Privacy statement

1. Who is responsible

Mifolo is the data controller for the data you share with us through this site.

Questions about your data or your privacy? Email us at hi@mifolo.com. Our postal address is Mifolo, Gentiaanstraat 23, 9731 BN Groningen, the Netherlands.

2. Which data we use

We only process what is needed to create and deliver your book:

• the photos you upload to create characters;
• the details you enter about the characters (name, age, physical features, relationship to the child);
• your email address, to send you the cover and the book and to handle your order;
• order and payment data (the payment itself goes through our payment provider; we do not see any account details);
• only if you say yes in the cookie notice: data about your visit and your purchase, to measure how the site is used and to measure our ads (see the cookie statement);
• if you comment on one of our posts on Facebook or Instagram: your comment and your name or username (see section 10);
• if you add an audiobook: the names and profile photos of the readers, their voice recordings and the text of your book that we have read aloud (see sections 11 to 13);
• if you contact our customer service: your messages, your email address or phone number and your name on WhatsApp (see section 14);
• limited technical data needed to keep the site working securely.

3. What for and on what basis

We use the photos and character data solely to create your story and illustrations, and to check that a photo is suitable for that. We do this on the basis of your explicit consent, which you give when uploading (Article 6(1)(a) GDPR). You can withdraw that consent at any time. Then we delete the photos straight away.

Before we store a photo, it goes through an automatic check by our AI partners: can the photo be used for a drawing, and is it free of nudity, sexual content and violence? A photo that does not pass the check is not stored and not used. Of the check we keep only the outcome, never the image. Our AI partners may still keep it for up to 30 days to detect abuse, even if it does not pass the check (see section 4). We carry out this check to protect children and our service (legitimate interest, Article 6(1)(f) GDPR).

If we see signs of sexual abuse of children, we may report this to the police and pass on the information they need for it, such as your email address, your account and the time. We do this to protect children and because the law may require it of us (Article 6(1)(c) and (f) GDPR). We do not pass on a photo: we do not keep it. An ordinary photo we cannot use, such as a photo in the bath, does not fall under this.

We process your email address and order data to perform the agreement: emailing the cover, handling the payment, delivering the book. We keep invoice data because tax law requires us to.

We only use statistics and ad measurement with your consent, which you give in the cookie notice (Article 6(1)(a) GDPR and the cookie rules in the law). With that consent we pass on to Meta Platforms Ireland which pages you view, whether you request a cover or buy a book, your IP address, your browser details and, as a hash, your email address, your account number with us and your country. We and Meta are jointly responsible for that collection and transfer. What Meta does with it afterwards falls under Meta's privacy policy. We never share anything about your photos, your child or the content of your book with Meta. You can withdraw your consent in the cookie preferences.

We also remember your choice for ad measurement with your account, when we know it is you: you are logged in, or you request a cover or check out. If you are logged in on another device where you have not answered the cookie notice yet, your account's choice applies there. If you said yes, we only report your cover request, your checkout and your purchase to Meta there, from our server and without cookies on that device. If you say yes or no on a device yourself, that choice applies there and also becomes your account's choice. We no longer use a choice made more than 12 months ago for another device.

With your consent to analytics, Google sees which pages you view and whether you request a cover, add something to your cart or go to checkout. If you buy something, we report that purchase to Google, with the amount, the type of product and the identifiers from the Google Analytics cookies, so Google can link it to your visit. Google processes this data on our behalf. Your name, your email address and anything about your child or your book do not go to Google.

