This data protection statement applies to the website located at the address https://www.qoorio.app and/or mobile applications called Qoorio available for iOS and Android devices (each known as the “Site”). This Site is operated by HumansApp, UAB (company number 304932414) whose registered office is at Malunu st. 6C-6, LT-01200 Vilnius, Republic of Lithuania, (“we” “our” “Qoorio”). Our VAT number is LT100011972613. More details about how to get in contact with us can be found at the end of this data protection statement under no. 10. We take your privacy extremely seriously. We will not sell or lease your personal data. All data will be collected, stored and processed by us in accordance with the European Union General Data Protection Regulation No. 2016/679, other statutory regulations and not passed on to any third party unless we are under a statutory obligation to do so, or unless necessary for the provision of our services, or unless you have expressly agreed to the passing on of your data. The services offered by us via Site can function only if we collect, store, transfer, delete and/or otherwise use (“Process” or “Processing”) specific data relating to you. Personal data means all information relating to an identified or identifiable natural person (“Data”) such as your name, date of birth, address or email address. This data protection statement describes which of your Data we collect and for what purposes we Process it when you use the services offered by us on the Site. This data protection statement also contains important information on the protection of your Data, especially the statutory rights you have in connection with it. Certain services on our Site are offered by third-party suppliers. When you use these services, the data protection regulations of the third-party suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the third-party suppliers may require you to provide permission under data protection law. This data protection statement supplements the general terms and conditions (“GTC”) that form the basis of your contract with Qoorio for the usage of the Site (“Usage Contract”). In the event of discrepancy between the GTC and this data protection statement, the provisions of the latter shall apply.
2. Which of your data do we Process?
2.1. Connection to Site
When you connect to the Site, we Process the following data (logfiles), even if you are not logged in to the Site as a user:
- the IP address of your device;
- the browser used by your device;
- the content and URLs you connect to;
- the date and time of your connections
In the event of access via mobile devices, the following logfiles are also captured as part of your use of the Site:
- model and manufacturer of your mobile device;
- the operating system used by your mobile device (iOS, Android).
Without your express permission we will not use the personal data specified in this section, especially the IP address, unless such use is necessary (i) for the provision of our services and/or (ii) for security purposes, especially the prevention of cyber attacks such as data scraps and denial of service attacks and for preventing impermissible multiple applications.
2.2. Registration as member
In order to use our Site, and especially to undertake commercial transactions via the Site, to use the electronic payment system or to leave reviews and communicate with other users, you need a Qoorio account. For this purpose, you must register as a user on the Site. To register as a user, you will be asked to enter the following details on our Site:
- full name;
- email address;
Your full name, location and photo will be visible to all visitors to the Site.
2.3. Completion of your profile
After registering, you can add optional information to your profile.
(a) Profile details
- topics you can share;
- your meeting options.
Topics you can share and your meeting options are visible to other visitors to the Site.
Under “Payment” you can enter the details of the bank account (name of account holder and IBAN) to which payment is to be made by purchasers of the meetings you sell via the Site. To make it easy to provide this information, you can save your account details under “Payment”. Your account details will of course not be visible to anyone.
2.4. Use of Site for transactions
We will store and Process Data on your transactions on the Site (e.g. meeting option, introduction message sent to a seller, price, date and time of transaction and meeting, etc.). You can see this Data in the transactions overview of your account. If you sell meetings on our Site, we collect additional Data that you create when you offer the meetings for sale, particularly photos and video as well as text and other descriptions, location, etc. This Data will be visible only to visitors to the Site.
2.5. Use of the Adyen electronic payment system
(a) Setting up your e-wallet
When you pay a seller by credit card or if you accept payment from a buyer, or if you use other services on the Site for which a charge is made, the transaction in question will be processed via our electronic payment system, Adyen (see our GTC). To use Adyen, you will need to set up an e-wallet on the Site (referred to on the Site as a “wallet”) and provide us with the following information, which we will transfer to Adyen:
- Full name
- Date of birth
- Invoice address
- Telephone number
- Email address
(b) Payment via Adyen
If you use the Adyen electronic payment system, Adyen will collect the payment information required according to the payment method selected (e.g. credit card). Payment will then be implemented via Adyen and the payment service provider you have selected. To this extent, the data protection regulations of Adyen and the relevant payment service provider will apply. For more information on payment procedure and payment service providers, see no. 12 of our GTC. If you use a credit card as your payment method, Qoorio will see only the last four digits of your card number. This information will be used by us solely for the purpose of confirming payment and preventing fraud.
