This Privacy Policy explains what personal data is collected through the neighbourgood.app application, why it is collected, how it is used and shared, how long it is kept, and what rights you have in relation to it. Because the application shows you people and offers near you, it uses information about the location of your device. Section 6 explains how that works and how you can control it.
1. About This Privacy Policy
1.1 This Privacy Policy applies to the neighbourgood.app mobile application for iOS (the "App") and to the services made available through it (the "Service").
1.2 It should be read together with the Terms and Conditions of Use, which govern your use of the Service. Terms defined in the Terms and Conditions have the same meaning here.
1.3 This Privacy Policy is written to apply internationally. Some rights and obligations described in it apply only to users in particular countries or regions, and those sections identify where they apply.
2. Who Is Responsible for Your Personal Data
2.1 The Service is operated by Abhishek Jain ("we", "us" or "our"), an individual operator rather than an incorporated company. We determine the purposes and means of the processing described in this Privacy Policy and, where data protection law uses that concept, we act as the controller of your personal data.
2.2 You may contact us in relation to privacy matters by email at support@neighbourgood.app or in writing at 19667 73C Avenue, Langley, BC V2Y 3R5, Canada.
2.3 We have not appointed a data protection officer. Applicable law does not require us to do so on the basis of our current activities. If that position changes, this Privacy Policy will be updated.
2.4 Where we are required to designate a representative in the European Union or the United Kingdom in respect of users located there, the details of any such representative will be published in this Privacy Policy.
3. Scope and What This Policy Does Not Cover
3.1 This Privacy Policy covers personal data that we collect through the App and in connection with the operation of the Service.
3.2 It does not cover the way in which another user handles information about you. When you contact a seller or a buyer, or meet a user in person, that user obtains information about you directly, and their handling of it is a matter between you and them. We are not responsible for it. You should share only what you are comfortable sharing.
3.3 It does not cover the practices of Apple in operating the App Store and the iOS platform, of your mobile network operator, or of any external website or service that you reach from the App. Those parties operate under their own privacy notices.
4. Categories of Personal Data We Collect
4.1 We collect the following categories of personal data:
- Account data: your name and your email address.
- Profile data: your profile photograph and any other information that you choose to add to your public profile.
- Age confirmation data: the date of birth or age confirmation that you provide when you register, and the record that the confirmation was given. We use it only to establish that you meet the minimum age required by the Terms and Conditions and to enforce that requirement.
- Location data: the approximate geographic position of your device, derived from its satellite positioning capability and related signals, where you have permitted the App to access it.
- Listing data: the text, images, categories, prices and other details that you publish when you advertise goods or services.
- Rating and review data: the star rating and review text that you submit about another user, a listing or a dealing, together with your identity as the reviewer and the date of submission.
- Favourites data: the record of the sellers or listings that you save to your favourites list, which is held against your account and is not published to other users.
- Message data: the content of messages you exchange with other users through the in-app messaging function, together with the identity of the participants and the time of sending.
- Usage and technical data: information generated when you use the App, such as authentication events, search queries, records of interaction with listings, device and application identifiers, the push notification token assigned to your device by the Apple Push Notification service where you enable notifications, application version, crash and diagnostic information, and internet protocol addresses recorded by our hosting infrastructure.
- Report and enforcement data: information contained in reports that you submit or that concern you, and records of any action taken in response.
- Correspondence data: the content of any communication that you send to us and our replies.
4.2 We do not knowingly collect special categories of personal data, such as data revealing health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric data, or data concerning sex life or sexual orientation. Please do not include such information in your profile, listings, reviews or messages. If you choose to do so, you make that information public or disclose it to the recipient at your own initiative and, where consent is the applicable legal basis, you consent to its processing as part of the content concerned.
4.3 We do not collect payment card details or bank account details, because the Service does not process payments.
5. Information You Provide to Us
5.1 You provide account data, profile data and age confirmation data when you register, and you may change your account and profile data at any time from within the App.
5.2 You provide listing data, rating and review data, favourites data and message data whenever you publish a listing, submit a review, save a favourite or send a message. Listing data and rating and review data are published to other users of the Service. Message data is disclosed to the recipient of the message. Favourites data is not published to other users.
5.3 You provide correspondence data when you contact us for support, to submit a report, or to exercise a privacy right.
5.4 You are responsible for the personal data of other people that you include in your own content. If you upload an image that shows another identifiable person, or refer to another person in a listing, a review or a message, you must have a lawful basis for doing so and, where required, that person's consent.
6. Location Data
6.1 The Service exists to connect users who are near one another. It cannot perform that function without information about where your device is.
