Privacy Policy

1. Who is responsible

Stefan Horn
Kinderbuch Horn · BedtimeWish
Gutenbergstraße 10
27570 Bremerhaven, Germany

Email: bedtimewish@gmx.net

Our business is located in Germany, so the EU General Data Protection Regulation (GDPR) applies to how we handle your data, wherever you live. We have not appointed a data protection officer; in our assessment, we are not required to.

2. The essentials at a glance

• No customer account, no sign-up, no newsletter.
• No advertising services, no social media plugins. Fonts and all images come from our own server.
• Analytics with Google Analytics only if you expressly consent (section 4a). Without consent, Google is not loaded and there is only one technically necessary session cookie.
• To create your story, we send the necessary details to two AI services: OpenAI (text and cover image) and ElevenLabs (voice recording).
• Payment is handled by PayPal; we never receive credit card or bank details.
• We delete personal details about the child after a few weeks (section 9).

3. Visiting the website

The website runs on a server we rent from Alfahosting GmbH, Edmund-von-Lippmann-Straße 13–15, 06112 Halle (Saale), Germany. Alfahosting processes the data on our behalf (Art. 28 GDPR).

When you open a page, the web server temporarily stores the IP address, date and time, requested address, status code, amount of data, referrer and browser identifier – to deliver the page, for security and for troubleshooting (Art. 6(1)(f) GDPR). These logs are deleted after 14 days. Visits to the order, payment and download pages are not logged.

To protect the server, a security service temporarily blocks IP addresses that repeatedly make failed login attempts on the server access (Art. 6(1)(f) GDPR).

4. Cookies

We set only one cookie (“session”). It stores your details from the order form while you fill it out, and the link to your order so you can see its status. It is signed, only transmitted encrypted (HTTPS), can’t be read by scripts and lasts no longer than 7 days. It is strictly necessary for the service you requested (Section 25(2) no. 2 TDDDG; Art. 6(1)(b) GDPR). You can delete it in your browser at any time.

We store your choice in the analytics notice only in your browser (local storage “bw_consent”, not a cookie, never sent to us) for 12 months, so we don’t ask you again on every page (Section 25(2) no. 2 TDDDG). Only if you agree to analytics are the Google Analytics cookies added (section 4a).

4a. Analytics with Google Analytics (only with your consent)

If you choose “Allow analytics” in the notice, we use Google Analytics 4, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). It shows us, in aggregate, how many people visit our website, how they find us (for example search engine, a link on another website, social networks or a direct visit) and which pages they use.

Only after your consent does your browser load Google’s script. The following is then processed: the addresses of the pages you visit – without order keys and download links and without address parameters, except campaign details (utm_…) –, page titles, the website you came from (for other websites only their address without the subpage), time, details about device, browser, screen size and language, a pseudonymous identifier in cookies, and steps in the order process without their content (for example “product viewed”, “story world chosen” or “payment started”, with our price and currency). After a successful payment, we also send the amount, currency, the chosen story world (only the category, never a world you described yourself) and a pseudonymous transaction number that we derive from the order with a secret key – it does not contain or reveal your order number, and Google cannot link it to you. We never send first names, ages or other details about the child (including favorite topics and your wish), messages, email addresses or payment data to Google.

Google determines your approximate country and region from your IP address; according to Google, IP addresses are not logged or stored in Google Analytics. The cookies “_ga” and “_ga_…” distinguish visitors and visits; we limit how long they are stored to no more than 13 months. Google signals, advertising features and personalized advertising are turned off; we don’t use any Google advertising services.

The legal basis is your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). Google processes the data on our behalf under Google’s data processing terms (Art. 28 GDPR). Data may be transferred to the US; Google LLC is certified under the EU-U.S. Data Privacy Framework, for which there is an adequacy decision of the European Commission (Art. 45 GDPR). In Google Analytics, the data is deleted after 14 months.

You can withdraw your consent at any time with effect for the future: under “Privacy settings” at the bottom of every page. After that, we no longer load Google Analytics and remove its cookies from your browser. Without consent, you can use the website without any restrictions. More about privacy at Google: https://policies.google.com/privacy

5. Your order

We process: the child’s first name and age, the pronouns for the story if you chose them, the chosen story world (or your description of your own world), any additional favorite topics of the child (chosen from a list), your choice of what you are wishing for the child right now (one of the offered directions or “nothing in particular”), any companion (type and name), whether the child has a pet and, if given, its kind and name, favorite things and special details, any personal message and who it is from; your email address; the country you live in (your answer in the order form) and the country PayPal reports for your payment; order number, timestamps, payment status and PayPal transaction numbers; the time and wording of your consent to the immediate start of creation.

We need your country of residence to check that we sell to your country and for our tax records. We don’t ask for a postal address. Legal basis: Art. 6(1)(b) and (c) GDPR (contract; record-keeping obligations under German tax law).

