Quick Summary (TL;DR)
- ✅ We do NOT sell your personal data to data brokers.
- ✅ We do NOT collect precise GPS location (only rough City/Country).
- ✅ Your voting data is anonymous and used for aggregate statistics.
- ✅ You can delete your account and data instantly in App Settings.
1. Introduction & Data Controller
This Privacy Policy applies to the LORA mobile application.
Serbo Solutions (Sole Proprietorship / ZZP)
Amsterdam, The Netherlands
Email: serdarburakoral@hotmail.com
2. Data We Collect
2.1 Information You Provide (Voluntary)
When you use LORA, you may voluntarily provide:
- Year of Birth (for age verification and demographic groups).
- Gender identity.
- Demographic preferences (e.g., "Introvert vs Extrovert").
2.2 Usage Data (Automatic)
We collect interaction data to improve the app:
- Voting history ("Left" or "Right" selections).
- App timestamps and session length.
2.3 Device Data (No GPS)
We collect generalized data for analytics:
- Approximate Location: Derived from IP address or device settings (e.g., "Amsterdam, NL"). We do NOT collect precise GPS coordinates.
- Device type (e.g., "iPhone 15") and OS version.
3. Lawful Basis for Processing (GDPR)
Under the General Data Protection Regulation (GDPR), we process data based on:
- Consent: For the demographic data you explicitly answer (e.g., Profile questions). You can withdraw this at any time.
- Legitimate Interest: For analytics, security, fraud prevention, and maintaining the core functionality of the app.
4. Security & Retention
4.1 Security Measures
We implement industry-standard security measures, including TLS/SSL Encryption for data in transit and encrypted storage at rest via our database provider.
4.2 Data Retention
We retain your voting profile only as long as your account is active. If you choose to delete your account, personal data is permanently purged from production databases within 30 days.
5. Third-Party Services & International Transfers
We use trusted partners to operate. Your data may be processed on servers outside the EEA (e.g., USA). We ensure these partners use Standard Contractual Clauses (SCCs) for protection.
Supabase
Encrypted Database & Auth.
6 Age Restriction (16+)
LORA is strictly for users 16 years of age or older.
We do not knowingly collect data from children under 16. If we become aware that a user is under 16, we will immediately delete their account and data.
7. Terms of Use & Conduct
By using LORA, you agree NOT to submit or share content that includes:
- Hate speech, racism, or discrimination.
- Violence or threats.
- Illegal material or harassment.
We reserve the right to suspend or ban users who violate these rules without notice.
8. Your Rights (Global)
Whether you are in the EU (GDPR), California (CCPA), or elsewhere, you have the right to:
- Access & Correct: View the data we hold about you.
- Delete ("Right to be Forgotten"): Permanently remove your account via Settings.
- Opt-Out of Ads: Adjust your device settings to limit ad tracking.
- Lodge a Complaint: EU residents may complain to the Autoriteit Persoonsgegevens (NL) or their local DPA.