2.6. Communication, comments and reviews
When you use our services, we also collect the following Data:
- News that you share with other members via the Site;
- Your communication with other users.
For technical reasons, this content generated by you will remain online after the end of your user agreement. Nonetheless your name will not be visible and there will be a note stating that the content comes from a member who is no longer active (see our GTC).
2.7. Location data when you use the Site
Prior to the use of location-specific content and services within the Site, you will be asked by the Site for authorisation to Process your location data. If you give your permission, Qoorio will use your mobile device or web browser to determine the location of your mobile device or computer from various sources (GSM radio cells, GPS location, WLAN etc.). Location data are only ever approximate. Please note that, if you do not provide permission for the collection of your location data, the Site services for which the assessment of your location is necessary (“Location Services”) cannot be used. If you wish to revoke your permission, you can at any time prevent your location data being collected in the future by adjusting the settings in your mobile device or web browser. If you do so, you may no longer be able to use the Location Services. Qoorio will process the location data collected via your mobile device or web browser to offer you people to meet in your location. We will not store your location data long term. We will keep it only for long as and insofar as we need it to offer you location-related services.
3. Purposes for which we Process your Data
Insofar as not already specified under 2, we will Process your Data for the following purposes.
3.1. Provision of our services
We will Process your Data for the purposes of performing the usage agreement, for providing the services used by you on our Site
- and for facilitating your buying and selling of meetings
- for facilitating the electronic processing of payments for meetings bought and sold on the Site
- for verifying your identity and details
- for facilitating communication with other members
- for sending you messages necessary for the provision of our services
- for providing an overview of your transactions on the Site (transaction history)
- to show you offers from other members that might interest you (e.g. offers specific to your age, gender, transaction history, etc)
- to show you offers in your location, which could help you to trade locally or meet other members local to you (location-related services)
- to be able to offer our services free of technical errors and to be able to recognise and resolve any errors.
3.2. Legal rights, improvement of our Site, prevention and detection of inadmissible activity, system security
We will also process your Data to protect the following legitimate interests of Qoorio and/or any third parties:
- Resolution of disputes, enforcing our GTC and the enforcement, exercise and upholding of our rights
- Analysis and evaluation of usage of our Site for the purposes of continual improvement of our products and services
- Prevention, detection and prosecution of unlawful activity, especially fraud
- Detection, prevention and block of prohibited meetings and issue warnings, suspension, block or termination of your access to the Site
- Guaranteeing the security of the Site, the protection of the Data we hold and the detection of cyber attacks and other threats to the integrity of the Site
- Compliance with applicable tax obligations
3.3. Email newsletter and other marketing emails
You can register for our newsletter and for other marketing emails (“Marketing Emails”). When you register, we will ask you for your permission to Process your email address for the purposes of sending you Marketing Emails containing the latest information on our products and services, especially with regard to offers available on the Site, special offers and marketing campaigns. You will receive Marketing Emails only if you have given permission. Your permission also includes your agreement that we may personalise the content of Marketing Emails in accordance with your needs and interests on the basis of any information you have provided to Qoorio. Your permission for the sending of Marketing Emails can be withdrawn by you at any time with future effect. In your Qoorio account, you can adjust your settings to block the sending of any further Marketing Emails. Alternatively you can click “Unregister” at the end of the Marketing Email. Withdrawal of permission will not affect the lawfulness of Processing carried out prior to withdrawal of permission.
3.4. Account verification for security purposes
To ensure safety and security on the Site we ask users to verify their identity through Onfido (see GTC).