6.2 The App requests access to location information through the standard permission prompt presented by iOS. You may grant or refuse that permission, and you may change or withdraw it at any time in the privacy settings of your device. iOS also allows you to choose whether the App receives your precise position or only an approximate one, and whether it may access location only while the App is in use.
6.3 Where you permit access, we use location data to identify listings and users situated near you, to display listings on a map, to show approximate distance, and to prevent abuse of proximity-based features. Where you have chosen to allow only approximate location, the accuracy of these features will be correspondingly reduced.
6.4 Other users see information about your general area to the extent necessary for the Service to function. They do not see your street address unless you choose to disclose it to them.
6.5 If you refuse or withdraw location permission, the core features of the Service will not operate. You may still be able to access your account, but the Service will be of limited use to you.
6.6 Precise geolocation data is treated as sensitive personal information under the privacy laws of several United States states, including California. Section 21 explains the additional rights that apply to it.
6.7 Map tiles and geographic information displayed in the App are supplied by third party mapping providers. When map content is loaded, technical information such as your internet protocol address and the coordinates of the area requested may be received by that provider in order to serve the requested content.
6.8 The optional alerts about new listings published in your area, described in Section 23, do not involve any additional collection of your location. An alert is sent to the devices of users who have enabled that feature, and your device then compares the location of the listing with your own location locally, on the device, in order to decide whether to display the alert. Your location is not transmitted to us for that purpose.
7. Photographs and Images
7.1 You may upload a profile photograph and images of the goods or services that you list. To do so, iOS will ask your permission to access your photo library or your camera. You may grant or withdraw that permission in the settings of your device. We access only the images that you select.
7.2 Images that you upload are stored by our hosting provider and are displayed to other users as part of your profile or your listing.
7.3 Images may carry embedded metadata, which can include the time an image was taken and the coordinates of the place where it was taken. Before uploading an image, consider whether it discloses the location of your home or of a valuable item. You can remove location metadata in the settings of your device or by editing the image before uploading it.
7.4 We do not use facial recognition or any other biometric identification technique on uploaded images.
8. Messages Between Users
8.1 Messages sent through the App are transmitted and stored on infrastructure operated by our hosting provider. They are protected in transit and at rest by the security measures described in Section 19, but they are not end-to-end encrypted, and they are technically accessible to us.
8.2 We do not routinely read messages. We may access, retain, disclose or remove message content where it is necessary to investigate a report, to protect the safety of a user, to prevent, detect or investigate fraud, abuse or unlawful conduct, to enforce the Terms and Conditions, to keep the Service secure, or to comply with a legal obligation or a lawful request from a competent authority.
8.3 Messages remain visible to the participants in a conversation. If you delete a message or your account, copies may remain in the account of the other participant and in our backups for the periods described in Section 18.
9. Information Collected Automatically
9.1 When you use the App, our hosting infrastructure automatically records technical information such as your internet protocol address, the time of a request, device and application identifiers, the version of the App and of your operating system, authentication events, and error and crash information. Where you enable notifications, the push notification token issued to your device by Apple is also stored against your account so that notifications can be delivered to that device.
9.2 We use this information to operate and secure the Service, to authenticate you, to deliver notifications that you have enabled, to diagnose faults, to detect and prevent abuse and fraud, and to understand which features are used so that we can improve them.
9.3 The App does not use advertising identifiers, does not display advertising, and does not track your activity across applications or websites operated by other companies. We therefore do not present the App Tracking Transparency prompt.
9.4 The App is not a website and does not use browser cookies. Local storage on your device may be used for essential purposes such as maintaining your session and caching content for performance.
10. How We Use Personal Data
10.1 We use personal data for the following purposes:
- to create and administer your account, to authenticate you, and to establish and enforce the minimum age requirement set out in the Terms and Conditions;
- to publish your listings, reviews and profile to other users and to operate proximity-based discovery and search;
- to maintain your favourites list;
- to transmit and store messages between users;
- to send notifications that you have enabled, including alerts about messages, about activity relating to your listings, and about new listings published in your area;
- to provide support and to respond to your enquiries;
- to send you service communications, such as security alerts, notice of changes to our terms, and messages about your account;
- to maintain the security, integrity and availability of the Service, and to detect, prevent and investigate fraud, abuse, spam, prohibited listings, false or manipulated reviews and other breaches of the Terms and Conditions;
- to handle reports and complaints and to take enforcement action where appropriate;
- to analyse usage in order to fix problems and improve features; and
- to comply with legal obligations and to establish, exercise or defend legal claims.
10.2 We do not sell personal data, and we do not use personal data for behavioural advertising or for cross-context behavioural advertising. We do not send marketing emails. If we introduce marketing communications in future, we will obtain your consent where the law requires it and will provide a means of opting out.
