Privacy policy
Responsible party
What is the scope of this privacy policy
What data is collected
How your data is used
How your data is shared
Cross-border data transfer
Your rights
How long your data is kept
Protection of children's data
Changes to the privacy policy
How you can contact us
1. Responsible party
The responsible body within the meaning of data protection law, in particular the EU General Data Protection Regulation (GDPR), is
RoKi travel
Romina Manzey & Kira Wonneberger GbR
August-Hanken-Straße 24
26125 Oldenburg
2. What is the scope of tis privacy policy
This Privacy Policy applies to our website and app, which we operate under the RoKi travel brand. For simplicity, we refer to these things all together in this Privacy Policy as our “Service”.
If, for any reason, one of our services requires its own separate privacy policy, that policy will be made available to you and will apply instead of this privacy policy.
3. What data is collected
In order to suggest suitable users, hotels, restaurants and activity providers to you individually, we need some information from you, such as basic profile details and information about your travel and travel buddy preferences. Using our service also generates some information, such as when you signed up and how you used the service. We may also collect data from third parties, for example, if you access the service through an account you have on another platform (e.g. Google or Apple) or if you upload information from your account on another platform to complete your profile. If you would like to know all the details about this, please read the following categories.
Account details:
When you create an account, you provide us with basic information to set up your account, such as your e-mail address and date of birth.
Profile date:
When you complete your profile, provide additional details about yourself, such as your gender, background, hobbies, travel budget or travel destinations.
Content:
When you use our service, you can post photos, videos, audio, text and other types of content, such as your vacation photos.
Acquisition data:
When you buy something, we receive the details of the transaction (e.g. what you bought, the date of the transaction and the price). The exact details depend on the payment method you choose.
Customer service data:
When you contact us, you provide us with information that may be required to process your inquiries. Other individuals may also submit inquiries or reports involving you.
Where permitted by applicable law, we may also receive information about suspected or convicted malicious actors from third parties as part of our efforts to ensure the safety of our members.
Social-Media-Data:
You may provide us with data about your accounts on other platforms (e.g. TikTok, Instagram, Google, Apple), e.g. when you create an account and log in to your account via these platforms.
Data that is generated or collected automatically
Usage data:
Using the service generates data about your activities, including how you use the platform (e.g. when you logged in, what features you used, what activities you performed, what information you were shown, what website you came to us from, what advertisements you interacted with) and interactions with others (e.g. searches, matches, communications). We may also receive data in connection with interactions you have had with our advertisements on third-party websites or apps.
Technical data:
Use of the Service includes the collection of data from and about the device(s) you use to access our Service, including hardware and software information such as IP address, device ID and type, app settings and properties, app crashes, ad IDs, and identifiers associated with cookies or other technologies that can uniquely identify a device or browser.
Other data that we collect with your permission/consent
Location data::
If you give us your permission, we can collect your location data from your device. If you decline permission, features based on precise location localization will not be available to you.
4. How your data is used
The main reason for processing your data is to provide our service and to continuously improve the service. This includes connecting you with other users, personalizing your experience and helping you get the most out of our Service. We also process your data to ensure your safety and the safety of all our members while using our service. We take this responsibility very seriously and are constantly working to improve our systems and processes to help protect you. We process your data to display relevant advertisements. This is explained in more detail below.
