Locals Privacy Policy

Locals Privacy Policy

Locals Privacy Policy

Last updated: August 4, 2024

This privacy policy explains how we, Locals Ltd of Gladstonos 12-14, 8046 Paphos, Cyprus or any of our affiliated entities (“Locals”, “we”, “us”, “our”), process your personal information (“you”, “your”) when you use our website, app or other services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. 

By using the Locals mobile application (the “App”) or the website located at https://locals.org/ (the “Website”) (App and Website individually referred to individually as a “Locals Service” or collectively as the “Locals Services”) or otherwise indicating your acceptance (e.g. by clicking tick-box or bottom “agree” or continue”), you agree to the following terms of our Privacy Policy, which will bind you at all times and in whatever manner you use the Locals Services. 

Please note:

  • Individuals in the European Economic Area (EEA) and the United Kingdom (UK) should read our section about “Your EEA & UK Data Privacy Rights”.

  • Individuals from United States should also read our section on “Your United States Privacy Rights”.

  1. Where This Privacy Policy Apply to

This Privacy Policy applies to all Locals Services. 

This Privacy Policy does not apply to information that you have directly provided to other users, including Activities’ Creators, Club group admins, and others with whom you may share information about yourself out of Locals Services.

Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy (not this Privacy Policy) applies.

  1. What Types of Information Do We Collect

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.

We will process the following information which may be considered personal information:

Information You Provide to Us Directly

  • Profile Data:

  • Your user details when you sign up as a user of Locals Services; Information, such as your username, name, surname, date of birth, age, gender, your city or place, your profile image.  

  • Information that you provide about your goal, professional area, interests and occupation or that Locals otherwise collect about your preferences and interests known, observed or inferred.

  • Social media profile usernames/links. For safety reasons this information will be available to Verified Members only, unless you opt-out at any time. You will be free to edit or remove such information at any time if you no longer wish to share such information.

  • Your Instagram ID and your Instagram photo-stream, if you choose to link your Locals account to your Instagram account. 

  • Sensitive personal information, if you choose to provide it, for example in your bio. This could be information such as, for example, about your political opinions, religious or philosophical beliefs, health or sexual orientation. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please be aware that your activity while using Locals Services sometimes may make available some of your sensitive information. For instance, the mere fact of voluntary joining certain Activities (e.g. Clubs) to some extent may indicate information about your health, religion, political views, or sexual identity. Please do not post or add personal data to your profile that you would not want to be publicly available. If you choose to use our Locals Services and to share sensitive personal information on it (e.g., as part of your biography, in a message, by joining a topic-based Club or via event invite), this will constitute your explicit consent to our processing that information. You will be free to edit or remove such information at any time if you no longer wish to share such information.  

  • Your Content. To the extent permitted, necessary and sufficient by applicable laws and Locals Privacy Policy, we may review, scan, or analyze your communications within Locals Services and the content you post with us for reasons outlined in the “How We Use Information” below, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our Terms of Service, and content moderation purposes. For example, as part of our Locals improvement efforts and to expand product offerings, we may scan and analyse messages and materials uploaded to the App in message threads, profiles, Activities. In some cases, we may also review or analyse your chats with other Users and content published by you for the purpose of identifying and reporting content violations or inappropriate activities to appropriate authorities. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and content moderations, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

You can choose what information to share on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Locals Services. Be cautious when sharing information, as it may become visible to other users.

  • Contact details such as your telephone number and email address. 

  • Details of your request. When you contact or visit us, we may process the details of your request, communications, complaints, or other interaction.

  • Activity Data. Information you provide to us when you participate in any interactive features of Locals Services, including surveys, contests, promotions; when you join and interact with Activities, for example Clubs and Private Activity. Your choice of Activities is entirely voluntary and also optional, but we are required to process this information in order to administer your account, and to indicate that you are a Participant of the Activities that you join.

