Privacy policy draft
Who is responsible for the app
A company registered in England and Wales, no. 16379430. The controller of your personal data under the UK GDPR and the GDPR.
- Data protection officer: At this scale probably not mandatory (GDPR art. 37). If we don’t appoint one, we will say so plainly and name who is responsible for data here — TBC
- EU representative (GDPR art. 27): Required — the company sits outside the EEA and the users are in the EU — TBC
- Legal representative under the DSA: Point of contact for the Commission and national coordinators — TBC
Registered address: Unit 82A James Carter Road, Mildenhall, Bury St Edmunds, IP28 7DE, United Kingdom
Your rights
From the GDPR and the UK GDPR. You exercise each one here, without writing to support. We answer within 25 days.
Access and a copy of your data
See and download everything we hold about you
Correcting your data
Change your name, vehicle, photos. If your date of birth is wrong, we correct it on request — write to us
Erasing your data
The “right to be forgotten” — removes the account and its content
Restricting processing
We freeze the data instead of deleting it — for the duration of a dispute
Objecting to processing
Covers everything we base on our legitimate interest: photos, reports and blocks
Moving to another service
A JSON file in a machine-readable format
Withdrawing consent
Location and notifications — at any time
Complaint to a supervisory authority
The ICO in the UK, the UODO in Poland or the authority in your country
What we process and on what basis
Account and profile
Performance of the contract — without it there is no app
Location (approximate; exact only if you choose)
Your consent, withdrawn with a single switch
Age
Legal obligation — the service is 18+
Profile photos
Legitimate interest: safety. Automatic checking before publication — TBC (provider to be chosen). No face recognition
Reports and blocks
Legitimate interest: the safety of the community
Groups and Friends
Performance of contract — only if you use them: group membership, group chat, your Friends list and requests. Members of your groups see your exact location (you can hide in any group), and so do Friends if you choose so
Analytics and crash logs
We don’t collect them. If that ever changes — only with your consent, and the app will still work fully without it
How long we keep data
Account after deletion
30 days of grace to change your mind, then permanent deletion
Messages
Deleted together with the account — on the other side as well
Group chat and Friends
The chat exists as long as the group does; a deleted group disappears at once, and from backups within 7 days. Your messages are deleted with your account. An unanswered Friends request expires after 30 days
Location
We keep only the last position, we store no history
Notification token
Deleted within 24 h of turning notifications off or logging out, and an unused token after 60 days —
A photo you deleted
From the app at once, from the server within 24 h, from backups within 7 days
A photo removed in moderation
A copy kept in case of an appeal, then permanent deletion. An appeal made later is judged from the case file, without the photo —
Material passed to the authorities
Concerns harm to children. Here the law sets a minimum, so we keep it exactly that long
Reports, blocks and logs
We keep the report file as long as you have to appeal — 12 months. Technical log periods depend on local duties and remain to be settled
What you are responsible for, and what we are
Meetings with other users
Choosing the person, the place and what you share is yours — we don’t answer for how meetings go or for losses arising from them
What we don’t check about users
Not identity, not criminal records, not intentions. Registration confirms an email address, nothing more
Limits of any exclusion of liability
Liability for death and personal injury caused by negligence cannot be excluded — UK CRA 2015 s. 65. Other limits are assessed for fairness: s. 62 CRA and Directive 93/13
Who else touches your data
Hosting and database
Servers in the European Union
Photo checking
A scanning provider and a processing agreement — to be chosen — TBC
Firebase and push
Notifications through Apple and Google
Maps
Android: Google Maps, iPhone: Apple Maps, browser: OpenFreeMap — the map loads from their servers
Analytics and diagnostics
None — we don’t collect analytics
Handling reports
A support email tool
Transfers outside the EEA
Apple, Google and Firebase — under the EU–US adequacy decision (DPF) of 10 July 2023. The decision stands but is under challenge before the CJEU, so our contracts keep standby SCCs
Polski Vanlife LTD · Companies House 16379430 · info@tripsnail.com