Data controller
The controller of your data is Elia Interactive, EURL with a share capital of €1,000, RCS Nanterre 834 492 894, 22B Avenue de la Division Leclerc, 92320 Châtillon, France, publisher of Eliacover. Contact: contact@eliacover.com.
Data we collect
Eliacover collects the following data: account information (first name, last name, email address, a password never stored in plain text, or the identity passed on by Google if you sign in with Google); what you provide to create your books: photos (with the information they contain, including the date and GPS position of the shot), face photos, documents, scans, PDFs, voice messages, a website address, answers to Elia's questions and instructions; the books created and their content; payment and billing data (payment is processed by Stripe: we never see or store card numbers); for a printed book, the name, delivery address, phone number and tracking email (encrypted in our databases); your messages to support and through the contact form; notification subscriptions of your devices; technical data (logs, security, protection against bots and against abuse of the free preview); a record of your cookie choices and of your consents (see “Proof of your consent”). Only with your consent (“Audience measurement” category): visit statistics for the website and the app (see “Audience measurement (Google Analytics)”).
Purposes of processing
Your data is processed to: create your books with Elia from what you provide (analysis of your photos and documents, transcription of your voice messages, writing the texts, creating the illustrations, layout, maps of the places in your photos, audiobook) and, with your consent, show your loved ones in them with a good likeness; show you a free preview and prevent its abuse; manage your account, payments, balance, gift cards and referrals; make, ship and track your printed books; send you service-related emails and notifications (no marketing without consent); help you, secure the service (bots, fraud, abuse, moderation), record sessions in the app and fix bugs; keep proof of your choices and consents. The documents, scans, PDFs and voice messages you send are working material for Elia: they are not reproduced as such in your book unless you ask for it (in the photo album, your photos make up the book). With your consent: measure the audience of the website and the app (pages viewed, where visits come from, book shares). Audiobook: create, at your request, the narration of your books with synthetic voices generated by artificial intelligence from a description, with sounds and music that are also generated; no recording of your voice is requested for this, and your voice messages are never used to reproduce or clone a voice.
Legal basis
The processing of your data is based on: performance of the contract (creating your books, account, payment, printing, delivery and parcel tracking), your explicit consent (face processing, audience measurement, newsletter), legitimate interest (security, preventing fraud and abuse of the free preview, support, session recording, service improvement), legal obligations (billing, accounting, proof of consent, removal of unlawful content). Biometric data (facial recognition) relies exclusively on your explicit consent (Article 9(2)(a) GDPR). Audience measurement (Google Analytics) relies exclusively on your consent (Article 6(1)(a) GDPR and, for cookies and trackers, Article 82 of the French Data Protection Act), which you can withdraw at any time. Keeping proof of your cookie choices relies on a legal obligation: being able to demonstrate consent (Article 7(1) GDPR).
Retention period
Your data is kept for as long as your account remains active. When you delete your account, your data (books, photos, face templates, balance…) is erased within 24 hours; the backup copies of our files then disappear within 30 days, and the backups of our databases (which do not contain your photos) within 35 days for daily backups and 12 months for monthly backups. Files you send (photos, documents, scans, PDFs, voice messages): for books created with the three current ways of creating, the original files are deleted automatically 90 days after they are sent; your book keeps its own images (for the photo album, a copy of the photos used, adapted for reading and printing) and what Elia drew from them (for example the written transcription of a voice message), kept with the book and deleted with it. A book's working files (image attempts, checks) are deleted after 30 days. Photos in a draft that is never launched are deleted after 90 days, and an uploaded ZIP file is deleted as soon as its photos have been extracted (at the latest 30 days after upload). Photo albums created with the previous version of the album: an unpaid preview is deleted 30 days after it is ready (its original photos earlier, between 7 and 14 days); for a paid album, unused original photos are deleted 90 days after payment, and those in the book 6 months after. Billing data is kept for 10 years in accordance with French legal obligations. Our servers' technical logs are kept for 30 days; session recordings, 30 days. Your account's activity log, which contains proof of your consents and of your acceptance of these texts (text accepted, version, date, language, truncated IP address), is kept for 5 years after the end of our relationship (the limitation period), including after the account is deleted, so that these agreements can be proven. The delivery address of a printed book is kept, encrypted, with the order for as long as your account exists (tracking, after-sales service), and deleted with it. Face templates (facial recognition) are deleted when the book is launched, when the draft is deleted or when consent is withdrawn, and at the latest 30 days after they were created. Google Analytics cookies expire after 13 months and audience measurement data is kept for 14 months in Google Analytics, then deleted automatically. Proof of your cookie choices is kept for 13 months, which is longer than a choice remains valid (6 months). Audiobook: the narration text and audio files are kept with the book and deleted with it; synthetic voices no longer used by any book are deleted automatically at our provider. No recording of your voice is requested or kept.