Information We Collect Automatically

  • Transaction information such as information about your purchases and donations in Locals Services, including date of donation / purchase, currency, amount, payment type and the last four digits of your card number. This data is used to provide you with Locals Services and for our in-app analytics.

  • Device information. When accessing our Locals Services, your device and browser will automatically provide unique information such as account ID, mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, app settings and characteristics, and identifiers associated with cookies or other technologies that may uniquely identify a device or browser operating system, browser type, time zone setting, location and date and time of access. (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. You may disable the collection of IDFA and/or Android Advertising ID by Locals, in the setting of your mobile device. We and third-parties may use cookies, Software Development Kits (SDKs), and other tracking technologies to automatically collect the Personal Data set forth above. For more information regarding our use of these technologies, please see our Cookie Notice.

  • Usage data. Our systems may record usage data about how you navigate, engage and interact with our Locals Services, for instance how you use them (e.g. when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address) and your interactions with other users (e.g. users you connect and interact with, and when you communicate  with them).

Information We Obtain from Third Parties
In addition to the information you may provide us directly, we receive information about you from others, including:

  • Users. Users may provide information about you as they use our Locals Services, for instance as they interact with you or if they submit a report involving you. 

  • Social media. You may decide to share information with us through your social media account, such as your interaction with our posts and content, social media profile by sharing your “stories” and ‘likes’ on social media platforms, such as Twitter and Instagram, TikTok.

  • Our suppliers. We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). We may receive information about you from our analytics service providers to help us measure traffic and usage trends with data they collect through Locals Services in accordance with their own privacy policies. A list of the analytic partners that operate in Locals Services can be found in the Appendix A below. Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties, as part of our efforts to ensure our users safety and security.

Other Information with Your Consent

  • Location Data. Some of our features rely on real-time information about the precise location of your device where you enabled the functionality on your device. If you decline permission for us to collect your precise location, we will not collect it, and those of our Locals Services which rely on location may not be available to you.

  • Phone Contact List. You may provide access to your phone contact list so that you can choose to invite your phone contacts to join the Locals Services or see which phone contacts are already on the Locals Service and get notified in the future when your contacts download the app. Your Phone Contact List will be periodically synced and stored securely on our servers. If you are the phone contact of a Locals Service user we may use your phone number to invite you to use the Locals Service but only if the existing registered Locals Service user requests that we do this.

  • Photo verification data. You may choose to verify your account, using our facial recognition feature, that compares the face in your selfie to the photos in your profile. We collect your verification data upon your consent, which may be considered biometric data in some jurisdictions. We only use your verification information for the purpose of Photo Verification. We do not add the verification photos to your profile. If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. 

  1. Data Accuracy

We will rely on the information provided by you as accurate, complete, and up to date, and we would be grateful if you could inform us of any changes. 

  1. How We Use Information

Generally, we will use your personal information to (i) provide our Locals Services and enable you to use our Locals Services features, (ii) respond to your queries, (iii) develop and promote our organization and services; (iv) ensure the security and technical availability of Locals Services; and (v) comply with the law. 

* If you are an individual in the EEA or the UK, we have to inform you about the “legal ground” for us to use your “personal data”. This will typically be the performance of our contract with you (based on our Terms of Use) or our legitimate interest to use your personal data to ensure that our services are provided properly, efficiently and securely, as is further explained in the table below.  

Where we rely on legitimate interests as the legal basis for processing personal data, we have considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose data are being processed and concluded that the processing is, on balance, fair. 

Where the legal basis is consent, you can withdraw consent at any time. You may withdraw your consent by adapting your settings or by deleting your content (for instance where you entered information in your profile that may be considered 'special' or 'sensitive'). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Where the legal basis is legitimate interests, you have a right to object to our use of your data.

Below, we describe the purposes for which we may process your personal data and our lawful bases for doing so:

Purpose

Personal information

Legal ground for processing* (for individuals in the EEA and UK only)

To administer your account and provide our Locals Services to you

To register you as a Locals Service user when you sign up for our Locals Services and to provide our Locals Services and service functionalities to you.

