Privacy Policy
Effective date: 4 September 2026.
1. Who we are (controller)
Spark to a Flame Consulting LLP operating under the brand Caminario 1103–11871 Horseshoe Way Richmond, British Columbia V7A 5H5 Canada
Business Number: 709595169 · Registration Number: LL01528
Privacy Officer / contact: Marcel Szenessy — hello@caminario.com
Website: www.caminario.com
2. Scope
This policy describes how we process personal data when you use Caminario (website and app), including accounts, path content, sharing with loved ones, check-ins, and optional partner email reminders.
3. Data we process
Depending on how you use Caminario, we may process:
- Account data: name, email, password/auth identifiers, language, plan/billing status
- Path content: life/story/people/care/farewell entries and media you upload
- Sharing data: invitees’ contact details and visibility rules you set
- Check-in preferences: cadence, channels (browser notification and/or email)
- Partner reminders (optional): partner name and email only if you opt in
- Technical data: IP address, device/browser info, logs needed for security and operation
- Support: messages you send to us
- Newsletter (optional): email address, language, signup time, IP used for signup, confirmation/unsubscribe status; if Brevo open/click stats are enabled, those engagement metrics
- Guest / local use: path content stored only on your device until you create an account; we do not receive it and we do not auto-subscribe you to the newsletter
We do not ask you to store secrets (passwords, seed phrases, PINs, private keys, recovery codes). Do not enter them. Product design aims at orientation and locations, not a vault.
4. Purposes and legal bases (GDPR Art. 6)
| Purpose | Legal basis (where GDPR applies) |
|---|---|
| Provide the subscription / app (contract) | Art. 6(1)(b) |
| Billing via payment provider | Art. 6(1)(b) / (c) as applicable |
| Your own check-ins (cadence / channel) | Art. 6(1)(b) |
| Partner email reminders | Art. 6(1)(a) consent; you confirm you may provide the address |
| Browser/device notifications | Consent where required (e.g. § 25 TDDDG / ePrivacy) |
| Security, abuse prevention, logs | Art. 6(1)(f) legitimate interests |
| Legal obligations | Art. 6(1)(c) |
| Newsletter / marketing emails | Art. 6(1)(a) consent (double opt-in) |
You may withdraw consent for newsletter, partner emails, and notifications at any time (unsubscribe link, Settings, or email us). Withdrawal does not affect prior lawful processing.
5. Processors / recipients (list only real services)
As of the publish date of this policy:
- Website hosting: All-inkl
- App hosting: same infrastructure as the website for the current marketing/app surface, or as updated here when a separate app host is used
- Payments: Paddle (when checkout is live)
- Email / newsletter: Brevo (Brevo SAS, France); data stored in the EU; Art. 28 DPA as applicable. Used for newsletter double opt-in and confirmation mail.
- Partner / product transactional emails: not enabled. Naming Brevo unlocks the newsletter only. Partner check-in emails may use the same Brevo account only if that purpose is described under §13 and the feature is deliberately switched on — until then, partner product emails remain off.
We do not sell personal data. We share data only as needed to run Caminario, comply with law, or with your instructions (e.g. shared access, partner reminders once enabled).
Partners / loved ones receive only what you choose to share — not your full account.
6. International transfers
We are established in Canada. If data is processed in other countries (e.g. payment or email providers), we use appropriate safeguards where required (e.g. SCCs). Details on request.
7. Cookies and similar technologies
Essential cookies/storage may be required for login and security. We do not currently use web analytics cookies or analytics services. If that changes, we will update this policy and, where required, obtain consent.
8. Retention
- Account and path content: while your account is active, then deleted or anonymized within a reasonable period after deletion request or account closure (unless law requires longer)
- Logs: short retention for security
- Newsletter: while subscribed, plus as long as needed to prove consent and honor opt-out
- Partner email / consents: until you withdraw or delete the feature data (only if that feature is enabled)
- Billing records: as required by tax/commercial law
- Guest/local data: remains on your device until you clear it or sign up and choose to sync
9. Your rights
Where applicable (including GDPR), you may have rights to access, rectification, erasure, restriction, portability, and objection, and to lodge a complaint with a supervisory authority. Contact: hello@caminario.com.
10. Children
Caminario is intended for adults. Do not use the service if you are under the age of majority where you live (generally 18).
11. Newsletter
We send the Caminario newsletter only with your consent (Art. 6(1)(a)), via double opt-in.
Data processed for newsletter: email address; name if you provide it; signup time; IP address at signup; confirmation status; unsubscribe status. If Brevo open/click statistics are enabled for our account, Brevo may also record whether messages are opened and which links are clicked — we will keep that honest in this policy if/when enabled.
Unsubscribe: link in every newsletter email, or write to hello@caminario.com.
Retention: while you are subscribed, and thereafter as needed to prove consent and honor opt-out.
12. Guest access / local use
If you use Caminario as a guest (try without an account), path content stays only on your device until you create an account and choose to save/sync. We do not receive guest path content, and guest use does not subscribe you to the newsletter. Newsletter signup is a separate, explicit action with double opt-in.
13. Check-ins / Partner sharing
See also product Settings. Summary:
- We store your check-in cadence and channels to deliver reminders you asked for.
- Optional partner name/email only after opt-in; purpose is to send orientation you chose.
- You confirm you are authorized to provide the partner address.
- No secrets in check-ins.
- Partner can stop receiving messages via unsubscribe / your Settings; you can revoke anytime.
- Status: Partner product emails via Brevo are not enabled until we deliberately turn the feature on and update this section accordingly. Newsletter use of Brevo does not by itself enable partner emails.
14. Changes
We may update this policy. The “Effective date” will change; material changes may be announced in-app or by email.
15. Contact
hello@caminario.com · Spark to a Flame Consulting LLP · address above.