Purpose of the processing of your data:
To enable your use of our service; this includes:
Creation and maintenance of your account and profile on our service
Operating and managing the various functions on our service
Recommend other members to you and recommend you to other members
Suggesting customized hotel offers to you
Answering your requests and questions
Monitoring the smooth functioning of our service and troubleshooting and resolving problems as required
Processing your requests to take out a Premium subscription
Basis for the processing of your data:
Performance of our contract with you
Your consent (if sensitive data or other types of data requiring consent are processed)
Categories of processed data (described in section 3 of this policy):
Account data
Profile data
Contents
Acquisition data
Marketing, survey and research data
Third party data
Customer service data
Social media data
Usage data
Technical data
Location data
Purpose of the processing of your data:
To enable your purchases on our Service, including:
Processing of payments Offering discounts and promotions, individual adjustment of prices
Fulfillment of our contract with you
Categories of processed data (described in section 3 of this policy):
Account data
Profile data
Technical data
Purchase data
Usage data
Purpose of the processing of your data:
To conduct advertising and marketing campaigns, including:
To run and measure the effectiveness of advertising campaigns on our Service
To run and measure the effectiveness of marketing campaigns promoting our own Service on third party platforms
Communicating with you about products and services that we think may interest you
Basis for the processing of your data:
Consent (where required by applicable law) and otherwise in accordance with our legitimate interest. It is in our legitimate interests to promote our Service and show advertisements to our members that are tailored to their interests in order to improve their experience and fund the free parts of our Service
Categories of processed data (described in section 3 of this policy):
Account data
Profile data
Usage data
Marketing, survey and research data
Technical data
Purpose of the processing of your data:
To improve our service and develop new features and services, including:
Organization of focus groups, market studies and surveys
Analyzing how our service is used
Developing and improving new features and services, including through machine learning and other technologies, and testing these new features and services
Basis for the processing of your data:
Performance of our contract with you
Our legitimate interest: It is in our legitimate interest to continuously improve our service
Consent where required by applicable law (for example, we may process data deemed sensitive or special category in certain countries to ensure that the different communities using our Service are treated fairly and equitably and that our Service remains diverse and inclusive)
Categories of processed data (described in section 3 of this policy):
Account data
Profile data
Contents
Acquisition data
Marketing, survey and research data
Third party data
Customer service data
Social media data
Usage data
Technical data
Purpose of the processing of your data:
To ensure your safety and the safety of other members on our service; this includes:
Preventing, detecting and addressing violations of our Terms, fraud and other illegal or unauthorized activities
Developing and improving tools to prevent, detect and address violations of our Terms, fraud and other illegal or unauthorized activities
Prevent recurrence, in particular by preventing someone who has breached our Terms from setting up a new account
Notifying people who have submitted a report of the action we have taken
Verifying your identity
Basis for the processing of your data:
Performance of our contract with you
Our legitimate interest: It is in our legitimate interest and that of our members that their safety is ensured
Protecting your vital interests and those of other members
Complying with legal obligations that apply to us, such as removing illegal content
Your consent (where sensitive data or other types of data requiring consent are processed)
Categories of processed data (described in section 3 of this policy):
Account data
Profile data
Contents
Purchase data
Third party data
Customer service data
Usage data
Technical data
Facial geometry data
ID data
Purpose of the processing of your data:
To comply with applicable law and to establish, exercise and defend legal claims and rights; this includes:
Retention of data for compliance with applicable law and proof of compliance
Supporting investigations and defenses in potential or pending litigation, regulatory actions or disputes
Responding to lawful requests from law enforcement agencies, courts, regulators and other third parties
Reporting illegal or infringing content to law enforcement agencies and governmental or other authorities
Establishing or exercising claims or defending against asserted or threatened claims
Disclosure of data to law enforcement authorities or business partners to combat abusive or illegal behavior
Basis for the processing of your data:
Our legitimate interest: It is in our legitimate interests to comply with applicable law and to protect ourselves, our members and others, for example, in particular in the context of investigations, legal proceedings and other disputes
Protecting your vital interests and those of other members
Complying with legal obligations that apply to us, such as complying with requests for information from law enforcement authorities
Categories of processed data (described in section 3 of this policy):
The categories of data shared vary depending on the specific circumstances that apply to each obligation, compelling interest or dispute
5. How your data is shared
Since our goal is to help you find your perfect Travelbuddy and plan the perfect vacation, some of your information will of course be visible to other members of the service and our cooperation partners such as hotels. We also share data with service providers and partners who help us operate the service, for the reasons set out below and in some cases for legal and related reasons. You can find more details below.