  • Profile data

  • Contact details

  • Phone contact list

  • Details of your request

  • Activity data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data

Necessary for the performance of our contract with you and for our legitimate interest in running our social media community.


We will obtain your consent and provide you with an “opt-out” option where required by law.

To enable you to make purchases or donations through our Locals Services.

  • Transaction information

Necessary for the performance of our contract with you and for our legitimate interest in facilitating our Locals Services.

To assist and contact you in relation to your enquiry or to send you information which you have requested about our Locals Services.

  • Contact details

  • Details of your request

  • Other information required to respond to your queries


Necessary for the performance of our contract with you and for our legitimate interest in responding to queries, maintaining business relationships and administering our business or to take necessary steps at your request prior to entering into a contract with you.

To fulfill your requests and send you service communications and notifications about matters relevant to your use of our Locals Services  and your engagement with us, such as information about offers you might be interested in, targeted content, confirmations of purchases, details of activities, surveys, changes in our terms, etc.

  • Contact details

  • Profile data

  • Contact details

  • Details of your request

  • Activity Data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data


Service communications are necessary for the performance of our contract with you. Other notifications are necessary for our legitimate interest in satisfying your requests, facilitating our Locals Services and organizing related business activities.


We will obtain your consent and provide you with an “opt-out” option where required by law.


Push notifications are generally subject to your consent given on your device.


To help you connect with other users

To facilitate networking opportunities on Locals Services and to enable you to operate your account as a Creator and Participants; to provide offers and interact with our social media community and to help you connect with other users, recommend you to other users  and recommend other users  to you; show users’  profiles to one another, enable users to search for and connect with other users

To facilitate networking opportunities on Locals Services and to enable you to operate your account as a Creator and Participants; to provide offers and interact with our social media community and to help you connect with other users, recommend you to other users  and recommend other users  to you; show users’  profiles to one another, enable users to search for and connect with other users; and to make recommendations for personalized activities (including using generative AI tools)

  • Profile data

  • Contact details

  • Phone contact list

  • Details of your request

  • Activity data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data

Necessary for the performance of our contract with you and for our legitimate interest in providing meaningful features to our users.


We will obtain your consent and provide you with an “opt-out” option where required by law.

To share information about you with our social media community, such as your username, story, image and other user information which is visible by all members of our social media community. 

  • Optional information that you choose to provide in your profile

Necessary for the performance of our contract with you and for our legitimate interest in running our social media community.

To assist and contact you in relation to your enquiry or to send you information which you have requested about our Locals Services.

  • Contact details

  • Details of your request

  • Other information required to respond to your queries

Necessary for the performance of our contract with you and for our legitimate interest in responding to queries, maintaining business relationships and administering our business or to take necessary steps at your request prior to entering into a contract with you.

To fulfill your requests and send you service communications and notifications about matters relevant to your use of our Locals Services  and your engagement with us, such as information about offers you might be interested in, targeted content, confirmations of purchases, details of activities, surveys, changes in our terms, etc.

  • Profile data

  • Contact details

  • Details of your request

  • Activity data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data

Service communications are necessary for the performance of our contract with you. Other notifications are necessary for our legitimate interest in satisfying your requests, facilitating our Locals Services and organizing related business activities.


We will obtain your consent and provide you with an “opt-out” option where required by law.


Push notifications are generally subject to your consent given on your device.

To provide offers and operate advertising and marketing campaigns

To send you promotional information through various marketing channels about our Locals Services and to organize, review and optimize effectiveness of advertising campaigns on our Locals Services and marketing our Locals Services off our platform.

  • Profile data

  • Contact details

  • Activity data

  • Device information

  • Usage data

  • Interaction information

  • Location data

  • Third party data

Some of our promotions are necessary for the performance of our contract with you. We will also use your information as is necessary for our legitimate interest in understanding your interests for direct marketing purposes from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics.