4. How long we keep data

• Original photos: deleted as soon as your book is ready, within 14 days at the latest. Want them gone sooner? One email is enough.
• A photo that does not pass the check: we do not store it. Of the check we keep only the outcome, no image.
• At our AI partners in the United States: what we send them, such as your photos and the text with names, may stay in their logs for up to 30 days to detect abuse, including a photo that does not pass the check. After that they delete it. Only if their check flags something as possible abuse may they keep it longer. They may not sell it, use it for their own purposes or train AI on it (see section 5).
• If we have reported something to the police (see section 3), we keep a record of that report, without any photo, for as long as necessary and at most 12 months, unless the police ask for longer.
• If you buy a book, we do not keep your photos, only the drawn character reference (an illustration, not a photo), for as long as you can still edit the book.
• Your book itself remains available in your account, so you can always view and download it again.
• Invoice data: 7 years (statutory tax retention obligation).
• Your email address: for as long as you have an account with us.
• If you request a cover, go to checkout or buy something after saying yes to marketing, we keep your IP address and browser details until we have reported it to Meta. Usually that happens straight away; if it fails, we keep trying for up to 7 days. For a purchase we wait until your payment has come in; if you do not complete the payment, we delete them after 14 days. We keep your choice for ad measurement with your account until you make a new choice or delete your account. If you buy something after saying yes to analytics, we keep the identifiers from the Google Analytics cookies with your order until we have reported the purchase to Google. If you do not pay, we delete them after 14 days.
• Comments on our posts on Facebook and Instagram: we delete your name and the text of your comment after 90 days (see section 10).
• Voice recordings and profile photos of readers in an audiobook: for as long as the audiobook exists. They are removed when the reader deletes their own recording, when you remove the reader or the photo, or when you have your account deleted (see section 11).
• Conversations with customer service: 12 months after the last message, after which we delete them. If you have your account deleted, we delete your conversations too. The figures without text or details about you (see section 14) are kept for 3 years.

5. Never sold, never for AI training

We never sell your photos, texts or your book, and we do not use them to train AI models.

Our AI partners, too, may only use your photos and texts to do their work for us and to detect abuse. They may not sell them, use them to train AI or use them for their own purposes. That is what their terms say; where it is a setting, we have switched it off. Only if the law requires it may they pass something on, such as a report of child abuse to the authorities.

6. Who else has access (processors)

We do not create your book entirely on our own. These parties receive data from us, only for the purpose stated with them. Most process it on our behalf; where a party is responsible itself, we say so:

With partners outside the European Economic Area, appropriate safeguards have been agreed, such as the EU-US Data Privacy Framework or the European standard contractual clauses.

• AI partners for the story text, the illustrations, the check on photos and texts, and the answers and translations of our customer service, based in the United States (how long they keep anything and what they may not do with it, you can read in sections 4 and 5);
• our partners for hosting, storage, the database and notifications to our own team;
• our payment provider (Mollie, the Netherlands) for handling payments. Mollie is responsible itself for your payment details, under Mollie's privacy notice;
• only if you pay for the hardcover with Klarna (pay later): Klarna Bank AB (Sweden). Through Mollie, Klarna then receives your name, email address, address and the order lines, to assess whether you can pay later and to handle the payment. Klarna is responsible for this itself, under Klarna's privacy notice;
• only if you order a hardcover: our printer. It receives your name, address, email address and, if you enter it, your phone number, plus the book with the names and illustrations, to print and ship it. The carrier receives your name, address, email address and phone number from this to deliver the parcel, and is responsible for that itself;
• only with your consent: Google (statistics) and Meta Platforms Ireland (ads on Facebook and Instagram; Meta is jointly responsible with us for the collection);
• our email provider in the United States, to send you messages about your book and to receive your emails to us; it keeps the emails for 30 days;
• only if you add an audiobook with the standard voice: an AI partner that reads the text of your book aloud, based in the United States (see section 12);
• only if you message us on WhatsApp: Meta Platforms Ireland, which processes and delivers the messages for us (see section 14);
• a security partner that checks you are not a robot in the chat and when you sign in. It receives your IP address and details about your browser for this, and also uses them to improve its own bot detection; it is responsible for that itself.

7. Children

Mifolo is for adults who create a book for a child. We process children's data solely because you, as a parent or carer, enter it yourself, with your consent. Children cannot create an account or place an order with us themselves. A child can, however, be a reader for an audiobook. If they are under 16, a parent or guardian of that child gives consent for it (see section 11).

8. Your rights

You may always see which data we hold about you, have it corrected or have it deleted. You can also withdraw your consent, object to a processing operation or take your data with you. Email us and we will arrange it.

Do you feel we are not handling your data properly? We would prefer to hear it from you first. In addition, you always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

9. Security

All traffic with our site is encrypted. Photos are stored securely, are accessible only to the systems that create your book, and never appear in log files. Access to personal data is limited to those who really need it.

10. Comments on Facebook and Instagram

If you comment on a Mifolo post on Facebook or Instagram, we see your comment, your name or username and when you commented. Meta passes these details on to us so that we can reply to you and hide or delete inappropriate comments. We do this on the basis of our legitimate interest in answering questions about Mifolo and keeping our pages safe (Article 6(1)(f) GDPR).

We keep your comment in our own management environment, which only our team can see. After 90 days we delete your name and the text of your comment, and the text of our reply to it as well. After that we only keep track of how many comments a post received.