4. Online security
Access to your account is protected by a password set by you. Do not disclose your password to anyone. Once you have finished using Qoorio, remember to log off by using the log-off button, especially if you’re using a public computer. Please note that the transfer of data via the Internet (e.g. via email) is not always totally secure and the prevention of access by third parties cannot be guaranteed. We will take all technical and administrative security measures required to protect your Data from unauthorised loss and access as well as from unauthorised amendment, disclosure or deletion. Access to your Data is limited to those persons who require it for the purposes described in this data protection statement. Such persons are bound by the applicable data protection laws.
5. Contract processing
Qoorio may appoint external service providers to provide specific services. These service providers will undertake data processing procedures on our behalf and at our instruction (contract processors). Qoorio will select contract processors carefully and in accordance with applicable data protection laws. It will also ensure that Processing is carried out in accordance with the provisions of any written contract and with statutory data processing regulations. The procedures carried out on our behalf include:
- the provision of the technical infrastructure for the Site and the provision of server space
- online and usage analysis
- account verification
- customer service and enquiry processing
- payment processing and escrow
- trust in and security of the Site (e.g. prevention of fraud and harassment).
The contract processors appointed by us may under certain circumstances be granted access to your personal Data but solely for the purpose of the data processing requested. Contract processors are also contractually required to ensure that the level of their data protection is at least equivalent to that provided by us. All Data processed on our behalf remains under our control. We continually monitor compliance with our instructions, with guaranteed levels of data security and with contractual agreements formed with the data processor. Some of these service providers may be in countries outside the EU/EEA whose data protection levels are viewed within the EU/EEA as inadequate. We have nonetheless formed appropriate agreements with these service providers (or there are other guarantees in place) that ensure that all necessary measures will be taken to protect your data in accordance with the applicable requirements. If you have any questions about our service providers, please contact our Service help centre. If our question is not answered there, please contact us via email at firstname.lastname@example.org. As a minimum, we will always supply on request any additional information on the guarantees we have put in place (or where applicable a copy of this information via email).
6. Capture of public content by external search engines
Your full name, profile photo, “topics I can share” and “meeting options” details in your profile (see 2.2. and 2.3 above) will be freely available online and thus included in external search engine results. We therefore advise you not to publish any addresses, mobile numbers, email addresses or other contact data or sensitive or private information.
7. Disclosure of your Data to third parties
Qoorio will share your Data with other entities in Qoorio group. Qoorio is statutorily obliged to provide personal and/or usage Data to investigative, criminal prosecution or supervisory authorities if and insofar as required for the avoidance of risk to the public and for the prosecution of criminal acts. Qoorio may share your Data with third parties when transferring rights and obligations pertaining to the contractual relationship between you and Qoorio to such third parties in accordance with the GTC, in particular in the case of the transfer of a sector of activity, a merger through the foundation of a new company, a merger through absorption, de-merger or any change in control affecting Qoorio. Prior to such event Qoorio will inform you separately about the details of sharing your Data and will obtain your consent where legally necessary. In all other cases your Data will be passed on to third parties only where you have granted permission or have yourself given third parties access to your Data (not including third parties that we have commissioned as contract processors, see 5 above).
8.1. Required cookies
Cookies are small text files that our Site wants to place on your computer or other online devices such as tablets or smartphones. Provided your browser settings accept cookies, your browser adds the text in the form of a small file. Unless stated otherwise elsewhere in this data protection statement, the cookies we use are necessary for the functionality and performance of our Site. This includes cookies that enable you to register for the protected areas of our Site, to buy a meeting or to use the electronic payment system. Most cookies are deleted from your device after the end of your browser session (session cookies). The information saved in the required cookies will be used by us solely to provide the services and functions requested.
8.2. Managing your cookie settings
You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. If however you decline cookies, some of our services may have restricted functionality. For information on how to adjust or change your browser settings, visit www.aboutcookies.org or www.allaboutcookies.org. If you use multiple devices to access our Site (e.g. smartphone, tablet, computer etc.) you must ensure that each browser is adapted to each device in accordance with your cookie preferences.
9. Right of amendment
As we are constantly developing our services, we reserve the right to change this data protection statement at any time subject to the applicable regulations. Any changes will be published promptly on this page. Regardless of the aforementioned, you should check this page regularly for any updates.
10. Our contact details
If you have any queries regarding the Processing of your data as part of your use of the Site, or regarding your rights, please contact our data protection officer at email@example.com.