Privacy Policy
This is a translation provided for convenience. In case of discrepancy, the French version prevails.
Version 2 — draft to be reviewed by a lawyer before publication. Passages in square brackets are to be completed.
1. Data controller
Julien Camboulives EI, [FULL ADDRESS], Paris, reachable at contact@waited.app (data protection officer: [IF APPOINTED]).
2. What we collect and why
| Data | Why | Legal basis |
|---|---|---|
| Username, password (stored hashed), recovery code (stored hashed) | Create your account and recover it | Performance of the contract |
| Month and year of birth, date of acceptance of the terms | Check the minimum age (16), better protect under-18s | Performance of the contract, legitimate interest (protection of minors) |
| Public encryption key | Allow encrypted photos to be sent to you | Performance of the contract |
| List of follows, blocks | Friends, conversations, protection | Performance of the contract |
| Text messages | Display your conversations | Performance of the contract |
| Reactions (the emoji chosen on the other person's message or photo) | Display your conversations | Performance of the contract |
| Streaks: the days each of you sent the other a photo, the streak's length and its last day | Work out the streak and its credits | Performance of the contract |
| Groups: their name, their members, who added whom and when, who changed their settings, each member's mute setting; their moments (who posted and when, who was nudged and by whom) and their counter | Run groups and their moments | Performance of the contract |
| Encrypted photos and their settings (waiting time, protections, challenges) | Deliver the photos | Performance of the contract |
| Credits (balance, credits earned and used) | Manage credits | Performance of the contract |
| Referral: the account that invited you with an invitation link or its profile link, the accounts you invited, and the credits earned that way | Reward referrals, prevent abuse | Performance of the contract, legitimate interest |
| Notification token | Send notifications | Performance of the contract |
| Phone system (iOS or Android) and app version, from the last time you used the app | Follow how the app is used on each system, fix the app | Legitimate interest |
| Days you used the app (the date only, nothing of what you did in it) | Count the people who use the app and those who come back to it | Legitimate interest |
| In-app notifications (who follows you, a photo received, a challenge completed, a moderation decision) | Tell you what concerns you | Performance of the contract |
| Identification data of each content creation (account, type and identifier of the content, date and time, IP address and source port), never the content itself | Allow the author of content to be identified at the request of the judicial authorities | Legal obligation (article 6 of the French law on confidence in the digital economy, decree no. 2021-1362) |
| Reports, moderation decisions and their log; for a reported photo, the transmitted photo (encrypted on our servers) and its fingerprint | Moderation, safety, evidence in case of proceedings | Legitimate interest, legal obligation |
| Feedback sent from the app: a bug, an idea or something else (type, text, app version, phone model and system, language) | Fix and improve the app | Legitimate interest |
| Opinions given in the app when a questionnaire is asked (a rating from 1 to 5 per question, optional text, app version, phone system, language) | Improve the app | Legitimate interest |
| Email address left on the website (waiting list) and the page's language | Tell you, in a single email, when the app is released | Consent |
| Keyed hash of the IP address when visiting the website (never the address itself, no cookie) | Count the website's visitors (audience measurement) | Legitimate interest |
Photo encryption. Your photos are encrypted on your phone. Our servers only store an encrypted version that they cannot read. The only exception: when a recipient reports a photo, they send it to us decrypted for moderation. We then store it encrypted, with a key kept outside our data servers, and every time a moderator views it is recorded.
A photo taken, not sent yet. So that sending is instant, the app sends us the photo, encrypted, as soon as it is taken, while you choose the wait and your friends. If you don't send it (photo retaken, sending abandoned), this encrypted version is deleted from our servers within one hour at most.
Nudity detection. The app analyses photos on your phone, before they are sent and when a received photo is opened. Neither the photo nor the result is sent to us. When a photo seems sensitive, the app simply asks for the strongest protections for that sending (view once, screenshots blocked): we record those protections, as for any photo, never the reason.
Text messages. Text messages are not end-to-end encrypted: they are encrypted in transit and stored on our servers.
We do not sell your data and we do not use targeted advertising.
3. Recipients
- Hosting: [HOSTING PROVIDER, COUNTRY].
- Notifications: Expo's notification service (United States), then Apple and Google, which receive the text of the notification. [TRANSFER SAFEGUARD: DATA PRIVACY FRAMEWORK OR STANDARD CONTRACTUAL CLAUSES].
- Judicial authorities, on request (identification data, reports).
- PHAROS, the French authorities' reporting platform, for content involving a minor.
4. Retention periods
- Photos: automatically deleted 7 days after they are sent by default — the sender chooses 24 hours, 7 days or 30 days for each conversation; if the wait is longer, the photo stays until one day after the wait ends (31 days at most). Earlier if the sender deletes it, if either party deletes their account or if moderation removes it. A "view once" photo can only be opened once: the recipient's key is erased from our servers as soon as it is opened. Backup copies follow within one hour for photos and within 3 days for the database.
- A photo taken but never sent: its encrypted version, sent ahead, is deleted within one hour at most (sooner if you take other photos).
- Account, month and year of birth, text messages: as long as your account exists.
- Account deletion: immediate erasure, except identification data and reports, kept as described below.
- Identification data: one year after each content creation, including after the account is deleted.
- Reports and moderation log: one year after the decision. The photo transmitted with a report is deleted when the decision is made; if it was handed to the authorities, it is kept encrypted for one year for the investigation, then deleted.
- Feedback (bugs, ideas): deleted with the account, and 90 days after being handled.
- Opinions: deleted with the account, and a year after being given.
- In-app notifications: 90 days.
- Waiting list (email address left on the website): deleted after the email announcing the app's release, or earlier on request.
- Website visits (hash of the IP address): 13 months.
- Days you used the app: 13 months (deleted with the account).
- Credits earned by sending photos: the record of each rewarded send is erased after 24 hours (the balance stays in the conversation).
- Reactions: kept with the message or photo they're on (or until you take them back).
- Streaks: the day of each send is erased after 2 days; the streak's length and its last day stay in the conversation for as long as it exists.
- Groups: for as long as the group exists (it is deleted when its last member leaves); your place in a group, until you leave it. A moment's photos: deleted unseen if the moment isn't complete in time, otherwise 1, 7 or 30 days after it opens (a setting of the group). When you leave a group, the photos sent to you there and your photo of the current moment are deleted. When only two people are left, the group closes: if they both follow each other, what they said and sent each other in the group since they were both in it moves to their conversation together (and follows its retention); the rest of the group is deleted.
- Referral: as long as the inviting account exists. If the invited account is deleted, only a record that a referral took place remains, with no link to it, to apply the monthly limit.
5. Your rights
You can access your data, rectify it, erase it (account deletion in the app), restrict its processing, object to it and request its portability, by writing to contact@waited.app. You can also lodge a complaint with the CNIL (www.cnil.fr).
6. Minors
waited is restricted to persons aged 16 or over. Between 16 and 18, a photo that seems to contain nudity can be neither sent nor shown. An account belonging to someone under 16 is suspended; they can write to us to have their data deleted. If you believe an account belongs to a younger person, report it or write to us.
7. Security
Hashed passwords and recovery codes (scrypt), end-to-end encrypted photos, private key kept only on your phone, encrypted connections (HTTPS), photos transmitted with a report encrypted (AES-256) and every view recorded.