11. Legal Bases for Processing
11.1 This Section applies where the General Data Protection Regulation (Regulation (EU) 2016/679), the United Kingdom General Data Protection Regulation, or another law requiring a legal basis for processing applies to you.
11.2 We rely on the following legal bases:
- performance of a contract, for creating and administering your account, publishing your listings and reviews, maintaining your favourites list, operating proximity-based discovery, transmitting your messages and providing support;
- consent, for access to the location capability of your device, for access to your camera and photo library, and for the delivery of push notifications. You may withdraw consent at any time in the settings of your device or, in the case of the alerts about new listings in your area, within the App, without affecting the lawfulness of processing before withdrawal;
- our legitimate interests, for keeping the Service secure, preventing and investigating fraud and abuse, verifying that users meet the minimum age required by the Terms and Conditions, handling reports, analysing usage to improve the Service, and protecting our legal position. We have considered the impact of this processing on you and consider that it does not override your interests and rights; and
- compliance with a legal obligation, where we are required to retain or disclose information.
11.3 Where we rely on legitimate interests, you may object to the processing on grounds relating to your particular situation, as described in Section 20.
12. Search Functionality and Automated Processing
12.1 The App includes a search function that applies automated techniques, including artificial intelligence techniques, to interpret search queries and to select and order the listings shown to you. It operates only on data held within the Service, such as listing text, categories and approximate location. It does not draw on external data sources.
12.2 Your search queries and interactions with results are processed in order to return relevant results and to improve the accuracy of the function.
12.3 We do not use your personal data to train general purpose artificial intelligence models, and we do not make your content available to third parties for that purpose.
12.4 Search results are generated automatically and may be incomplete or imprecise. They do not represent any assessment by us of a listing, a user, or the goods or services offered.
13. Automated Decision-Making
13.1 We do not make decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing.
13.2 We use automated signals to help detect spam, fraud, prohibited listings, false or manipulated reviews and abusive behaviour. Where such a signal leads to the removal of content or the restriction or suspension of an account, the decision is subject to human review on request, and you may challenge it by contacting us as described in the Terms and Conditions.
14. Information Visible to Other Users
14.1 The following information is visible to other users of the Service: your display name, your profile photograph if you upload one, the content and images of your listings, the ratings and reviews that you submit together with the display name under which you submitted them, any rating calculated from reviews about you, and information about your general area sufficient to indicate proximity.
14.2 The content of a message is visible to the participants in that conversation.
14.3 Your date of birth or age confirmation, and your favourites list, are not visible to other users.
14.4 Other users may retain, copy or screenshot information that you publish or send. We cannot control what they do with it once they have received it.
14.5 You control what you publish. You may edit or delete your listings and your profile information at any time from within the App.
15. Disclosure of Personal Data
15.1 We disclose personal data only as described in this Privacy Policy, namely:
- to other users, as described in Section 14;
- to the service providers described in Section 16, which process personal data on our behalf and on our instructions;
- to law enforcement authorities, regulators, courts and other public bodies, where disclosure is necessary to comply with a legal obligation or a lawful request, or to establish, exercise or defend legal claims;
- to professional advisers, such as lawyers, where necessary for advice or the conduct of a claim; and
- to an acquirer or prospective acquirer, in connection with a sale or transfer of the Service or of the business associated with it, subject to appropriate confidentiality protection and to notice being given to you where the law requires it.
15.2 We do not sell personal data and we do not share personal data for cross-context behavioural advertising, as those expressions are defined under United States state privacy laws.
15.3 Where we receive a request from a public authority, we will assess it and will disclose only what we are legally required to disclose. We will notify you of the request where we are permitted to do so.
16. Service Providers
16.1 We rely on a small number of external providers to operate the Service. At the date of this Privacy Policy they are:
- Google, in respect of the Firebase platform, which provides authentication, database, file storage, notification delivery and related application infrastructure. Personal data collected through the Service is stored on that platform. Information about Google's privacy practices is available at firebase.google.com/support/privacy and policies.google.com/privacy.
- Providers of the map data and mapping services displayed within the App, which receive technical information such as internet protocol addresses and requested coordinates when map content is loaded.
- Apple, in respect of the distribution of the App through the App Store and platform services including the Apple Push Notification service used to deliver notifications to your device. Information about Apple's privacy practices is available at apple.com/legal/privacy.
16.2 Providers that process personal data on our behalf do so under contractual terms that restrict them to processing on our instructions and require appropriate security measures.
