Privacy policy

Draft pursuant to Art. 13 and 14 GDPR – to be legally reviewed before publication.

1. Controller

[Name / organisation], [Address], email: [Data protection contact]

[If applicable: data protection officer with contact details]

2. Principles

We process as little data as possible. There are no tracking cookies, no advertising, no social media plugins and no embedded fonts or scripts from third parties. The website and all data are hosted on a server in the European Union.

3. What we process and why

3.1 Visiting the website

When you visit the site, the server processes technically necessary data (IP address, time, page requested, browser identifier) in order to deliver the page and protect it against attacks. IP addresses are not stored in plain text in our application logs, only as an encrypted short value (hash) for abuse protection (e.g. limiting login attempts). The web server logs are deleted after [14] days. Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in secure operation.

Audience measurement: [none / or: cookieless, self-hosted statistics (Plausible/Umami) without personal profiles]

3.2 Member account

For an account we store your email address, display name, a password (only as an irreversible Argon2id hash) or passkeys and – if enabled – an encrypted key for two-factor login, as well as the times at which you agreed to the terms of use and the privacy policy. Legal basis: contract (Art. 6(1)(b) GDPR).

When you set a password, we check anonymously whether it appears in known data breaches (“Have I Been Pwned”, k-anonymity): only the first 5 characters of a check value ever leave our server, never the password itself.

3.3 Contributions (pictures, texts, comments)

Uploaded files, descriptions and comments are published once they have been approved, together with your display name. Embedded metadata (e.g. GPS position, camera data) is removed from all publicly displayed versions; the original file remains stored internally. Legal basis: contract and consent to publication (Art. 6(1)(a) and (b) GDPR).

3.4 People shown in pictures

Historical pictures often show people. People are only named by hand and according to our rules; there is no automatic facial recognition. Those affected and their relatives can request removal or anonymisation at any time (“Report content” function or email).

3.5 Automatic checking of content

To protect against inappropriate content, our server automatically checks uploaded pictures using a program that runs on our own server. No data is passed on to third parties. In case of doubt, the final decision is made by a person.

[ONLY if enabled: for AI suggestions when uploading or a second opinion in borderline cases, the picture or text is sent to Anthropic PBC (USA) (processor, standard contractual clauses / Data Privacy Framework – check). These functions are currently SWITCHED OFF.]

3.6 Automatic translation

So that the archive can also be read in English, Hungarian and Croatian, titles, descriptions, topics and comments are translated automatically. Only the text is transmitted – without names, email addresses or account data – to [Google Cloud Translation, Google Ireland Ltd. (or Anthropic PBC, depending on the setting) – check data processing agreement]. Legal basis: legitimate interest in a multilingual service (Art. 6(1)(f) GDPR). Translations are marked as “Machine-translated”, and the German original can be viewed at any time.

3.7 Emails

We send emails to confirm your address, login links and – which you can unsubscribe from – notifications about comments and approvals. Sent via [Hostinger International Ltd. (email service), Cyprus/EU].

3.8 Contact and report form

We only use your details (name, email, message) to deal with your request. Spam protection is provided by a small calculation task in your browser (ALTCHA, self-hosted), without cookies and without third parties.

3.9 Location feature

“What used to be here?” uses your location – only after you have explicitly allowed it in your browser – to show pictures nearby. Your location is only used on your device and is not transmitted to us or stored.

3.10 Maps

Map tiles from OpenStreetMap are loaded and cached via our own server. Your IP address is not passed on to OpenStreetMap.

4. Processors

• Hosting: [Hostinger International Ltd., server location EU – check data processing agreement]
• Email delivery: [Hostinger Mail]
• Automatic translation: [Google Cloud Translation (Google Ireland Ltd.), once enabled]
• Backups: [Backup target, e.g. S3-compatible storage in the EU] (encrypted)
• [Only if enabled: Anthropic PBC (AI functions)]

5. Storage period

• Account: until you delete it; your data is then removed within 30 days (contributions anonymised or deleted, as you choose).
• Sessions: no more than 30 days. Login links: 20 minutes. Confirmation links: 24 hours.
• Contact requests and reports: [3 years] after completion.
• Moderation log: [define period] – needed to keep decisions traceable.
• Backups: daily for 14 days, monthly for 12 months.

6. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection, as well as the right to withdraw consent at any time. You can do much of this directly under “My account → My data” (data export, delete account, consents). You can lodge complaints with the Austrian Data Protection Authority (www.dsb.gv.at).