handling your personal information transparently and responsibly, in accordance with the General Data Protection Regulation (GDPR) and applicable Dutch and European data protection laws.
 

1. Who We Are

PhotoNudge is a digital product currently under development, with the aim of helping individuals, couples and families capture more meaningful everyday moments through personalised photography reminders and inspiration.
 

PhotoNudge is currently operated by an individual based in the Netherlands.
Data Controller: Aline van den Boorn, operating as PhotoNudge

Country: The Netherlands

Email: alinevdboorn@gmail.com

Website: www.photonudgeapp.com
 

For questions about this Privacy Policy or the processing of your personal information, please contact us using the details above.
 

2. What Personal Information We Collect

Depending on how you interact with our website, we may collect the following information:

Information you provide directly:

• First name

• Email address

• Interest in early access, beta testing or the official app launch

• Preferences regarding PhotoNudge communications

• Responses to optional surveys, questionnaires or feedback requests

• Information you voluntarily provide when contacting us

Information collected automatically:

When you visit our website, certain technical information may be collected through our website hosting provider and any enabled analytics tools, including:

• IP address

• Browser type and version

• Device type

• Pages visited and interactions with our website

• Cookie information and website usage data

We only collect personal information that is reasonably necessary for the purposes described in this Privacy Policy.
 

3. How We Use Your Personal Information

We may use your personal information for the following purposes:

Early Access and Beta Testing

• Managing registrations for the PhotoNudge early-access waitlist

• Inviting selected individuals to participate in beta testing or product trials

• Communicating with trial participants about their participation

• Collecting feedback to help improve PhotoNudge

App Launch and Product Communications

• Notifying subscribers when PhotoNudge officially launches

• Sharing announcements about app availability

• Providing updates about new features, improvements and developments

Email Marketing and Newsletters

Where you have provided your consent, we may send you ongoing email communications, including:

• PhotoNudge news and updates

• Photography tips and inspiration

• Educational content about capturing meaningful memories

• Product announcements and feature updates

• Special offers, discounts and promotions

• Subscription-related offers

• Occasional newsletters and other relevant marketing communications

These communications may continue after the official launch of the PhotoNudge app.

Website and Business Operations

• Responding to enquiries and requests

• Understanding interest in our products and services

• Improving our website and product concept

• Maintaining website security and preventing misuse

• Complying with applicable legal obligations

We will not use your personal information for purposes that are incompatible with those described above without an appropriate legal basis.
 

4. Legal Basis for Processing Your Information

Under the GDPR, we process personal information only when we have a valid legal basis.

Depending on the purpose, we rely on the following legal bases:
 

Consent

We rely on your consent when you voluntarily subscribe to receive PhotoNudge marketing emails, newsletters, promotional communications or other optional updates.

Consent is obtained through a clear affirmative action, such as selecting an unchecked consent checkbox on our website.

You may withdraw your consent at any time.
 

Contractual Necessity

Where applicable, we may process information necessary to take steps at your request before entering into an agreement or to administer your participation in an agreed product trial.
 

Legitimate Interests

Where appropriate, we may process limited personal information for legitimate business interests, such as maintaining website security, preventing misuse and improving our services, provided these interests are not overridden by your rights and freedoms.
 

Legal Obligations

We may process personal information where necessary to comply with applicable laws and regulations.
 

5. Email Subscriptions and Marketing Communications

When you subscribe to the PhotoNudge mailing list and provide your consent, you agree to receive email communications relating to PhotoNudge.

These communications may include information about early access, beta testing, the official app launch, photography inspiration, new features, product updates, newsletters and promotional offers.
 

Your subscription is not limited to the period before the app launches.

With your consent, PhotoNudge may continue sending relevant marketing and informational emails after the app becomes publicly available.

You are always in control of your subscription.
 

You can unsubscribe at any time by:

• Clicking the unsubscribe link included in our marketing emails

• Contacting us directly at alinevdboorn@gmail.com
   

We will process your unsubscribe request promptly and stop sending you marketing communications covered by that request.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

We may retain a minimal record of your unsubscribe request where necessary to ensure that you do not receive further unwanted marketing communications.
 

6. How We Store and Protect Your Information

Our website is built and hosted using Wix.

Information submitted through website forms may be stored and processed through Wix's website management, contact management and email marketing services.

We take reasonable technical and organisational measures to protect your personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

These measures may include access controls, secure connections and the security features provided by our service providers.

Access to personal information is limited to individuals and service providers who require it for legitimate operational purposes.

While we take reasonable steps to protect your information, no method of internet transmission or electronic storage is completely secure.
 

7. Sharing Your Personal Information
 

We do not sell your personal information.
 

We may share personal information with trusted third-party service providers where necessary to operate our website, manage our mailing list or provide related services.