16.3 If we engage an additional provider that processes personal data, this Section will be updated.
17. International Transfers
17.1 The Service is available internationally and our hosting provider operates a global infrastructure. Personal data collected through the Service may therefore be stored and processed in the United States and in other countries where our hosting provider maintains facilities.
17.2 Those countries may not provide the same level of protection for personal data as the country in which you live.
17.3 Where personal data is transferred out of the European Economic Area or the United Kingdom, the transfer is made on the basis of a transfer mechanism recognised under applicable law. Our hosting provider's data processing terms incorporate the standard contractual clauses adopted by the European Commission under Commission Implementing Decision (EU) 2021/914, together with the United Kingdom addendum issued by the Information Commissioner, and those clauses apply to transfers of personal data processed on our behalf.
17.4 You may request further information about the transfer mechanisms that apply by contacting us at support@neighbourgood.app.
18. Data Retention
18.1 We keep personal data only for as long as it is needed for the purposes described in this Privacy Policy, and then delete it or render it permanently anonymous.
18.2 The following periods apply in the ordinary course:
- account and profile data: for as long as your account remains open, and deleted following account deletion in accordance with clause 18.3;
- age confirmation data: for as long as your account remains open, and deleted with your account;
- listings and listing images: until you delete them, or until your account is deleted;
- ratings and reviews: for as long as your account remains open, and deleted or dissociated from your identity following account deletion in accordance with clause 18.3;
- favourites: until you remove the entry, or until your account is deleted;
- messages: for the duration of your account, subject to the copy retained in the account of the other participant;
- location data: retained only for as long as needed to serve proximity-based results and, where retained beyond a session, no longer than is necessary for security and abuse prevention;
- push notification tokens: for as long as notifications remain enabled on your device, and deleted when you disable notifications, when the token is withdrawn by the platform, or when your account is deleted;
- technical, security and diagnostic logs: ordinarily not more than twelve months;
- reports, complaints and enforcement records: ordinarily not more than twenty four months from the closure of the matter, or longer where necessary to identify repeat conduct or to defend a claim; and
- correspondence with us: ordinarily not more than twenty four months.
18.3 When you delete your account, your profile and listings are removed from public view without undue delay, and the underlying data is deleted from our active systems within thirty days. Copies may persist in encrypted backups for a further period of up to ninety days, after which they are overwritten in the ordinary backup cycle.
18.4 We may retain specific information for longer where retention is necessary to comply with a legal obligation, to prevent a user who has been removed for serious misconduct or for being under the minimum age from re-registering, or to establish, exercise or defend legal claims. In those cases we retain the minimum information necessary for that purpose.
19. Security
19.1 We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration and disclosure. These include encryption of data in transit, encryption of data at rest as provided by our hosting platform, access controls and authentication rules restricting access to stored data, administrative access limited to those who need it, and logging of system activity.
19.2 No system can be guaranteed to be completely secure. We do not claim, and you should not assume, that the Service has been certified against any particular security standard, or that it has been subjected to independent audit.
19.3 You play an important part in security. You should use a strong and unique password, keep your device secured and updated, and never share your credentials or one-time codes with anyone, including anyone claiming to represent us.
19.4 If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority, and will notify you where required by applicable law, without undue delay.
20. Your Rights
20.1 Depending on where you live, you may have some or all of the following rights in relation to your personal data: to be informed how it is used; to obtain access to it and a copy of it; to have inaccurate data corrected; to have data erased; to restrict how it is processed; to object to processing that is based on legitimate interests, or to processing for direct marketing; to receive data that you provided to us in a structured, commonly used and machine readable format and to have it transmitted to another controller where technically feasible; and to withdraw consent at any time where processing is based on consent.
20.2 Many of these rights can be exercised directly within the App. You can edit your name, profile photograph and listings, delete individual listings, edit a review that you have submitted, remove entries from your favourites list, delete your account, turn notifications on or off, and change or withdraw location, camera and photo library permissions in the settings of your device. To delete a review that you have submitted, contact us as described in clause 20.3.
20.3 To exercise any right, write to us at support@neighbourgood.app. We will respond within the period required by the applicable law, and in any event without undue delay. We may need to ask for information sufficient to satisfy us of your identity, so that we do not disclose your data to someone else.
20.4 We do not charge a fee for responding to a request unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act, and will explain our reasons.
20.5 We will not discriminate against you for exercising a privacy right. The Service will not be degraded, and no different price or service level will be applied, because you have made a request.
20.6 If you are in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or place of the alleged infringement. We would ask you to contact us first so that we have the opportunity to address your concern.
21. Additional Information for United States Residents
21.1 This Section applies to residents of United States states that have enacted comprehensive consumer privacy legislation, including California, and supplements the rest of this Privacy Policy.