We will obtain your consent and provide you with an “opt-out” option where required by law. For example, your consent will be required to process advertising ID. 

To improve our Locals Services and develop new ones

To improve and develop our Locals Services, including to:

  • obtain feedback;

  • record likes and preferences;

  • conduct statistical analysis use  analytics service;

  • use analytics service;

  • make Locals Services and features more relevant;

  • improve user experience; and

  • work with third parties and evaluate data to improve and develop our Locals Services.


To ensure proper administration of our business, including to:

  • keep appropriate records about how our Locals Services  are used;

  • resolve complaints;

  • conduct troubleshooting;

  • manage our business relationships and identify opportunities;

  • register interactions with our communications, such as emails;

  • enforce our terms.

  • Profile data

  • Contact details

  • Phone contact list

  • Details of your request

  • Activity data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data

  • Communications data

Necessary for our legitimate interest improving Locals, including developing and delivering our Locals Services efficiently, understanding our users’ needs and where it is necessary for the adequate performance of the contract with you.


We will use cookies and similar technologies if you provided your consent.


Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our Locals Services and necessary for compliance with a legal obligation to which we are subject. 

To engage our third party service providers who may process your information on our behalf to facilitate the provision of our services and the fulfillment of essential service functions, such as web hosting, cloud storage, analytics, payments, plugins, communications, accounting, security and others.

  • All information necessary to enable the relevant service

Some activities are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring the proper operation of our Locals Services.

To prevent, detect and fight fraud and other illegal or unauthorized activities

To verify your identity and prevent fraud and to ensure the safety and security of Users.


To monitor operations, user activity and networks for suspicious activity, fraud prevention and crime detection purposes, including information from third parties who may help us verify your identity or alert us about suspicious activities and test and audit our systems and deploy appropriate security measures. Upon sign up, we may ask for your telephone number to send you a verification code.


To prevent, detect and fight fraud and other illegal or unauthorized activities.


To find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between users.


To better understand and design countermeasures against violations of our Terms of Use.


To retain data related to violations of our Terms of Use to address the violation and prevent against recurrences.


To enforce or exercise our rights, for example our rights set out in our Terms of Use.


To communicate to individuals who submit a report, including what we’ve done as a result of their submission.

To verify your identity; prevent fraud and to ensure the safety and security of Users.


To monitor operations, user activity and networks for suspicious activity, fraud prevention and crime detection purposes, including information from third parties who may help us verify your identity or alert us about suspicious activities and test and audit our systems and deploy appropriate security measures. Upon sign up, we may ask for your telephone number to send you a verification code.


To prevent, detect and fight fraud and other illegal or unauthorized activities.


To find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between users.


To better understand and design countermeasures against violations of our Terms of Use.


To retain data related to violations of our Terms of Use to address the violation and prevent against recurrences.


To enforce or exercise our rights, for example our rights set out in our Terms of Use.


To communicate to individuals who submit a report, including what we’ve done as a result of their submission.

  • Profile data

  • Contact details

  • Details of your request

  • Activity data

  • Transaction information

  • Device information

  • Usage data

  • Interaction information

  • Location data

  • Photo verification data

Necessary for our legitimate interest to ensure that accounts are not set up and operate fraudulently and to safeguard Users of our social community and necessary for compliance with a legal obligation to which we are subject.


We will obtain your consent and provide you with an “opt-out” option where required by law. For example, Photo verification and Location data are generally subject to your consent given on your device.

To ensure legal compliance

To share information with our group companies.

  • Any necessary information on a proportionate and lawful basis

Necessary for our legitimate interest in using our group’s resources to organize, develop and deliver our Locals Services, run our organization and decide on future strategies.

To share data with another organization in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization or similar event relating to our business.

  • Data necessary in connection with the event

Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.

To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.


To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.