We don’t ask for the child’s last name, address or date of birth. Please don’t enter health information or other sensitive information, and only details you are allowed to share for this purpose.

Purpose: creating and delivering your BedtimeWish, order confirmation, notification when it is ready, questions, cancellation and warranty. Legal basis: Art. 6(1)(b) GDPR; for the details about the child as a third person, additionally Art. 6(1)(f) GDPR (legitimate interest in producing the personal content you ordered). We don’t use these details for advertising, for profiling or for training AI.

5a. Children’s privacy

Our website is meant for adults – parents, grandparents and other gift-givers. We don’t knowingly collect personal information directly from children under 13. Details about a child are provided only by the adult who places the order and are used only to create the story they ordered. If you believe a child has sent us information directly, please email us at bedtimewish@gmx.net and we will delete it.

6. Creation with AI services

Your BedtimeWish is created with the help of AI services and narrated with a digital voice. We only send what each step needs:

• OpenAI (OpenAI Ireland Limited, 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, and OpenAI, L.L.C., USA): for the story, first name, age, pronouns (if chosen), story world, additional favorite topics, your wish, companion, pet, favorite things and message; for the cover, the finished story text and the age. The image description for the illustration contains no names; we add the title to the image on our own server. We have turned off storage of our requests at OpenAI (“store: false”). OpenAI may nevertheless keep requests for up to 30 days to detect abuse. According to OpenAI, data sent via the API is not used for training. Processing in the US by OpenAI companies takes place, according to OpenAI, on the basis of EU Standard Contractual Clauses.
• ElevenLabs (Eleven Labs Poland sp. z o.o., ul. Lipska 27/22, 03-908 Warsaw, Poland; according to its own information, the US parent company is certified under the EU-U.S. Data Privacy Framework): the title and text of the story (which contains the first name and, if given, the companion, the pet and message), to create the recording. The recordings and the related text are stored in the history of our ElevenLabs account until we delete them there.

We use both services as processors (Art. 28 GDPR); transfers to third countries are based on EU Standard Contractual Clauses or the adequacy decision for the EU-U.S. Data Privacy Framework (Art. 45, 46 GDPR).

7. Payment with PayPal

Payment is handled by PayPal; our merchant account is with PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg. We send PayPal only the amount (7.99 USD), the description “Personal BedtimeWish bedtime story” and our random order number – no details about the child. You enter your payment details directly at PayPal. From PayPal we receive the payment status, amount, currency, transaction numbers and the country PayPal reports for your payment (only that country, no address). PayPal processes your data under its own responsibility: https://www.paypal.com/us/legalhub/paypal/privacy-full. Legal basis: Art. 6(1)(b) and (c) GDPR.

8. Emails

We send the order confirmation, the email with your download link and, if applicable, the acknowledgement of a cancellation to your email address – no advertising. Emails are sent through our mailbox at GMX (1&1 Mail & Media GmbH, Brauerstraße 48, 76135 Karlsruhe, Germany). Legal basis: Art. 6(1)(b) GDPR.

9. How long we keep data

These deletion periods apply to your data. Automatic deletion is currently being introduced; until it is active, we apply the periods by hand.

• Unpaid orders: all details 7 days after the last change.
• Details about the child, your wish, message, story, cover, recordings, MP3 and your email address: 30 days after the first download, no later than 60 days after completion. The download link is valid for 30 days from completion.
• Orders that could not be completed: 60 days after the last processing step.
• Cancelled orders: 30 days after the cancellation.
• Details from a cancellation (name, email, message): 3 years (proof, regular limitation period).
• Tax-relevant order data without details about the child and without the email address (order number, date, amount, payment and refund status, PayPal transaction numbers, country of residence as stated by you and by PayPal): 10 years as part of our records, accounting vouchers 8 years, each from the end of the calendar year of the order; longer only while they matter for a tax assessment that is not yet final (Section 147(3) and (4) German Fiscal Code).
• Proof of your consent to the immediate start (time and wording): 3 years from the end of the calendar year of the order (proof against claims under the contract, regular limitation period).
• Server logs: 14 days.
• Only with your consent: analytics data in Google Analytics 14 months, Google Analytics cookies no more than 13 months; your choice in the analytics notice 12 months in your browser.

10. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). Just email us at bedtimewish@gmx.net.

You can lodge a complaint with a data protection supervisory authority, for example the one responsible for us: Der Landesbeauftragte für Datenschutz und Informationsfreiheit der Freien Hansestadt Bremen, Arndtstraße 1, 27570 Bremerhaven, Germany, https://www.datenschutz.bremen.de.

11. Required details, no automated decisions

Without the first name, age, story world and email address, we can’t create a BedtimeWish; all other details are optional. There is no automated decision-making within the meaning of Art. 22 GDPR.

12. Security

The connection is encrypted throughout (HTTPS). Order pages can only be reached with a random key, download links only with a random, time-limited token; production files are not publicly accessible.