Receiver:
Other members
Reasons for disclosure:
You share information with other members when you voluntarily disclose information on the Service that others can view (e.g., your public profile).
If someone makes a report that concerns you (e.g. an allegation that you have violated our Terms of Use), we may let the person making the report know what action, if any, we have taken as a result of their report. The same applies if you submit a report that concerns another member.
Categories of personal data:
Profile data
Profile content
Social media data
Third party data
Customer service data
Receiver:
Service provider/ cooperation partner
Reasons for disclosure:
We share data with vendors and business partners who help us operate, promote and improve our Service. They perform services for us, such as data hosting and storage, analytics, customer support, marketing, advertising, payment processing, legal support and security operations.
Categories of personal data:
Depending on the service to be provided by the provider or business partner, this may include the following data:
Account data
Profile data
Contents
Acquisition data
Marketing, survey and research data
Third party data
Customer service data
Social media data
Usage data
Technical data
Geolocation data
Face geometry data
ID data
Receiver:
Advertising partners/ cooperation partners (hotels, restaurants)
Reasons for disclosure:
We may publish advertisements about advertisers' products and services on our Service and publish advertisements on third-party websites and apps that promote our own Service. To improve the relevance of these advertisements, we provide third parties, including advertising partners, with certain information about you or allow them to collect such data from our Services (e.g. via cookies, SDKs or similar technologies). Some of our advertising partners allow us to convert your email address, advertising identifiers or phone number into an identifier that cannot be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns or to target our ads to an audience similar to you in terms of background, interests or app usage.
Categories of personal data:
Account data
Profile data
Usage data
Technical data
Recipient:
Affiliated companies
Reasons for disclosure:
We may share data with or receive data from affiliated companies for the purposes set out in Section 6 of this Privacy Policy.
Categories of personal data:
The categories of data vary depending on the reason for sharing, but may include the following:
Account data
Profile data
Content data
Acquisition data
Marketing, survey and research data
Third party data
Customer service data
Social media data
Usage data
Technical data
Geolocation data
Face geometry data
ID data
Recipients:
Law enforcement authorities
Reasons for disclosure:
We may disclose your information to (i) comply with or support court orders, such as court orders, subpoenas or search warrants, government or law enforcement investigations or other legal requests, (ii) assist in the prevention or detection of crime, (iii) protect the safety of any person, and (iv) establish, exercise or defend legal claims.
Categories of personal data:
The categories of data shared will vary depending on the specific circumstances that apply to each arrangement, but will often relate to the following:
Account data
Profile data
Contents
Purchase data
Customer service data
Third party data
Social media data
Usage data
Technical data
Geolocation data
ID data
Receiver:
In connection with mergers and acquisitions with our affiliated companies or new owners
Reasons for disclosure:
We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change in ownership or control.
Categories of personal data:
The categories of data passed on vary depending on the type of corporate transaction. The entire organizational data or only a certain subset, such as acquisition data, may be included.
6. Cross-border data transmission
As we operate a global service, transfers of your data under Section 5 include cross-border transfers to the United States of America and other countries that may have different data processing laws in place. When we transfer personal data to countries outside the EEA, the United Kingdom, Switzerland or other countries whose data protection laws have been deemed adequate by the European Commission or other relevant government authorities, we generally rely on the so-called Standard Contractual Clauses. These Standard Contractual Clauses are obligations between companies that transfer personal data and require them to ensure the protection and security of your data.
7. Your rights
We want you to be in control of your data, so we want to remind you of the following rights, options and tools that are available to you. Depending on where you live, you may not have the same rights or they may be labeled differently. If you have any questions about your rights and how to exercise them, please contact us here.
Your right:
Access, transferability or information
Right to be informed about the personal data we process about you.
How to practice it:
You can access and check some data directly by logging in to your account.
Your right:
Correction:
Right to amend or update your personal data if it is incorrect or incomplete.
How to practice it:
You can update your data directly in the service by simply updating your profile. If you wish to correct other data, please contact us here.
