Data Processing Agreement

The subject matter of this Agreement is our processing, on your behalf, of the personal data relating to third parties that you enter into or generate in the Platform, within the features described below. Processing begins when the professional account is created and lasts for as long as the account exists. The Agreement ends when the account is deleted, except for those obligations which by their nature continue to apply — confidentiality and deletion of the data.

We process the data solely in order to provide you with the Platform features you use, namely:

• storing the data and displaying it in your portal: the event guest list, portion counts, menu choices, the seating plan and the day-of schedule;
• generating the event sheet, its printable version and, on your instruction, the access link described in a separate section below;
• managing your database of clients and prospects, including the notes and documents you attach to them;
• receiving and storing the inquiries visitors send through your public profile form;
• hosting the questionnaires you write and generating the links you send to couples; storing the answers and photos you receive, displaying them in your portal and, for viewing only, in the account of the couple who sent them; emailing you when answers arrive (details in the section “Questionnaires” below);
• sending the emails you yourself trigger from the Platform;
• backups, technical logs and maintenance strictly necessary to keep the service running and secure.

We do not process this data for our own purposes: we do not sell it, do not use it for advertising, do not use it to train automated systems, do not combine it with another account’s data, and do not make it available to other Platform users outside the sharing mechanisms you instruct.

• guest identification and contact data: names, the number of people in a party (adults and children), phone, email, preferred language;
• catering data: attendance status, each person’s menu choice, and the free-text field where a special requirement can be noted — this field may contain health information (allergies, intolerances, medical diets) or allow a religious belief to be inferred, and therefore special categories of data under Art. 9 GDPR. For the events you manage, the Art. 9(2) GDPR condition for this field is yours to hold, as controller; we ask whoever fills it in to confirm that the guest gave the information knowing where it goes, we keep that confirmation, we save nothing without it, and the contents of the field are deleted automatically 14 days after the event date;
• accommodation needs and the table each person is seated at;
• client and prospect data: name, phone, email, pipeline stage, your own notes, quoted amounts and the documents you upload (contracts, for example);
• the content of marketplace inquiries: name, contact details, event date and the sender’s message;
• the answers to your questionnaires, that is, whatever information the questions you write ask for (for example the day's schedule, songs, names and groupings for photos, the godparents' names, addresses, phone numbers, links), and the photos couples upload, up to 10 per question, which may show other people too. The content depends entirely on the questions: if a question asks for health information, religious beliefs or other special categories of data under Art. 9 GDPR, the answer will contain them.

We neither ask for nor need national identification numbers, detailed health records or guests’ payment details. We recommend that you do not enter them into the Platform, nor ask for them in questionnaires.

• guests of the events you manage, and the people listed in the guest list (including children, whose data is entered by their parents or by the organiser);
• your clients and prospects, together with the contact persons they designate;
• people who send you an inquiry through your public profile;
• the couples who fill in your questionnaires, and the people they mention in their answers or who appear in the photos they upload (for example godparents, parents, other family members, guests).

• You establish a legal basis for each processing operation and ensure the processing is lawful, fair and transparent.
• You inform the data subjects as required by Art. 13 and 14 GDPR. This point deserves emphasis: for the events you manage yourself, Loomia sends no notice to the guests — they receive no guest link and never land on a page of ours explaining the processing. Informing them is entirely down to you or to your client.
• You enter only data you are entitled to enter, and only as much as the purpose requires. Menu choices are recorded per person, by name, so that portions can be matched to seats at the table; in the free-text field for special requirements, note only what the kitchen needs to know.
• You are responsible for the questions in your questionnaires and ask through them only for the information needed for the service you provide to the couple. If a question concerns special categories of data under Art. 9 GDPR, you must have one of the conditions set out in Art. 9(2) GDPR (details in the section “Questionnaires”).
• You keep the data accurate, and update or delete it when it is no longer needed.
• You are responsible for the instructions you give us and for their lawfulness.
• You keep a valid contact address on your account, so that we can notify you of a security incident or a change of sub-processor.