  • Any information subject to mandatory processing or disclosure, where this is proportionate and lawful

Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims, to fulfill our duty of care owed to third parties or, where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws.

  1. Automated Decision-Making and Profiling

We use Automated decision-making and profiling features for the following reasons:

  • To help connect you with other users; (including where we use generative AI tools to recommend personalized ideas for activities, as described below)

  • To show you ads and offers that may be of interest to you;

  • To promote safety and security. We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other profile data) and messages for content that indicates breaches of our Terms of Use. This processing may lead to suspension or account closure for users who are reported to be found to engage in illegal or unauthorized activities, both on and off our services, without prejudice to other legal actions we could take.

We do not intend that these automated decision-making or profiling activities will produce legal or other significant effects for you; please contact us if you think for any reason that this is the case.

  1. No Processing of Payment Details

We will not receive or store any of your payment details, this is fully handled by the relevant payment service provider. If/when you make any purchases in a Locals store, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details or personal data related to the payment. We only keep the data concerning transaction dates, currencies, value, the last four digits of your card number and the subject of the transaction.

  1. Cookies and Similar Technologies

Please, read our Cookie Notice on how we use cookies and similar technologies. 

  1. Sharing Your Information

We will generally not share your information except with (i) our third party service providers and advisors who may process personal information on our behalf, (ii) our advertising, marketing and analytics partners, as explained above, (iii) our group companies for the purposes set out above, (iv) persons or authorities where we are compelled by law, (v) to the relevant entity in case of a merger, acquisition or collaboration, and (vi) other third parties where you have provided your consent

From time to time Locals may offer the functionality for you to choose to synchronise your Locals events with third party event platforms and relevant personal information may be shared with such third party event platforms in this case. 

We use suppliers to help us operate, distribute, market and improve our Locals Services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. For these purposes, we may share your personal information with our analytics service providers, who utilise generative AI and machine learning tools (e.g., ChatGPT) to perform in-depth analysis and gain valuable insights on Locals Services improvement. We also share information with suppliers who distribute and assist us in advertising our Locals Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors.

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Sharing with other users on and off Locals services. You share information with other Users when you voluntarily disclose information on Locals Service (including your public Profile data). Your profile data is fully visible to all users and/or visitors of our Locals Services, it can also be visible to others on or off of our Locals Services (e.g., visitors to our Services or users of third-party search engines). You may choose to share other user profiles and they may share yours with people outside of our Locals Services, using the sharing functionality.

Some information about your activity within Local Services, such as registration for or donation to an Activity, including Paid Activity, your Club memberships, participation in or expressing interest in Activity, may be visible to other users and/or visitors of our Locals Services. We recommend that you check the Activity and what information may become available before joining the Activity to ensure that you are happy with the information that may be visible to others.

You may update your profile's privacy settings at any time (e.g. make your Profile Data unavailable for public viewing off the Locals Service) by contacting us.

Creators. Please also note that some users, such as Creators of Activities or Club group admins, you interact with, may have access to your Personal Data (e.g. Profile data, Contact details) and act as data controllers to your information. We are not in charge of their actions as they are directly responsible for complying with all applicable privacy legislation in relation to Personal Data they process for the purposes of managing their Activities, including Club administration.

  1. Third-Party Content And Integrations

Our Locals Services may contain third-party content and integrations, such as ChatGPT that we use to suggest personalized ideas for activities. Through these integrations, you may be providing information to the third party as well as to Locals (or we may do so on your behalf). We are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our services.

  1. Suggested Personalized Ideas For Activities

We have a feature to suggest personalized ideas for activities based on your goals, interests, bio, occupation, professional area, gender, age, location (city or place), gender (“Input Data”). By using our Locals Services, you acknowledge the processing of your data using generative AI tools for the purpose of personalized ideas for activities.