21.2 The categories of personal information that we collect are identifiers, such as name, email address, account identifier, device push notification token and internet protocol address; characteristics of protected classifications, in the form of the age or date of birth that you confirm at registration; commercial information, in the form of the listings, ratings, reviews and saved favourites associated with your account; internet or other electronic network activity information, such as usage and diagnostic data; geolocation data; visual information, in the form of photographs that you upload; and the content of communications between you and other users. The sources, purposes and disclosures for each category are described in Sections 4, 10 and 15.
21.3 Precise geolocation data and, where applicable, the content of communications, are treated as sensitive personal information. We collect and use them only to provide the Service that you have requested, to keep it secure and to comply with law. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you, and we do not use it for any purpose beyond those permitted by applicable law without your consent.
21.4 We do not sell personal information and we do not share personal information for cross-context behavioural advertising, including that of any consumer we know to be under the age of sixteen. We have not done so in the preceding twelve months.
21.5 Subject to the conditions and exceptions in the applicable state law, you have the right to know what personal information we collect, use and disclose; to obtain a copy of it; to correct inaccurate information; to delete it; to limit the use and disclosure of sensitive personal information; to opt out of any sale, sharing, targeted advertising or profiling in furtherance of decisions producing legal or similarly significant effects, none of which we carry out; and not to receive discriminatory treatment for exercising a right.
21.6 You may exercise these rights by writing to support@neighbourgood.app. An authorised agent may submit a request on your behalf, in which case we will require written proof of authorisation and may require you to verify your own identity directly.
21.7 Where the applicable state law provides a right of appeal against a decision on a privacy request, you may appeal by replying to our response within thirty days, and we will inform you of the outcome and of any further avenue of complaint available to you.
22. Children and Young People
22.1 The Service is not directed to children and is not available to anyone under the age of eighteen. The Terms and Conditions require every user to be at least eighteen years of age.
22.2 When you register, you are asked to confirm your age or your date of birth, and an account is not created where the confirmation given indicates that you are under the age of eighteen. That confirmation is a self-declaration. We do not carry out documentary age verification and we do not use a third party age assurance service, and we therefore cannot guarantee that a person who gives a false confirmation will be prevented from registering.
22.3 We do not knowingly collect personal data from a person under the age of eighteen.
22.4 If we become aware that we hold personal data of a person under the age of eighteen, we will close the account and delete the data without undue delay.
22.5 If you are a parent or guardian and you believe that a person under the age of eighteen has provided personal data through the Service, please contact us at support@neighbourgood.app so that we can take appropriate action.
23. Device Permissions and Platform Controls
23.1 The App requests the following permissions from your device. Each may be granted or withdrawn at any time in the settings of your device.
- Location, in order to show listings and users near you and to display them on a map. iOS allows you to choose between precise and approximate location and to limit access to periods when the App is in use.
- Camera and photo library, in order to allow you to add a profile photograph and images to your listings. We access only the images that you select.
- Notifications, where you choose to receive alerts. Notifications are used for two purposes. The first is to alert you about messages sent to you and about activity relating to your own listings and reviews. The second is the optional alert about new listings published in your area, which is off unless you turn it on and which you may turn off at any time within the App or in the notification settings of your device.
23.2 Where you enable notifications, the push notification token issued to your device by Apple is stored against your account so that notifications can be delivered to it. Alerts about new listings are sent to the devices of users who have enabled that feature, and the App then decides on your device, by comparing the location of the listing with your own, whether the alert is shown to you. Your location is not sent to us in order to receive those alerts.
23.3 Withdrawing a permission does not delete data already collected. To have that data deleted, use the rights described in Section 20.
23.4 Apple publishes privacy information about the App on its App Store listing. That information is a summary and this Privacy Policy is the authoritative description of our practices.
24. Changes to This Privacy Policy
24.1 We may update this Privacy Policy to reflect changes to the Service, to the providers we use, or to applicable law.
24.2 The effective date at the head of this Privacy Policy indicates when the current version took effect. We will keep the previous version available on request.
24.3 Where a change is material, we will give notice within the App or by email before it takes effect. Where the change requires your consent under applicable law, we will obtain that consent.
25. How to Contact Us
25.1 If you have a question, a request or a complaint about privacy, please contact us by email at support@neighbourgood.app or in writing at 19667 73C Avenue, Langley, BC V2Y 3R5, Canada.
25.2 We will acknowledge your communication and respond within the period required by applicable law.
25.3 If you are not satisfied with our response, you may be entitled to complain to the data protection or consumer protection authority in your country, as described in clause 20.6 and clause 21.7.