Your right:
Deletion
Right to erasure of personal data
How to practice it:
You may delete some of the data that you have provided to us directly within the Service. You can also close your account, in which case we will delete your data as set out in this Privacy Policy. In any case, you can contact us here at any time.
Your right:
Revocation of consent
Right to withdraw your consent to the processing of your personal data for a specific purpose
How to practice it:
You can withdraw your consent directly by either updating your account setting or removing device permissions that you have consented to in your device settings (e.g. access to certain types of device data such as phone contacts, pictures, advertising identifiers and location services or consent to receive push notifications). If you withdraw your consent, certain services may no longer work. For more information, you can contact us here at any time.
For your protection and the protection of all our members, we may ask you for information to verify your identity or authority to act on behalf of a member before we can respond to the above requests. We don't want anyone else to have control of your data!
Remember that we may deny requests if, among other things, we are unable to authenticate you, if the request is unlawful or invalid, or if it violates another person's trade secrets or intellectual property or privacy or other rights. If you wish to obtain information about another member, such as a copy of any messages you have received from that member, the other member must make a request themselves.
If you are a resident of Texas, Oregon, Montana, Virginia, Colorado or Connecticut, in the event that we deny your privacy request, you may be able to appeal by contacting us and specifically referencing “Privacy Request Appeal”. If you have concerns about the outcome of your appeal, you may contact the Attorney General of your state.
In certain countries, in particular the European Economic Area and the United Kingdom, you have the right to lodge a complaint with the relevant data protection authority if you have concerns about the way we process your personal data. The data protection authority to which you can lodge a complaint may be located where you are habitually resident, where you work or where an alleged infringement has taken place.
8. How long your data is stored
We will only retain your personal information for as long as necessary for legitimate business reasons (as set out in Section 4) and as permitted by applicable law.
If you decide to stop using our Service, you can delete your account, which will make your profile no longer visible to other members.
After closing your account, we will delete your data as described below:
To protect the security of our members, we retain information for security reasons for a period of three months after account closure or one year after an account ban. During this period, we will retain your information to investigate unlawful or harmful behavior. The retention of data during this security retention period is based on our legitimate interest and that of potential third party victims.
We retain limited data to comply with legal retention obligations: Specifically, we retain transaction data for a period of 10 years to comply with tax and accounting legal requirements, retain credit card information for the period for which the user may dispute the transaction, and retain “traffic data”/logs for a period of one year to comply with legal retention requirements. We also retain records of consents given by members for a period of five years to ensure and demonstrate compliance with applicable laws.
We retain limited data based on our legitimate interest: we retain customer service communications for a period of 6 years from the date of communication, retain customer care records and supporting data, as well as imprecise download/purchase location data for a period of five years to support our security efforts, to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, retain information about the existence of previous accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, retain profile data in the event of potential litigation, for the establishment, exercise or defense of legal claims for a period of one year, and retain data necessary to prevent members who have been prohibited from opening a new account for as long as necessary to ensure the safety and vital interests of our members.
Finally, we retain data based on our legitimate interest if there is an outstanding or potential issue, claim or dispute that requires us to retain data, in particular if we receive a valid legal subpoena or request to retain data (in which case we would need to retain the data to comply with our legal obligations) or if data would otherwise be required as part of legal proceedings.
If and to the extent permitted by law, we may retain and use information that does not identify you alone or that cannot be specifically attributed to you for the purposes described in this Privacy Policy, including to improve our Service and to create new features, technologies and services.
9. Protection of children's data
Our service is intended exclusively for people aged 16 and over. We do not tolerate anyone under the age of 16 on our platform. If you suspect that a member is under the age of 16, please use the reporting procedure available on the service. For more information on Tinder's age verification, please click here.
10. Changes to the privacy policy
This policy may change over time. We want to make sure that statements about our data practices are always up to date. We will notify you before material changes become effective so that you have time to review the changes.
11. How you can contact us
Online:
Postal:
RoKi travel
August-Hanken-Straße 24
26384 Oldenburg
Stand: 25.10.2024