Privacy policy

This English translation is provided for convenience. If it differs from the French version, the French version prevails.

Rimbi helps you organize gift draws among family and friends. Secrecy is at the heart of the app: nobody sees anyone else’s draw, not even the organizer. We apply the same high standard to your personal data.

This policy explains what data we process, why, for how long, with whom, and how to exercise your rights, in accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act (loi Informatique et Libertés).

1. Who is responsible for your data?

SECRETARAI, SASU with share capital of 50 €, registered office in Nice (06200), RCS Nice 103 272 100, publisher of Rimbi.

Contact for any question about your data: [email protected], or from the app: Profile › Data & privacy › Write to us.

2. Our commitments in brief

• Your data is hosted in France (our hosting provider’s Paris region).
• No advertising, no reselling, no profiling. Our business model relies solely on the paid plans.
• No advertising trackers or audience measurement tools in the app.
• Face ID and fingerprint data stay on your phone: we never have access to them.
• The draw is secret by design: our database’s security rules prevent the organizer, administrators and other members from reading your draw.
• As little data as possible: most fields are optional.

3. What data, for what purpose, and on what legal basis?

We do not collect your address book (with “Find your family”, only fingerprints of email addresses leave your phone, and we don’t keep them), your location, your browsing history, or your bank details (payments go through the App Store or Google Play).

“Find your family”: how it works

• Your permission first. The app only reads your contacts if you allow it in the iOS or Android prompt, for your whole address book or only the contacts you pick. You can withdraw this access at any time in your phone’s settings.
• Nothing readable leaves your phone. The app only reads your contacts’ email addresses. On your phone, it lowercases them, removes spaces and turns them into fingerprints (SHA-256 function). Only these fingerprints are sent to our server, in France: never names, numbers, email addresses or the address book itself.
• Compared, then forgotten. The server compares these fingerprints with those of Rimbi accounts’ email addresses (for this, we keep a fingerprint of each account’s address, erased with the account), then does not keep them. Such a fingerprint is not anonymous: it is pseudonymized data, which is still personal data. That is why we don’t keep it.
• Only people who agree can be found. Only accounts (never child profiles) with the setting Profile › Data & privacy › Let my contacts find me turned on appear. It is on by default and can be turned off at any time. For someone found, you see their first name, avatar and the groups you already share, never their email address.
• Limited records. To prevent abuse, we count the number of fingerprints sent and the date of each search (24 hours); one search is limited to 1,000 contacts. We keep the record “this person found that person” for 7 days, to allow a direct invitation. These records are erased as soon as the person found turns the setting off, and with the account.
• An invitation, never a forced sign-up. Someone found and invited gets a notification and accepts or declines. An unanswered invitation expires after 7 days; answered or expired invitations are erased after 30 days. After a “no”, the same person can’t invite you into that group again for 30 days.
• Rimbi never writes to your contacts. To invite a contact who doesn’t have an account yet, the app prepares a text message or a share that you send yourself, from your phone.
• It’s all in your export. This information is included when you download your data (find_family section).

4. Who sees what in the app?

• Your draw: only you. In “open” mode, chosen by the organizer before the draw and visible to all, everyone sees who is giving to whom.
• The final reveal, if the organizer turns it on: depending on their choice, fixed at the time of the draw, each person discovers their own Secret Santa, or the whole chain is revealed to the participants.
• A member’s page (ideas, votes, discussion about them): the other members of the group, never the person concerned.
• Your wish list: your groups; you never see who has reserved what.
• Your postal address: only your Secret Santa, for a long-distance exchange, and then it is erased.
• The code of a guest without the app: the guest alone; the organizer only sees a masked number or address.
• Your account, with “Find your family”: only people who have your email address in their contacts can see that you’re on Rimbi (first name, avatar, groups in common), and only if you leave the “Let my contacts find me” setting on.

5. Who do we share your data with?

Only with service providers that help us run the app (our “processors”), bound by a data processing agreement that complies with Article 28 of the GDPR, and only for this service:

Apple and Google process your in-app purchases as independent controllers, under their own privacy policies.

The up-to-date list of our processors is published on the Our processors page. We never sell or rent out your data. We may be required to disclose data to a judicial or administrative authority, in the cases provided for by law.

6. Transfers outside the European Union

Your data is stored in France. A few limited transfers outside the European Union may take place:

• notifications pass through the services of Expo, Apple and Google, which receive only the text of the notification (which never contains the name of the person you drew) and a technical identifier of your phone;
• the rimbi.app website is hosted by Cloudflare, which receives the IP address and browser of the website’s visitors in its technical logs;
• RevenueCat receives an anonymous account identifier and the status of your subscription, without your name or email;
• Supabase’s technical support may, exceptionally, access the infrastructure from outside the Union.

These transfers are covered by the EU–US Data Privacy Framework where the provider participates in it, or otherwise by the European Commission’s standard contractual clauses.

7. How long do we keep your data?

8. How do we protect your data?

• Encryption of communications (HTTPS) and of stored data.
• Access rules in the database, row by row: each person can only read what concerns them.
• Passwords and codes (gift codes, guest codes) never stored in plain text.
• Optional two-factor authentication, login alerts, remote sign-out of devices.
• Team access limited to what is strictly necessary, and logged.
• In the event of a data breach presenting a risk, we notify the CNIL (the French data protection authority) within 72 hours and, if the risk is high, the people concerned.

9. Your rights

At any time, you can:

• access your data and obtain a copy of it;
• rectify it;
• erase it, by deleting your account from the app (Profile › Data & privacy › Delete my account);
• download your data in a machine-readable format (portability);
• object to processing based on legitimate interest, or request its restriction (to stop being found by your contacts, just turn off Let my contacts find me);
• withdraw your consent (allergies, news by email), without affecting what was done before;
• set instructions on what happens to your data after your death.

Most of these actions can be done directly in Profile › Data & privacy. For anything else, write to us at [email protected]. We reply within one month at most. We may ask you to prove your identity if there is any doubt.

If you believe your rights are not being respected, you can lodge a complaint with the CNIL (www.cnil.fr).

10. Minors

You must be at least 15 years old to create an account. For younger people, a parent can create a child profile, which they manage themselves: the child does not have an account. The parent exercises the child’s rights over this data. The child will be able to take over their profile at 15, by creating their own account.

11. Trackers and storage on your device

The app and the web page use no advertising cookies or audience measurement tools. They only store on your device what is strictly necessary for them to work (login session, preferences, a guest’s access). These items are exempt from consent.

The rimbi.app website does not set any cookies. Like any web host, ours, Cloudflare, records technical logs (IP address, date, page requested, browser) to keep the website secure; they are never used to measure audience and are kept for at most one year, the period set by law for connection data.

12. Changes

If we make significant changes to this policy, we will let you know in the app before the changes take effect.