We process the data only on your documented instructions. Those instructions are: (i) your use of the Platform features — every operation you perform in the portal is a documented instruction; (ii) this Agreement together with the Terms and Conditions; (iii) any further written instruction sent to contact@loomia.ro and accepted by us. An instruction that goes beyond the Platform’s existing features may be declined, or made conditional on the reasonable costs being covered.

We will inform you if, in our opinion, an instruction infringes the GDPR or Romanian data protection law, and we may suspend it until the matter is clarified. We may also process the data where European Union or Romanian law requires us to; in that case we will inform you beforehand, unless that law prohibits such information on important grounds of public interest.

Access to the data processed on your behalf is limited to the people who need it in order to provide, maintain and secure the service. Those people are bound by contractual or statutory confidentiality obligations that survive the end of their engagement with us. Loomia is run by a small team. Administrative access to the database is limited to the Operator’s technical staff and is used exclusively for maintenance, fixing faults and handling your support requests.

We apply technical and organisational measures appropriate to the risk, in accordance with Art. 32 GDPR:

• encrypted connections (HTTPS) for all traffic, public pages included;
• account passwords stored only as cryptographic hashes, never in the clear;
• encrypted, revocable sessions — a password change signs out sessions open on other devices;
• access rights checked on the server for every operation, not only in the interface, and strict separation of data between accounts at the level of each query;
• links, connect codes and tokens generated cryptographically at random, making them effectively unguessable;
• a questionnaire link is bound to the first couple account that starts filling it in and cannot be used from any other account;
• rate limiting on login attempts and on submissions from public forms;
• the documents you upload for clients, and the photos couples upload in questionnaires, are accessible only after checking the access right of whoever requests them (you, as account holder, or the couple who uploaded them), never through a public address or a temporary link to the storage bucket;
• uploaded files are kept in European-Union-jurisdiction storage, and the production database is hosted in the European Union (Amsterdam);
• database backups kept separately from the main infrastructure, with a tested restore procedure;
• error monitoring configured so that tokens are stripped from personal links before anything is sent, and form contents and guest data are not transmitted at all.

These measures are described at the level of detail that can be published without weakening the very security they protect. We may update them at any time, provided the level of protection does not decrease.

You give us general authorisation to use sub-processors for the service infrastructure. As at the date of this version, they are:

• Railway Corporation (USA) — application and production database hosting, in the EU-West region (Amsterdam, the Netherlands);
• Cloudflare, Inc. (USA) — storage of uploaded files (photos, documents) in European-Union-jurisdiction storage, and the domain’s DNS service;
• Resend, Inc. (USA) — sending account emails and the emails you trigger from the Platform, including the notice that a questionnaire has been answered;
• Functional Software, Inc. (Sentry) (USA) — monitoring of technical errors, hosted in the European Union (Germany);
• PostHog, Inc. (USA) — usage statistics and session replay in the portal, hosted in the European Union (Frankfurt), active only with the consent given through the cookie banner; all on-page text is masked automatically in recordings, and guest pages are never tracked or recorded.

We impose on every sub-processor, by contract, data protection obligations at least equivalent to those in this Agreement, and we remain fully liable to you for their processing. The payment processor that handles your subscription is not in the list above because it receives none of your event or client data: for payment data it acts in its own right, as an independent controller, under its own privacy policy.

Any addition or replacement of a sub-processor is announced on this page, by updating the list and the version date, and — for active accounts — by email. You may object in writing at contact@loomia.ro within 14 days of the announcement, on reasonable data protection grounds. If we cannot offer an alternative, you may terminate for the affected part by deleting your account, under the conditions set out in the Terms.

Data subject requests — access, rectification, erasure, restriction, portability, objection — are addressed to you, as the controller. The Platform is built so that you can handle them yourself and immediately: you can view, correct and delete any guest party and any person within it, any client in your database, any inquiry received and any questionnaire link, together with its answers and photos; you can unlock answers so that the couple can correct them, and the guest list can be exported.

If a request reaches us directly and concerns data processed on your behalf, we will not answer it in your place: we forward it to you without undue delay. Where a request cannot be resolved from the interface, we provide reasonable technical assistance, in time for you to meet the statutory deadlines — as a rule one month from your receipt of the request. This assistance is free for ordinary requests; for repetitive or manifestly disproportionate requests we may ask for reasonable costs to be covered, notified to you in advance.