To reply faster, our team sometimes asks an AI partner for a suggestion. We then send only the text of your comment, never your name, and a member of our team reads the reply and sends it themselves.

What happens to your data at Facebook and Instagram themselves is covered by Meta's privacy policy.

11. The audiobook: readers and their voice

You can add an audiobook to your book. In it, people you invite read the book aloud, such as grandpa, grandma or you. Each reader gets their own link from you. On that page, the reader records the book with the microphone of a phone or computer.

Before the recording starts, the reader reads what happens to their voice and gives their own consent (Article 6(1)(a) GDPR). If the reader is under 16, a parent or guardian of the reader gives that consent. That is why the recording page first asks whether the reader is 16 or older. If not, a parent or guardian looks on and ticks a box to give consent. We record who gave the consent. The reader can withdraw consent at any time by deleting the recording; from age 12 they can do so without a parent. A deleted recording is gone, even if you would have liked to keep it. A reader does not leave an email address with us: you pass on the link yourself.

We use a recording only for the audiobook of this one book. We split it into pages, even out the volume and remove silences. This happens on our own systems. We do not use the recording to recognise anyone: no voice profile and no voice recognition. A reader's voice never goes to an AI partner, we never turn it into an imitated voice and we never use it to train AI.

Who can hear the voice? Anyone who has the link or the QR code of this book, and the reader through their own link. The reader is told this before recording, too. So only share them with people you trust.

We keep a recording for as long as the audiobook exists. The reader can delete their own recording at any time through their own link. You can remove a reader, recording and all, in your account. If you have your account deleted, we also delete all recordings in your audiobooks. If a reader no longer has the link, they can email us at hi@mifolo.com.

Profile photos: you can add a photo for each reader, so your child can see who is reading. Only upload a photo of someone who is happy with that; for a child, a parent of that child. A profile photo goes through the same check as every photo you upload (see section 3). We store it small and without the extra data a camera puts in a photo, such as place and time.

A profile photo is not the same as the photos we use to make your book. We delete those as soon as your book is ready, and within 14 days at the latest. A profile photo stays for as long as the audiobook exists, because that is how your child recognises the reader. You can replace or delete it in your account at any time, and it is removed when you have your account deleted.

We store and play the recordings on the basis of the reader's consent. We use a profile photo on the basis of your legitimate interest and ours: showing your child who is reading (Article 6(1)(f) GDPR). Anyone in a profile photo who does not want this can email us at hi@mifolo.com, and we will remove it.

12. The audiobook: the standard voice

If you choose the standard voice, we have the book read aloud by an AI partner. For this we send the text of the story pages, page by page. That text contains your child's name and the names of others in the story. We do not send photos, your email address or the voices of readers.

We have the book read aloud once, after your payment, and then keep the audio ourselves. If you later choose another voice, or a name needs to be pronounced better, we have it read aloud again. Nothing goes to that partner when you listen. The text and audio land in our account history with the partner; we have them deleted there straight away. They may remain in the partner's logs and backups for up to 30 days. The partner may only use them to make the voice for us, not to train AI (see section 5).

We do this to deliver the audiobook you bought from us (Article 6(1)(b) GDPR). For the name of your child and of others in the story, the basis is your legitimate interest and ours: delivering the audiobook you ordered for your child (Article 6(1)(f) GDPR).

The partner is based in the United States and stores the data there; for speed it may also process it in the EU or in Singapore. It is certified under the EU-US Data Privacy Framework, for which the European Commission has decided that data is adequately protected (Decision (EU) 2023/1795). If that decision lapses, the European Commission's standard contractual clauses (Decision (EU) 2021/914) in our agreements with the partner apply.

13. The audiobook: the QR code and the Listening Shelf

You open an audiobook with the QR code in the printed book, with the book's link or in your eBook. Your Listening Shelf shows all the audiobooks in your account together, with its own link. You do not need an account to listen: the link is the key. That is why these links are long and random, so nobody can guess them.

Search engines do not include these pages. We do not measure visits there: no statistics and no advertising cookies. And if you go from such a page to another site, the link is not passed on.

You can protect your Listening Shelf with a 4-digit PIN. A device on which the PIN has been entered once remembers it. Anyone who tries a wrong PIN too often has to wait a while.