Hosting, providers and transfers outside the European Union
Your data is hosted by Amazon Web Services (AWS) in the Paris region (eu-west-3), France, encrypted at rest and in transit. Our providers use your data only to provide their service to us, on our instructions: (1) Amazon Web Services EMEA SARL (Luxembourg): hosting, storage, databases, sign-in (Amazon Cognito), sending our emails (Amazon SES, Paris region), bot protection (AWS WAF); with your consent, face analysis by Amazon Rekognition in the Ireland region (eu-west-1); writing the texts and designing the books by Elia, with artificial intelligence models provided by Amazon Bedrock in the European Union: requests are processed in European AWS regions (Paris, Frankfurt, Ireland…) and, if unavailable, by another model of the same family, still in the European Union; this data stays with AWS, the model provider has no access to it, and it is not used to train models; (2) Google LLC (United States): analysis of your photos and documents, transcription of your voice messages, reading a website whose address you give, creating images and videos and, for the audiobook, creating synthetic voices from the narration text and the description of each voice; with your consent, reference photos of your loved ones' faces to draw them (see “Face photos and facial recognition”); Google does not use this data to train its models and keeps it, for a limited time, only to detect abuse; (3) fal.ai, Inc. (United States): creating some images and animations, and backup relay if our main engine is unavailable, without keeping requests or results; (4) ElevenLabs: sounds and music of the audiobook, from a short description of the desired sound or music, with no photo or voice recording; (5) Stripe Payments Europe Ltd (Ireland): payment; (6) printers: Prodigi (United Kingdom) for the Essentiel range and CEWE (France) for the Signature range, which receive your book's print files, the name, delivery address, phone number and, for Essentiel, the tracking email; the carrier receives the delivery address; (7) Ship24: parcel tracking, from the tracking number and destination country only; (8) Zoho (European Union data centre): inbox of contact@eliacover.com, whose messages are forwarded to a Gmail (Google) mailbox of the team; (9) maps: to name the places in your photos and draw your album's maps, the coordinates of these places, with no other data, are sent to OpenStreetMap public services (Nominatim, from the OpenStreetMap Foundation, and Overpass servers); map backgrounds are hosted by Eliacover; (10) Google Ireland Limited: audience measurement, with your consent (see “Audience measurement (Google Analytics)”), and sign-in with Google if you choose it. Transfers outside the European Union: to the United States (Google LLC, fal.ai, Inc., Stripe, Inc., ElevenLabs where applicable), covered by the EU–US Data Privacy Framework for certified companies and by the European Commission's standard contractual clauses; to the United Kingdom (Prodigi, OpenStreetMap Foundation), covered by an adequacy decision of the European Commission. Apart from these cases, no data is transferred outside the European Union.
User rights
Under the GDPR, you have the following rights: right of access to your data, right to rectification, right to erasure (right to be forgotten), right to data portability, right to object, right to restriction of processing, right to withdraw a consent at any time (without affecting processing already carried out) and right to set instructions for what happens to your data after your death. To exercise these rights, write to us at contact@eliacover.com; most can also be exercised directly from your account (deleting a photo, a book or the account, withdrawing a consent).
Audience measurement (Google Analytics)
Only with your consent (“Audience measurement” category of the cookie banner), Eliacover uses Google Analytics 4 on the eliacover.com website and in the app.eliacover.com app to measure how they are used: pages viewed, where visits come from and the main actions taken. Until you have given your consent, Google's script is not loaded at all. Processor: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, under Google's data processing terms (Google Ads Data Processing Terms, accepted). Settings used: Google signals, ad personalization, granular location and device data collection, and data sharing with Google for its own purposes turned off; in Google Consent Mode (v2), advertising purposes always remain denied; no identifier relating to you is sent (no account identifier, no email address, no name); page addresses are cleaned before being sent (shared-book link tokens and sensitive parameters are removed); Google Analytics 4 does not log or store IP addresses, which are only used transiently to infer an approximate country or region and then discarded. Data processed: a random identifier stored in the _ga and _ga_<ID> cookies, pages viewed, where visits come from, device and browser type, approximate location, browsing events. Transfer: data may be transferred to Google LLC in the United States; this transfer is covered by the EU-U.S. Data Privacy Framework, under which Google LLC is certified, and by standard contractual clauses. Legal basis: your consent (Article 6(1)(a) GDPR and Article 82 of the French Data Protection Act), which you can withdraw at any time via the “Manage cookies” link or in your account settings (Privacy section): measurement stops and the _ga cookies are deleted. Retention: 13 months for the cookies, 14 months for the data in Google Analytics, then automatic deletion. With the same consent, when you open a shared book, the first share link you received is remembered for 30 days in your browser's local storage (eliacover.v5.referral, along with the list of shared books already opened, eliacover.v5.sharesSeen), so we know which share led you to discover Eliacover; without your consent, this information is only kept in memory for the duration of the visit.