We will inform you without undue delay after becoming aware of a breach affecting the data processed on your behalf, by email to your account address. The notification will include, to the extent known to us at the time: the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken, and our point of contact; any missing information follows as it becomes available.

Notifying the Romanian supervisory authority (ANSPDCP) within 72 hours and, where applicable, informing the data subjects are your responsibility as controller. We do not do so on your behalf, but we give you the information you need in order to do it in time.

We also provide reasonable assistance with your obligations under Art. 32-36 GDPR, including a data protection impact assessment and prior consultation with the authority, taking into account the nature of the processing and the information available to us.

When the services end, deletion is the default. Deleting your account from the account page permanently deletes the events you manage, the guests you entered, your client database, the documents you uploaded, the inquiries received through your profile, and your questionnaires with every answer and photo received. Export whatever you need before deleting the account: once deleted, the data cannot be recovered. Data may remain for a limited period in backups, until those are overwritten in the normal rotation cycle; throughout that period it stays protected by the same security measures and is not used for any other purpose. After termination we keep only what European Union or Romanian law requires us to keep, in particular the accounting records relating to your subscription.

At your written request, sent to contact@loomia.ro, we make available the information needed to demonstrate compliance with Art. 28 GDPR: a description of the security measures, the list of sub-processors, the processing locations and the basis for international transfers.

You may request an audit at most once a year, and in addition whenever a supervisory authority requires it or following a breach that affected your data. An audit is announced with reasonable notice of at least 30 days, takes place during business hours and without disrupting the service, and always starts as a documentary, remote review; a further check is arranged only if the answers received remain insufficient.

The appointed auditor may not be a competitor of ours and signs a confidentiality undertaking. No audit may include access to the data of other Platform customers, or to components whose exposure would weaken the security of all accounts. The costs of the audit are borne by you, unless the audit finds a significant non-compliance attributable to us.

The data is stored in the European Union: the production database in Amsterdam, uploaded files in European-Union-jurisdiction storage, error monitoring in Germany, analytics in Frankfurt. Some of the sub-processors listed above are United States companies and may access the data for administration and technical support. Those transfers rely on the EU-US adequacy decision (EU-US Data Privacy Framework) for certified providers and/or on the standard contractual clauses approved by the European Commission, together with supplementary measures where needed. We authorise no transfer outside those mechanisms without informing you beforehand.

The event sheet can be shared through a unique access link, with no account and no password, generated on your instruction — or on the couple’s instruction, for weddings you are connected to. The link contains guest data, including per-person menu choices and the seating arrangement.

The address is generated cryptographically at random and is excluded from search engine indexing, but a secret address is not an access control: anyone who receives the link can open the sheet. Treat it as a confidential document — pass it only to the people who need it to run the event, do not publish it and do not display it where third parties can see it. The link can be replaced at any time from the app, and the old address stops working immediately. The decision to share the sheet this way is yours, as the controller.

If, as a wedding planner, you buy couple Premium tied to a wedding you run on your own (see the section “Premium bought by a wedding planner for their clients” in the Terms), choosing the wedding at purchase, together with sending the link, is your documented instruction to hand that wedding over to the Couple account that first uses the link. On the takeover the couple become the holders of the wedding and receive all of its data — the guest list, with the menu choices and the notes for the kitchen, the seating, the schedule, the vendors and the whole budget — except the tasks you have not made visible to the couple, your documents, your notes and your client database, which stay in your account. From that moment we no longer process the wedding’s data on your behalf: Trailbits SRL becomes its controller, under the Privacy Policy, and this Agreement no longer applies to that data. You stay connected to the wedding as a planner and see what the couple choose to share.

Until the takeover the data is yours, as controller: the legal basis for disclosing it to the couple — including the notes falling within the special categories of Art. 9 GDPR — is yours to establish, as is informing the guests about the period before. Whoever first uses the link takes over the wedding, so send it only to the couple whose wedding you organised. The instruction can be withdrawn at any time before the link is used: giving the link to another couple from the portal undoes its tie to the wedding, and deleting the wedding has the same effect.