How it works

This feature is based on ChatGPT. ChatGPT is a natural language processing tool that analyzes your Input Data to provide recommendations. When you create your account in Locals and provide your Input Data, we send a query to ChatGPT together with the Input Data and receive a reply that has been drafted by ChatGPT. Locals operates a ChatGPT account and interacts with the ChatGPT software on your behalf; so you do not need to have your own account with ChatGPT.

Your Input Data will be used solely for the purpose of suggesting personalized ideas for activities and will not be used to train ChatGPT. Suggested personalized ideas for activities that  you have “liked” on your Locals profile, will be available on your account and profile and may be visible to other users. You can edit, remove or delete these activities at any time.

To learn more about how ChatGPT processes your data, please see the ChatGPT Privacy Policy at [https://openai.com/policies/privacy-policy].

Disclaimer

Please note that the suggestions provided by ChatGPT are not guaranteed to be accurate or suitable for your specific circumstances. We do not assume responsibility for the results of using this feature. If you are not satisfied with the result of the suggested personalized idea for activity, you may simply “dislike” it, refrain from “liking” it. You can always contact our support team at [email protected], we will do our best to address your concerns and find a solution that meets your needs.

Opt-out

If you wish to opt-out of this feature you may remove suggestions in your profile.

  1. Personalised Cover For Your Activity Generated By AI

If you grant us permission to access your camera, your device’s photo library or your contact list, we will process the photos you select to upload to Locals to provide features of the app that you choose to use.

The following describes how we process, share, and retain your photos, and Image Data in connection with the feature for the creation of  personalized cover for activity feature, generated by artificial intelligence of the Locals app (AI RSVP). 

AI RSVP.  When you upload photos to Locals to use this feature, we process your photos using technology that identifies a face on the photo (collectively, “Image Data”).

When uploading photos that include individuals other than yourself, you are confirming that you have obtained all the necessary consents from these individuals to upload their photos to Locals.

If you have uploaded a photo to Locals to create AI RSVP, we will use artificial intelligence technology to generate new images using the Image Data. This processing only occurs on your device and is not stored on our servers. Image Data will be used solely for the purpose of creating new images in AI RSVP and will not be used to train any technology and/or create separate artificial intelligence outputs or products. 

The new content created using AI RSVP will be available on your account and profile, if you choose to share it, and may be visible to other users. You can edit, remove or delete this content and/or the activities to which the content relates at any time.

  1. Links to Other Sites

For the convenience of our visitors and clients, Locals Services may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.

  1. How Long Is Your Information Kept?

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

  • Account deletion. We delete most of your information after you delete your account, unless we are required to keep it for longer for limited legal purposes or for our legitimate interest purporses. It means that we will retain your Personal Data until you delete your account or request us to delete your data (by contacting us at [email protected]). Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

Please note that deletion of App does not imply the deletion of your account and your data

  • Photo verification data retention. We retain the scans so that we can verify you in the future and to audit and manage our photo verification feature until we no longer need them for such purposes. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems. Photo verification data are only created and retained with your consent for the duration of the Photo Verification process. Photo Verification may take up to 24 hours. Once your Photo Verification is complete, the verification information is deleted. We retain screenshots from the photo selfie that you took for the purposes outlined above, but the Photo Verification information pulled from your photo is deleted.

    You can request deletion of the scans by [email protected]. In any event, this information is deleted upon account closure.

  • Retention to comply with legal obligations. We may retain your Personal data in connection with your privacy-related requests and communications with us, if any, as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. 

    We delete your data and only keep limited information for specified purposes, as laid out below:

    • We must keep it to comply with applicable law (for instance, if you make purchases within the Locals Services, some personal data may be kept for tax and accounting purposes);

    • We must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behavior that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);

    • There is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

    • The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

  • Usage data. We may retain usage data associated with the deleted account for the purposes of ensuring the security and integrity of our systems, supporting business analysis and improving our services. We will ensure that any usage data retained after account deletion is securely stored and used only for the aforementioned purposes.

  • Anonymized Data. Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.