Measuring our ads (Meta pixel)
Only with your consent (“Advertising” category of the cookie banner), Eliacover uses the Meta pixel on the eliacover.com website and in the app.eliacover.com app to measure how well its Facebook and Instagram ads work: visit, sign-up, free preview started, purchase (amount and currency). Until you have given your consent, Meta's script is not loaded at all. Data processed: a random browser identifier (_fbp cookie) and, if you arrive through an ad, a click identifier (_fbc cookie), page address, device and browser type, IP address (processed by Meta). No data from your account is sent (no email address, name or phone number: advanced matching is off), automatic events are off, and nothing is sent from a page whose address contains a shared-link token or a gift code. Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) is joint controller with Eliacover for collecting and transmitting this data (Article 26 GDPR), then sole controller for its further use, in particular to show ads; its policy: https://www.facebook.com/privacy/policy. Transfer: data may be transferred to Meta Platforms, Inc. in the United States, under the EU–US Data Privacy Framework, to which Meta Platforms, Inc. is certified, and standard contractual clauses. Legal basis: your consent (Article 6.1.a GDPR and Article 82 of the French Data Protection Act), which you can withdraw at any time via the “Manage cookies” link or in your account settings (Privacy section): the pixel stops sending anything and the _fbp and _fbc cookies are deleted. Retention: 3 months for the cookies; data received by Meta is kept according to its own policy.
Session recording in the app
When you are signed in to the app at app.eliacover.com, Eliacover records how your sessions unfold in order to assist you, understand and fix errors, and improve the service. This processing is carried out by Eliacover itself, without any processor. Data processed: changes to the app screen (pages, text and images displayed, including your photos and books, which the recording does not copy: it only keeps a reference to them), clicks, scrolling and text typed, screen size and orientation, device and browser type, approximate location (country, region and city), derived from the IP address at the start of the session using a geolocation database installed on our servers, without calling any third-party service (the IP address itself is not stored), pages visited, errors and, for each exchange with our servers, the generic address called, the result, the duration and technical identifiers, never the content exchanged. Never recorded: passwords, codes received by email or used for authentication, and payment card details (payment takes place on the secure page of our payment provider, which is never recorded). A portion of sessions is recorded, and always those in which an error or a payment occurs. Access: restricted to authorized members of the Eliacover team, who may replay a session or follow it live, without ever being able to act on your behalf; every viewing is logged. Hosting: Amazon Web Services, Paris region (France). Storage in your browser: a random identifier for the browser (local storage) and for the tab (session storage), to tell your tabs apart; no cookie. Legal basis: Eliacover's legitimate interest in assisting its users, ensuring the proper functioning and security of the service and improving it (Article 6(1)(f) GDPR); you are informed of it through these terms, accepted in the app. You may object at any time by writing to contact@eliacover.com. Retention period: 30 days, then automatic deletion.
Proof of your consent
Each time you make or change a cookie choice (accept all, reject all, customize), we record on our servers: a random reference for the choice, its date, the version of the text shown, the categories chosen, the action taken (accept all, reject all or custom choice), where the choice was made (banner, settings panel or account), the language, and whether it was made on the website or in the app. This log contains no IP address and no account identifier. When you are signed in, your setting is also saved on your account. Purpose: being able to demonstrate that your consent was properly obtained (Article 7(1) GDPR). Legal basis: legal obligation. Retention: 13 months (longer than a choice remains valid, 6 months), then automatic deletion. Hosting: AWS, Paris region (eu-west-3).
