Privacy Policy

Last updated: 26 September 2026

1. Data Controller

CallSanta.Online is operated by:

Ringsdale BV
Van Hallstraat 623
1051HE Amsterdam
The Netherlands
Email: [email protected]
Telephone: +31 6 41 36 23 13

Ringsdale BV is the controller of your personal data for all processing described in this policy.

2. Who the App Is For and How It Is Used

Family Oriented: CallSanta.Online is intended for families.

Parental Supervision: Children may only use the service under the supervision of a parent or legal guardian (18+).

Consent: We do not knowingly collect personal information from children without verifiable parental consent.

3. What Data We Process and Why

3.3.1 Account and Login

When you create an account, we process:
- Email address
- Login credentials (password or login token/magic link)
- Timestamp of account registration
- Account status (active/blocked)
- Optional: Name of parent or guardian

Purpose: To create and maintain your account, link call minutes, and manage settings.

We do NOT store: Plain-text passwords, sensitive personal data, or child data (except optional info in the child profile).

You can log in without a password: with a six-digit code we email you (we store only a hashed version of the code, for 10 minutes, plus the number of attempts), or with your Google account. When you use Google, we receive your email address, your name and a Google account identifier from Google, and we store the email address and the identifier so we can recognise you next time. We do not get access to your Google contacts, files or calendar. You stay logged in on your device for 90 days unless you log out.

3.3.2 Payments via Mollie

We use Mollie as our payment service provider.

We process: Purchase amount, type of bundle, transaction status, order number, and the link to your account.

Mollie processes independently: Payment method, name, payment details, and fraud prevention.

Note: We do not receive or store your bank or credit card details.

3.3.3 Real-Time Conversation

During a live conversation we process the following data. Nothing from the conversation is stored by us.

A. Voice. Your child's voice is streamed in real time through LiveKit (our video-call infrastructure) to our AI provider OpenAI, which understands the speech and generates Santa's spoken answers. We have opted out of model training: your audio and text are not used to improve OpenAI's models. OpenAI may keep encrypted audio and transcripts for up to 30 days solely for abuse monitoring, then deletes them. Santa's own voice is sent to Lemon Slice, which animates the face; Lemon Slice never receives your child's voice or image.

B. Child profile and your note. The first name, age, gender and interests you entered, and the note you wrote for the call, are sent to LiveKit as session data (deleted when the session ends) and to OpenAI as part of Santa's instructions, so that the conversation is personal. They are kept in your own browser for your next call. We do not write them to our database or to our logs.

C. Camera (optional, off by default). If you switch the camera on for a call and confirm the consent text, your browser sends a photo (about 640 by 480 pixels) every 20 seconds to our server, which passes it to OpenAI so that Santa can react to what he sees. Photos live only in memory during the call and are never stored by us. You see exactly what Santa sees and can switch the camera off at any moment; the consent version you agreed to is recorded with the call.

D. Session data. A random session identifier, the number of minutes used, timestamps and technical connection data. Free-text ratings you give after a call.

3.3.4 Child Profile Information (Optional)

Parents may voluntarily enter:
- Child's first name
- Age
- Hobbies / Gift wishes

Purpose: This information is used only to personalize the conversation. It is optional and can be deleted by the parent at any time.

3.3.5 Analytics (Optional)

Collected only with consent for up to 6 months. Includes session duration and page interactions. We do not use advertising cookies, tracking cookies, device IDs, or fingerprinting.

3.3.6 What We Do NOT Collect

3.3.7 Friends Programme

If you share your personal link, we store a random code for your account and, for each person who signs up through it, the link between the two accounts, the date, and whether that person has called or bought minutes. We do not store the friend's data before they create an account themselves, and we do not send invitations on your behalf. The person you invited does not see your name or email address; you do not see theirs. This data is kept as long as both accounts exist and is used only to grant the free minutes (performance of the agreement, Art. 6(1)(b) GDPR).

4. Legal Bases & Parental Consent

4.4.1 Contractual Necessity

To provide the service, including account management and call minutes.

4.4.2 Consent

Required for analytics and optional child profile information. Consent may be withdrawn at any time.

4.4.3 Legal Obligation

We store payment/invoice data as required by tax laws.

4.4.4 Legitimate Interest

To maintain platform security and prevent fraud.

4.4.5 Verifiable Parental Consent (VPC)

To ensure a responsible adult is authorizing the use of this Service, we verify your identity through a monetary transaction (the purchase of call minutes).

We accept only payment methods that provide a transaction notification to the account holder (e.g., Credit Card, Bank Transfer).

This purchase serves as Verifiable Parental Consent for us to collect and process the optional child profile data you subsequently provide.

5. Sharing of Data

We share data only with the following providers. Each receives the minimum it needs.

6. International Transfers

OpenAI, LiveKit, Lemon Slice, Twilio SendGrid, Sentry and Google process data in the United States. We rely on the EU-US Data Privacy Framework where the provider is certified and on the European Commission's Standard Contractual Clauses otherwise, with encryption in transit and data minimisation. DigitalOcean hosts our data in the European Union.

7. Security Measures

All traffic is encrypted in transit (HTTPS/TLS; SRTP for audio and video). Because Santa is an AI, the conversation is by design processed by our agent and by OpenAI; it is not end-to-end encrypted between you and Santa. Our database is hosted by DigitalOcean with encryption at rest. Passwords are stored as salted hashes. Access is limited to the people who need it, and our logs contain no names, notes or conversation text.

8. Retention Periods

Account data: until you delete your account.

Child profile (name, age, interests, note): only in your browser; not stored by us.

Live audio and camera photos: not stored by us; OpenAI keeps audio and transcripts up to 30 days for abuse monitoring.

Call records (session id, minutes, timestamps): 24 months, then anonymised.

Ratings and comments: 12 months.

Payment and invoice data: 7 years (tax law).

Visitor statistics: 2 months.

Inactive accounts: after 24 months without a login we delete the account and its data, after a warning e-mail.

9. Your Rights

You may request access, rectification, deletion, restriction, objection, or portability of your data. You may withdraw consent at any time.

Contact: Make requests via your account settings or email [email protected]. We may request additional information to confirm the correct account.

10. Cookies

Strictly necessary (no consent needed): a session cookie for your login, a "remember me" cookie (7 days), a security token against form abuse, and a small cookie with your detected currency. Your call settings (child profile, note, camera choice) are kept in your browser's local storage, not in a cookie.

Statistics (only with your consent): Google Analytics cookies, set only after you accept them in the cookie banner. Advertising features are switched off. You can withdraw your choice at any time via the "Cookies" link in the footer.

No advertising or tracking cookies.

11. Children's Privacy Notice

No Collection Without Consent: CallSanta.Online does not knowingly collect personal information from children under 13 without verifiable parental consent.

Parental Control: All child-related data is entered voluntarily by the parent after the verification step (payment).

Review & Delete: Parents may review the personal information collected about their child, request its deletion, and refuse further collection by contacting [email protected].

No Ads: We do not use children's data for marketing, profiling, or advertising.

12. US State Privacy Rights

Residents of certain US states (CPRA, CPA, CTDPA, UCPA, VCDPA) have rights to know, access, correct, and delete their data. CallSanta.Online does not sell or share personal data for advertising.

Contact: [email protected] to exercise any of the above rights.

13. Changes to This Policy

We may update this policy. The date above reflects the latest version. Significant changes will be notified via email or account notification.

Questions about this Privacy Policy?
Contact: [email protected]

Ringsdale BV
Van Hallstraat 623
1051HE Amsterdam
The Netherlands
[email protected]
+31 6 41 36 23 13