  1. How Do We Secure Your Information?

We maintain appropriate organizational and technological safeguards to help protect against unauthorized use, access to or accidental loss, alteration or destruction of the personal information we hold. We also seek to ensure our third-party service providers do the same.

We will endeavor to use the least amount of personal information as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate.

Our staff will access your personal information on a “need to know” basis.

Unfortunately, the transmission of personal data through the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to or stored on our IT system, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.

  1. Where Is Your Information Processed?

We may transfer your personal information to our group companies, suppliers and other third parties in countries different to your country of residence.

In addition, data may be transferred to our subsidiaries or processors in third countries or subcontractors of our processors in third countries.

We and certain of our service providers are incorporated in the United States. Accordingly, your Personal Data may be transferred to and stored in the United States.

Where required under the EEA General Data Protection Regulation ("GDPR"), in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK General Data Protection Regulation ("UK GDPR"), in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom

  1. Our Policy Regarding Children

We appreciate the need to provide extra privacy protections to users who are children. Locals Services are intended for general audiences over the age of 18 years (or of age of legal majority where you live, if different). We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 18 or knowingly allow such persons to use Locals Services. If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 18, please contact us.

  1. Electronic Communications

By using Locals, you also agree to receive electronic communications from us, including via email, push notifications and by posting notices on Locals. The communications between you and us may take place via electronic means, whether you use Locals or send us emails, or whether we post notices on Locals or communicate with you via email. These communications may include notices about Locals and Subscriptions and are part of your relationship with us. For contractual purposes, you: (i) consent to receive communications from us in an electronic form; and (ii) agree that all terms and conditions, agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if it were to be in writing. The foregoing does not affect your statutory rights. Communications from us and our affiliated companies may include but are not limited to: operational communications concerning your Account or the use of Locals (e.g., technical and security notices, updates to this Privacy Policy and Locals Terms of Use), and updates concerning new and existing features (e.g., changes/updates to features of Locals and their scope, prices of in-app subscriptions).

You may opt-out of receiving promotional emails from us at any time through any of the following methods:

  • by following the opt-out links in any promotional email sent to you;

  • by contacting us at any time at [email protected];

You may opt-out of push notifications by changing the settings on your mobile device.

  1. Contact Us

Please email us if you have any queries or concerns about how we use your personal information. We will try to resolve your query without undue delay.
E-mail: [email protected] 

Appointed UK representative
Locals has appointed LocalsUK Ltd. as its data privacy representative in the UK to act as its direct contact for data subjects and UK supervisory authorities. If you usually reside in an UK you can contact LocalsUK Ltd. regarding matters pertaining to the data privacy by: 
Email – [email protected]
Postal address – Ground Floor Wessex House, Pixash Lane, Keynsham, Bristol, United Kingdom, BS31 1TP.

  1. Updates

If we make any changes to our Privacy Policy you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.

We may make changes to these Privacy Policy at any time, including, for example only, in order to: (a) comply with any changes to the law or regulations that apply; (b) to reflect any technical changes, such as to respond to security breaches; or (c) deal with changes to Users’ needs and changes to our business. You should check these Privacy Policy each time you access the Locals Services to ensure you understand the terms that apply at that time.

Provided you have registered an account with us, we will try to notify you of any changes to these Privacy Policy by email or a pop-up notice when you next access your account. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.

If you do not agree to any changes to these Privacy Policy that we may make, do not use the Locals Services. In addition, you may close your account by contacting us.

  1. Your EEA & UK Data Privacy Rights

This section provides further disclosures and describes the rights in relation to your personal data that you may have under GDPR if you are an individual in the EEA or UK GDPR if you are an individual in the UK.

  1. Personal data. “Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.

  2. How do we process your information and why? We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above.We will update you about any new purposes of processing your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.

  3. Data subject rights. Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:

    • Right to information about matters set out in this policy. You may also contact us for further details about our retention policy and international data transfers.

    • Right to make an access request to receive copies of personal data, as well as to share your personal data with other parties.