Face photos and facial recognition
Face photos and the data derived from them are biometric data, a special category of data under Article 9 of the GDPR. They are only processed with your explicit consent (Article 9(2)(a)), which can be withdrawn at any time in your account. Photo album (“Your photos”): this consent is asked once for your account, before your first photo upload (and again if this text changes), through a “Yes” / “No thanks” choice presented equally (nothing is pre-selected); with your consent, Amazon Rekognition (Amazon Web Services, Ireland region eu-west-1, European Union) locates the faces in your photos so that a face is never cut off in the layout. Recognising faces person by person (grouping your photos by person, suggesting a person already saved in your library, which you always confirm yourself) only happens if you turn this option on yourself, when it is offered. “You're the hero” and “Starring you”: these books draw people from their photos; your consent is asked for each book, together with confirmation that the people photographed agree, before their photos are sent. Amazon Rekognition may also check the quality of each person's reference photos (sharpness, angle, same person) and the likeness of people in the images created (cover and illustrations). The digital face templates are kept in a space dedicated to your project, together with small face thumbnails; they are deleted when the book generation is launched, when the draft is deleted or when you withdraw your consent, and at the latest 30 days after they were created. The likeness check compares images on the fly and keeps no template. Drawing your loved ones: so that they look like themselves, the reference photos of their faces (cropped to the face, with any other people in the photo masked) are transmitted, together with the instructions for each image, to our image generation provider, Google LLC (United States), under its data processing addendum: Google does not use these photos to train its models and keeps them for at most 55 days, solely to detect abuse. When an image is not a close enough likeness, it may be recreated by a second provider, fal.ai, Inc. (United States), which we ask to keep neither the photos nor the generated images and which does not use them to train models. Only photos are transmitted to these providers, never a biometric template; these transfers are covered by standard contractual clauses and, for Google, by the Data Privacy Framework. Without this consent, no face is analysed or transmitted: in the photo album, your photos are still used (places, mood, memory pages), but your loved ones are not reproduced in the illustrations; in “You're the hero” and “Starring you”, photos of people cannot be used. Your photos and biometric data are never sold or shared for other purposes, and are not used to train artificial intelligence models. Photos are encrypted, stored in France and can be deleted at any time. Reference portrait: when you add a person, a few portraits are drawn from their photos and you pick the closest likeness; the chosen portrait is kept with their profile (and deleted with it) and may be used as an additional reference, sent to our image generation providers in the same way, to keep their face consistent from page to page.
Data from your Google account
When you import photos or files from Google Photos or Google Drive, or sign in to Eliacover with Google, Eliacover accesses certain data from your Google account, strictly within the following limits. Data accessed: (1) Google Photos: only the photos and videos you choose yourself in the Google Photos picker (Google Photos Picker); Eliacover has no access to the rest of your library or to your albums; (2) Google Drive: only the files (photos, videos, PDF, Word, text) you choose yourself in the Google Drive picker (Google Picker), with an authorization limited to the chosen files; Eliacover cannot browse, modify or delete your other files; (3) the email address of the Google account used for the import, shown only in your browser (“Connected with …”) and never stored on our servers; (4) if you sign in with Google: your email address (and whether it is verified), your first and last name and your profile picture, to create your account and identify you. The access authorization issued by Google (access token) is temporary: it stays in your browser while it is valid and is sent to our servers only to download the chosen items, without ever being stored there. Purpose: only to import the chosen items into your book or into the event album of your choice, exactly like an upload from your phone or computer. Like any photo in your book, an imported photo may be analyzed (description of the scene, and faces with your consent) and used to create the illustrations of that book, for you only, including, with your consent, to draw your loved ones with a good likeness (see “Face photos and facial recognition”); in an event album, it is visible to the participants according to the album settings. Retention: the chosen items are copied to our storage, with Amazon Web Services in the Paris region (France, European Union), and kept as long as the book exists (photos of a book draft that is never launched are automatically deleted after 90 days) or, in an event album, until the album is erased, at the latest at the end of its retention period. You can delete them at any time; the photos in your books are deleted at the latest 30 days after your account is deleted. The import record (names and identifiers of the chosen items) is erased after 7 days, and the selection made in Google Photos is deleted at Google once the import is complete. Sharing: this data is never sold, never used for advertising (no targeting, retargeting or profiling), and is only transferred to the processors needed to run the service, already listed in “Hosting, providers and transfers outside the European Union” and “Face photos and facial recognition” (Amazon Web Services for hosting and, with your consent, facial recognition; Google LLC for photo analysis and image creation; fal.ai, Inc. for some images), or when required by law. It is not used to train, develop or improve generalized artificial intelligence or machine learning models, neither by Eliacover nor by its providers. Human access: no one at Eliacover views this data, except with your explicit agreement (for example to answer your support request), when necessary for security (abuse, reports: see “Event albums: access by the Eliacover team”) or to comply with the law. Items imported from Google are viewed by the authorized people described in “Access by the Eliacover team to your creations” only in these cases, in read-only mode, with every viewing recorded in an audit log; they are used to prepare a creation for you only at your request. You can revoke Eliacover's access at any time from your Google account (https://myaccount.google.com/connections); items already imported remain in your book or album until you delete them. Eliacover's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements: https://developers.google.com/terms/api-services-user-data-policy
Imports from Dropbox and from your phone
Dropbox: you choose the files yourself in the Dropbox selection window; Eliacover only receives a direct download link to those files, downloads them and then processes them like an upload from your device; Eliacover has no access to the rest of your Dropbox account or to your credentials. Phone: by scanning the QR code (or typing the code) shown by the app, you can send photos from your phone to a book in progress without signing in; this link is only valid for that book, expires after 30 minutes of inactivity (2 hours at most) and is revoked as soon as you close the window on your computer. Files received are processed and kept like those sent from the website (see “Retention period”).