These may include:

• Wix: Website hosting, form submissions, contact management and email communications

• [Insert other providers, if applicable]: Email marketing, analytics or other website-related services
   

Where these providers process personal information on our behalf, we seek to ensure that appropriate data protection arrangements are in place.

We may also disclose personal information where required by applicable law or a valid legal request.
 

We do not share your email address with unrelated third parties for their independent marketing purposes without an appropriate legal basis.
 

8. International Data Transfers

Some of our service providers may process or store personal information outside the European Economic Area (EEA).

Where personal information is transferred to countries outside the EEA, we will ensure that an appropriate transfer mechanism is in place where required by the GDPR.

These mechanisms may include:

• European Commission adequacy decisions

• Standard Contractual Clauses approved by the European Commission

• Other lawful safeguards permitted under applicable data protection legislation

You may contact us for further information about relevant international data transfers and safeguards.
 

9. How Long We Keep Your Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Our retention practices include:

Email Subscribers

We retain your contact information while you remain subscribed to PhotoNudge communications. If you unsubscribe, we will remove you from active marketing lists and delete or anonymise information that is no longer required, subject to applicable legal or compliance requirements.

Early-Access and Beta Trial Applicants

We retain application information for [insert retention period or objective deletion criteria], unless you separately consent to ongoing marketing communications or another lawful reason requires us to retain certain information.
 

Enquiries and Feedback

We retain correspondence and feedback for [insert retention period or objective deletion criteria], depending on the nature of the enquiry and whether further follow-up is necessary.
 

Consent Records

We may retain records of consent and withdrawal for as long as reasonably necessary to demonstrate compliance with applicable legal obligations or establish, exercise or defend legal claims.

We periodically review the personal information we hold and delete or anonymise information that is no longer required.
 

10. Cookies and Tracking Technologies

Our website may use cookies and similar technologies to support website functionality and improve the visitor experience.

These technologies may include:

Essential Cookies

Cookies necessary for the basic operation, security and functionality of our website.

Analytics Cookies

Where enabled, cookies that help us understand how visitors interact with our website, which pages are visited and how we can improve the user experience.

Marketing Cookies

Where enabled, cookies or similar technologies that support advertising, campaign measurement or personalised marketing.

We request consent for non-essential cookies and tracking technologies where required by applicable law.

You can manage your cookie preferences through our website's cookie settings, where available, or through your browser settings.

[This section must be reviewed and updated to reflect the actual cookies, analytics services and tracking technologies used on the website.]
 

11. Your Rights Under the GDPR

Under applicable data protection law, you have certain rights regarding your personal information.
 

These may include:

Right of Access

You can request confirmation of whether we process your personal information and obtain access to that information.

Right to Rectification

You can request correction of inaccurate or incomplete personal information.

Right to Erasure

You can request deletion of your personal information in circumstances provided for by law.

Right to Restrict Processing

You can request that we restrict certain processing activities.

Right to Data Portability

Where applicable, you can request to receive personal information you have provided in a structured, commonly used and machine-readable format.

Right to Object

You can object to certain processing activities, including processing for direct marketing purposes.

Right to Withdraw Consent

Where we rely on your consent, you can withdraw it at any time.

To exercise your rights, please contact: Alinevdboorn@gmail.com
 

We will respond within the time limits required by applicable law, generally within one month of receiving your request.
 

You also have the right to lodge a complaint with a competent data protection authority.

In the Netherlands, the relevant authority is:

Autoriteit Persoonsgegevens

Website: https://autoriteitpersoonsgegevens.nl

12. Children's Privacy

The PhotoNudge website, mailing list and early-access registration are intended for individuals aged 18 and over.

We do not knowingly collect personal information directly from children through our website registration forms.

If we become aware that personal information has been collected from a child inappropriately, we will take reasonable steps to delete it.

The future PhotoNudge app may include features relating to family memories and photographs. Any additional processing of personal information through the app, including information relating to children, will be addressed in an updated Privacy Policy before those features become available.
 

13. Automated Decision-Making

We do not currently use personal information collected through our website or mailing list to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.

We may use information voluntarily provided by subscribers to organise mailing lists or send communications relevant to their expressed interests.
 

14. Third-Party Websites

Our website may contain links to third-party websites or services.

We are not responsible for the privacy practices, content or security of websites operated by third parties.

We encourage you to review their privacy policies before providing personal information.
 

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, website, services, data processing practices or applicable laws.

When changes are made, we will update the date at the top of this page.

Where required by law, we will provide additional notice or request renewed consent.

We encourage visitors and subscribers to review this Privacy Policy periodically.
 

16. Contact Us

If you have questions, concerns or requests regarding this Privacy Policy or how your personal information is processed, please contact:

PhotoNudge

Operated by Aline van den Boorn

The Netherlands

Email: alinevdboorn@gmail.com

Website: www.photonudgeapp.com
 

We are committed to handling privacy-related enquiries transparently and responsibly.