If the link to your Listening Shelf gets out, you create a new one in your account; the old one then stops working. We cannot replace the QR code in a printed book. If you no longer want people to listen through that code, you can switch it off in your account. The book's link, your Listening Shelf and the eBook then do not play that audiobook either. You can switch it back on at any time.

14. Customer service: chat, WhatsApp and email

You can ask us a question in the chat on the site, on WhatsApp or by email. We then keep your messages, our replies and the times. We also keep what you give us yourself: your email address, or on WhatsApp your phone number and the name on your WhatsApp profile. If you are signed in, we link the conversation to your account. We do not keep photos, voice messages or attachments in the conversation; it only says that you sent them. An email with an attachment does stay in our mailbox. So please don't send us photos of your child; they belong in the book maker.

In the chat and on WhatsApp, our AI assistant answers first. You can see this at the start of the conversation. It answers your question with the information on our site. If you would rather talk to a person, it passes your question to a member of our team, who carries on in the same conversation. The assistant makes no decisions about you: a refund, a new book, a discount or an exception is always decided by a person. Our team can read the conversations with the assistant.

If you write in a language other than Dutch, an AI partner translates your messages for our team, and our replies into your language. For an email, an AI partner sometimes writes a draft reply first; a member of our team reads it, changes it if needed and sends it themselves.

To do this, we send the text of your messages to an AI partner in the United States, together with the earlier messages in the same conversation. Your email address is only included if you want us to reply by email. Photos are never included. The partner may not sell the text or use it to train AI (see section 5); it may keep it in its logs for up to 30 days to detect abuse. Meta also keeps your WhatsApp messages for up to 30 days to deliver them, and an email to or from us stays with our email provider in the United States for 30 days.

To prevent spam and abuse, we automatically check that you are not a robot when you start a new chat. We also count how many messages come from an IP address or phone number. For this we only keep the IP address as a hash, not the address itself.

We also use the conversations to improve our service and the site: which questions come up often, how long you had to wait and whether an answer was good. For this we keep figures without your messages, name, email address or number. To see whether someone gets in touch more often, we keep an encrypted key instead of your details. These figures are kept for 3 years, even after the conversation itself has been deleted.

We answer your question to perform our contract with you, or to help you before an order (Article 6(1)(b) GDPR). If your question is not about that, we do so on the basis of our legitimate interest in answering questions (Article 6(1)(f) GDPR). The AI assistant, the translation, the abuse checks and improving our service rest on that same interest. What WhatsApp itself does with your data falls under the privacy policy of WhatsApp and Meta.

15. The waiting list

On the page of a country where you can't order yet, you can sign up for the waiting list. We then store only your email address, the country and the language of the page. You're only on the list once you click the link in our confirmation email; without confirmation, we delete your address after 7 days.

We use your address for one thing: sending you a single email as soon as you can order in that country. Then we delete it. If the country still hasn't opened after 18 months, we delete your address too. You won't get a newsletter unless you choose that separately (see below), and we don't measure anything with your sign-up.

When signing up, you can also tick a separate box: that you'd like occasional news and offers after that. The box is unticked by default and only counts after you confirm. If you ticked it, we don't delete your address after the email saying the country is open; instead we add it to our news list, with the date and the text you agreed to. Only from then on do we send you occasional news and offers. We do this on the basis of your consent too (Article 6(1)(a) GDPR). If you no longer want this, email us at hi@mifolo.com and we'll delete your address.

We do this on the basis of your consent (Article 6(1)(a) GDPR). Want to come off the list sooner? Email us at hi@mifolo.com and we'll delete your address straight away.

16. Friends & Family

When you buy an eBook, you get your own share code for Friends & Family. It is made of your first name and a few random characters, such as JULIET-K7QP. So anyone you give your code or link to sees your first name.

When someone opens your share link, we store the code in a cookie on that device for 30 days, so the discount is ready at checkout. The code does not appear in the address of the pages we measure.

When someone pays with your code, we record which code the order came through. That lets us give you the credit and spot misuse, such as referring yourself. We do this to keep our agreements with you and with the new customer (Article 6(1)(b) GDPR) and to prevent misuse (legitimate interest, Article 6(1)(f) GDPR). You only see your credit, not who made a book through your link.

We keep your code and your credit for as long as your account exists; credit lapses 90 days after it became available. Which code an order belongs to is kept as long as the order itself. If you have your account deleted, we delete your credit and make your code unrecognisable.

17. Changes

If we amend this statement, you will see the new version here with the date at the top. We will announce important changes.