Event albums: access by the Eliacover team
Photos and videos in an event album (wedding, birthday, trip…) are visible to its organizers and, depending on their settings, to the guests; the Eliacover team does not access them in the normal course of business. Only specially authorized team members can open the full album of an event, solely to answer a support request (for example from the organizer) or to handle a report (moderation). Each opening requires a stated reason, is time-limited and is recorded in an audit log (who, when, which event, which reason), as is every action taken: hiding, blurring a face, rotating, downloading, deleting a photo or video, removing a person from face recognition. Photos are blurred by default. When a photo or video is deleted by the team, the organizer is informed by email. Legal basis: Eliacover's legitimate interest in supporting its users and keeping the service secure (Article 6.1.f GDPR), and compliance with its legal obligations to remove unlawful content (Article 6.1.c).
Access by the Eliacover team to your creations
The Eliacover team does not access your creations in the normal course of business. Only specially authorized people (currently, Eliacover's management) may view, in read-only mode, the creation conversation of a book (your messages, your answers and the requests made to Elia), as well as the photos and documents you sent for that book. They do so only to answer your support request, to handle a report or an incident, or to comply with the law. They may also, at your request or for support purposes, prepare a creation for you from these items (an encrypted creation package, never shared with any third party). Every viewing is recorded in an audit log (who, when, which book). No copying or bulk download is possible outside these encrypted packages. Files you have deleted are never visible. Legal basis: Eliacover's legitimate interest in assisting you and keeping the service secure (Article 6.1.f GDPR); you may object by writing to contact@eliacover.com.
Notifications and emails
If you allow them on your device, the app sends you notifications (book ready, audiobook ready, gift card received, printed book shipped or delivered…); for this, we keep the subscription address provided by your browser and your preferences, which you can change in your account. Notifications go through the notification service of your browser or operating system (Google, Apple, Mozilla…), which only receives an encrypted message. Service-related emails (sign-in, creation finished, payment, order and tracking of a printed book) are sent from the European Union (Amazon SES, Paris region). You can withdraw permission for notifications at any time, in your account or in your device settings.
Eliacover Photos Android app
The Eliacover Photos Android app is used only to send photos from your phone to an Eliacover book you are creating. It requires no account: you open it with the QR code or the code shown on the website, which is valid for that book only. Data sent: only the photos you choose in the app, as their original files, with the information they contain, including the GPS location where each photo was taken; the app asks for access to your photos' location in order to keep this information, which is used to sort your photos by place and to draw the map of your book. The app accesses no other data (no contacts, no current location of the phone, no camera: the QR code is read by the system scanner) and contains no advertising and no audience measurement. Uploading can continue in the background with the screen off; a notification then shows its progress, and notifications are used only to follow your uploads. On the phone, the app only keeps the last book opened (title, thumbnail, link) and the list of photos already sent (internal identifiers of the phone, so that they are not offered to you twice), which is forgotten after 60 days or when the app is uninstalled. Photos received are processed and retained in the same way as photos sent from the website (see “Retention period”) and are deleted together with the book or draft they belong to. You can withdraw access to your photos or to their location at any time in Android settings.
Personal data contact
For any question about the protection of your personal data or to exercise your rights, write to us at contact@eliacover.com (subject “Personal data”): requests are handled by the management of Elia Interactive within one month. Elia Interactive has not appointed a data protection officer. You may also file a complaint with the CNIL (French Data Protection Authority).