# Postland Privacy Policy

> **DRAFT PENDING LEGAL REVIEW.** The structure follows the GDPR, but it **has
> not been reviewed by a lawyer** and contains fields to complete in square
> brackets. Replace it with the final version before publishing the app.

**Last updated:** [DATE]

## 1. Data controller

[LEGAL ENTITY], company number [COMPANY NUMBER], [FULL ADDRESS].
Contact: [CONTACT EMAIL]. Data protection officer: [DPO EMAIL].

## 2. What data we process

- **Account data:** name, email address, username, phone number (optional) and
  profile photo.
- **Location data:** latitude, longitude and accuracy, only while you have an
  active check-in.
- **Check-ins:** venue, address, optional message and end time.
- **Communications content:** messages you exchange with your friends.
- **Usage data:** sign-ins, device, IP address and last access date, for
  security purposes.

## 3. Why we use it and on what legal basis

| Purpose | Legal basis |
|---|---|
| Creating and maintaining your account | Performance of the contract |
| Showing your location to friends during a check-in | Your consent |
| Sending verification and password reset emails | Performance of the contract |
| Notifying you of friend requests and messages | Performance of the contract |
| Preventing abuse and protecting the service | Legitimate interest |

## 4. Location: exactly how it works

Your location is **only visible to your friends while you have an active
check-in**. When the check-in expires or you end it, sharing stops
automatically. You can revoke the location permission in your device settings
at any time; the app will keep working without it, with limited features.

## 5. Who we share your data with

- **Other users:** only your friends, and only as described above.
- **Service providers:** hosting [HOSTING PROVIDER], email delivery SendGrid,
  and maps and venue data Google Maps Platform. They act as data processors.
- **Authorities:** where there is a legal obligation.

We do not sell your data and we do not use it for third-party advertising.

## 6. International transfers

Some providers may process data outside the European Economic Area. Where that
happens, the European Commission's standard contractual clauses apply.

## 7. How long we keep it

For as long as your account is active. Location data is kept for
[RETENTION PERIOD] after a check-in ends. When you delete your account your
personal data is erased, except what we must keep by law.

## 8. Your rights

You can access, rectify, erase, object to and restrict the processing of your
data, request its portability, and withdraw your consent at any time. Write to
us at [CONTACT EMAIL]. You may also lodge a complaint with the competent
supervisory authority ([DATA PROTECTION AUTHORITY]).

## 9. Minors

The service is not intended for people under [MINIMUM AGE]. If we detect an
account belonging to a minor, we will delete it.

## 10. Changes

We will tell you inside the app if we change this policy materially.