You can write your own questionnaires in the Platform and generate a link for each couple, which you send them yourself. The couple answer from their own Loomia account, and the link is taken by the first couple account that opens it and presses “Start”. Answers save as they are typed, but you see them only once the couple have sent them for the first time. Once sent, they can be changed only if you unlock them; while they are unlocked, you see changes as they are made. When the couple send their answers, we tell you by an email containing the questionnaire’s title, the link’s label and the address where you can read them, but not the answers themselves.

We process the answers, and the photos the couple upload, on your behalf under this Agreement. We display them in your portal and, for viewing only, in the account of the couple who sent them. The photos are kept in private storage and have no public address: we show them only after checking that the request comes from you or from the couple who uploaded them.

Alongside the answers you see the couple’s names and the wedding venue (its name and address), taken from the wedding the couple keep in Loomia. The venue appears only if the couple choose to show it on their invitation. We pass these to you as controller, at the couple’s request, and the couple are told so before they start the questionnaire. They are not copied into the answers: we read them from the couple’s wedding each time they are displayed, so they change or disappear with it. You receive them as an independent controller, solely to know whose answers they are and to deliver your own services. This Agreement does not apply to them.

You alone decide what a questionnaire asks. The Platform has no field dedicated to the special categories of data under Art. 9 GDPR and does not ask you to collect any. The questions the Platform suggests are only suggestions: once added, they are your questions. If you nevertheless write a question that asks for such data or is likely to lead the couple to disclose it (for example about allergies or dietary requirements, someone’s state of health, religious beliefs or sensitive family situations), the need for that question, the Art. 9(2) GDPR condition and informing the couple of its purpose are entirely yours, as controller. Unlike the special-requirements field on the guest list, no consent tick is asked for on questionnaire answers, and they are not deleted automatically after the event. Couples may also write about other people in their answers (godparents, parents, guests) or upload photos in which others appear; informing those people, where the law requires it, is likewise yours. Before they start, the Platform tells the couple who receives their answers and what accompanies them, and the Privacy Policy explains what the Platform does with their data. Neither replaces the information about the purposes for which you yourself use the answers, which is yours to give.

Answers and photos stay in your account until you delete the link, the questionnaire or the account. The photo files are then deleted from storage too, subject to the backups described above. Deleting them once they are no longer needed for the purpose you asked for them is your decision and your obligation. If the couple delete their Loomia account, the answers stay with you, because they were sent to you: only the link to their account is removed, and the label you gave the link appears in place of their names. A request from the couple to delete them is addressed to you, as controller, and you can resolve it by deleting the link.

You can send a couple a contract made from your template; you and the couple fill in its blanks in the contract, each from your own account. We process on your behalf, under this Agreement, the values typed in by you and by the couple, which we store encrypted and show only to the two parties, in the contract and in the documents they download, generated on request and not kept. When you or the couple upload the signed copy, the Platform deletes the values typed in; it also deletes them if you cancel the contract or if the couple delete their account before then. The signed copy stays in your storage, accessible only to you and to the couple on the contract, until you delete it or your account: keeping it is your decision, and Loomia is not its archive of record, so download it. The contract's text is yours, Loomia is not a party to it, and signing happens outside the Platform.

Liability under this Agreement follows the limits agreed in the Terms and Conditions. Nothing in this Agreement limits the liability that Art. 82 GDPR establishes directly towards data subjects, or any liability that cannot be limited under the law. In the event of a conflict between this Agreement and the Terms, this Agreement prevails as regards the processing of personal data.

The Agreement is concluded by creating the professional account: by creating it, you accept the Agreement on behalf of the business you represent and confirm that you are authorised to bind it. Electronic form is sufficient, in accordance with Art. 28(9) GDPR. We record the accepted version on your account (current version: 2026-10-15), so that it can always be established which text applied to you.

We may update the Agreement, for example when new features are introduced, when a sub-processor changes, or following legislative changes. The current version, with its last-updated date, is permanently published on this page, and significant changes are announced to you by email or in the Platform a reasonable time in advance. If you do not accept a new version, you may terminate by deleting your account.

For any question about this Agreement: Trailbits SRL, email contact@loomia.ro — we normally reply within two working days.