Legal
Imprint, privacy policy and terms of use · Last updated: July 2026
Imprint
Information pursuant to § 5 DDG
Privately operated, non-commercial service:
Thomas Hanke
Düsseldorfer Landstr. 145a
47249 Duisburg, Germany
Contact
Email: hello@draw.gift
Responsible for content per § 18 (2) MStV
Thomas Hanke, address as above
EU dispute resolution
The EU Commission provides a platform for online dispute resolution: ec.europa.eu/consumers/odr. I am neither obliged nor willing to participate in dispute resolution proceedings before a consumer arbitration board.
Privacy Policy
1. Controller
The controller for data processing on this website is:
Thomas Hanke, Düsseldorfer Landstr. 145a, 47249 Duisburg, Germany
Email: hello@draw.gift
2. What data I process
To run the Secret Santa draw I process the data you provide: name, email address, group name, registration deadline and optionally budget, allowed email domains and your voluntary gift tips.
3. Purpose and legal basis
Processing is carried out exclusively to create Secret Santa groups, to automatically match participants and to send the associated emails. The legal basis is the performance of the user agreement (Art. 6(1)(b) GDPR) and your consent (Art. 6(1)(a) GDPR).
4. Analytics with Matomo
I measure how this website is used with Matomo, a self-hosted open-source analytics tool. Collection is server-side and cookieless — no information is stored on or read from your device. Your IP address is shortened, and the data stays with me (never shared with third parties).
This anonymous analytics runs without consent on the basis of my legitimate interest in a needs-based design of the service (Art. 6(1)(f) GDPR); § 25 TDDDG does not apply as nothing is stored on or read from your device.
Only with your consent is an additional anonymous ID stored in your browser so you can be recognised across visits (unique and returning visitors). The legal basis for this is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG); you can withdraw it at any time via “Analytics settings” in the footer.
5. Storage period & deletion
All data of a group is deleted automatically and completely 7 days after the registration deadline. No storage beyond this takes place.
6. Recipients & hosting
The website and all associated services run on servers of Hetzner Online GmbH, Industriestr. 25, 91710 Gundelfingen (data-centre location: Germany/Finland). A data-processing agreement pursuant to Art. 28 GDPR exists with Hetzner. Emails are sent via a mail server operated by myself on the same infrastructure; no external email provider is used. Your data is not shared with third parties for advertising purposes.
7. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability and objection. You can withdraw consent at any time with effect for the future. You also have the right to lodge a complaint with a supervisory authority. Please send requests to hello@draw.gift.
Terms of Use
1. Scope
These terms of use apply to the use of the draw.gift service, operated by Thomas Hanke (“I”). By creating a group or joining one, you accept these terms.
2. Description of service
draw.gift lets you create Secret Santa groups, invite participants and automatically match them after the registration deadline. The service is provided free of charge.
3. User obligations
You warrant that you provide truthful information and only use email addresses you are authorised to use. Misuse — in particular entering other people without their consent — is prohibited.
4. Availability & warranty
I strive for high availability but do not guarantee uninterrupted use. A valid email address for each participant is required for the draw to work correctly.
5. Liability
I am liable without limitation for intent and gross negligence and under the Product Liability Act. For slightly negligent breach of material contractual obligations, liability is limited to the foreseeable damage typical for the contract.
6. Changes & final provisions
I reserve the right to amend these terms with effect for the future. The law of the Federal Republic of Germany applies. Should any provision be invalid, the validity of the remaining provisions remains unaffected.