    • Right to rectification of any inaccurate or incomplete personal data.

    • Right to withdraw consent previously provided, without affecting the lawfulness of our processing based on consent before its withdrawal.

    • Right to object to our processing of personal data for direct marketing purposes, or that is based on our legitimate interests, and any automated decision-making and profiling.

    • Right to erasure of personal data, in certain circumstances.

    • Restriction on the processing of personal data in certain circumstances.

    • Right to data portability from one service provider to another, where applicable.

    • Right to lodge a complaint with your country’s supervisory authority. Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter. You can exercise these rights directly with us by submitting a request at [email protected]. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

  1. Your United States Privacy Rights

While Locals collect, process and share personal information of all our users as described in this Privacy Policy, U.S. residents ​​may have certain statutory rights under state comprehensive privacy laws including the rights specified below. 

A “resident” is a natural person who resides in a specific state, even if the person is temporarily outside of the state. References to “personal data” in this Section include “sensitive/personal information” as defined under applicable California or other US state legislation.

  1. We do not sell your information for monetary gain. Under certain state laws (including California), if we disclose personal information to a third party for any benefit, this can be considered a “sale” or “share” or personal information, even if the third party does not use the personal information for any other purpose. Locals may “share” personal information if we disclose personal information to a company for purposes of cross-context behavioral advertising.

  2. Request to opt out. While we do not sell your personal information for monetary gain, you have the right to opt out of our “sale” or “sharing” of your personal information (as defined under California or other US state legislation) to our analytics and advertising partners. To exercise this right, you can adjust your browser settings or contact [email protected].

  3. Right to request the business or commercial purpose for collecting your Personal Information. Locals will provide, where relevant and required by law, the purposes to collect data.

  4. Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Locals will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.

  5. Right to request the specific pieces of Personal Information collected about you. Locals will provide, where relevant and required by law, your Personal Information.

  6. Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Locals.

  7. Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.

  8. Shine the Light. California residents may also request information from us once a calendar year about any personal information shared with third parties for their own direct marketing purposes. We don’t share information with third parties for their own marketing uses, but please email us at [email protected] if you have questions.

Please keep in mind that in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

Appendix A: Analytics and Other Service Providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving Locals Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

  • Amplitude. Amplitude is an analytics service provided by Amplitude Inc. (USA). For more information on the privacy practices of Amplitude, please visit the Amplitude Privacy Policy or write to Amplitude at [email protected].

  • AppsFlyer. AppsFlyer is an analytics service provided by Appsflyer Ltd (Israel). For more information on the privacy practices of Appsflyer, please visit the Appsflyer  Website Privacy Policy & Services Privacy Policy. You can opt-out of AppsFlyer Analytics tracking by completing the Opt-out form or by writing to AppsFlyer at [email protected].

  • Adapty. Adapty (Adapty Tech Inc., USA)  is a service for analytics and growing mobile in-app subscriptions. For more information on the privacy practices of Adapty, please visit the Adapty Privacy Policy. You may opt-out by contacting Adapty at [email protected].

  • Meta Ads Network. Meta Ads Network is an analytics service provided by Meta Platforms, Inc. (USA) that connects data from the Meta advertising network with actions performed on this Application. You can opt-out of Facebook Analytics by following the instructions provided by Facebook in its Data Policy and Cookies & Other Storage Technologies section or by writing to us at [email protected].

  • Google Firebase. Firebase is an analytics service provided by Google Inc. (USA) You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google. You can opt-out of certain Firebase features by following the instructions provided by Google in the United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out.

  • Google Analytics. Google Analytics is an analytics service provided by Google Inc. (USA). You can opt-out of certain Google features by following the instructions provided by Google in the United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out.

© 2024 Locals Ltd. All rights reserved.
© 2024 Locals Ltd. All rights reserved.
© 2024 Locals Ltd. All rights reserved.
© 2024 Locals Ltd. All rights reserved.