Privacy Policy

Automated processing in moderation: when a listing is published, the system computes a risk score based on duplicate photos, duplicate titles, a price that significantly deviates from the area average, and the presence of contact information in the description. Where enabled, the listing's title and description are additionally sent to a large-language-model provider (see section 6, "Content risk-scoring provider") for a scam-probability estimate. This score is one of the signals that can route a listing to manual moderator review — the final decision to remove or hide a listing is always made by a human (see Terms of Use, §6).

4. Legal basis for processing

5. Data retention

• Account: data is kept while the account is active. Upon account deletion (see section 8), the email address, display name, and phone number are anonymized; the user record itself remains in the database for referential integrity (e.g. so other users can keep their own copy of a shared conversation), but no longer allows login or identification of the person.
• Listings: every listing stays active for 60 days from publication or last renewal; you get a reminder 7 and 1 day before expiry, and after 60 days the listing is automatically paused (no longer publicly visible) unless renewed. When the owner's account is deleted, their listings are archived, not deleted — no longer publicly visible, but retained for legal and audit reasons (e.g. potential disputes, DSA obligations).
• Chat messages: account deletion erases only the messages sent by that user; the counterparty's messages remain part of their own conversation history and are not deleted (deleting another person's messages would infringe on their own right to retain their data).
• Favorites, saved searches, notification devices: deleted upon account deletion.
• Moderation records, audit log, reports (as the reporting party): retained indefinitely, or as required by law (DSA accountability and transparency obligations) — not deleted with the account.
• Access logs (IP addresses): the IP address is truncated/anonymized after 30 days.
• Database backups: a nightly backup is retained for 30 days, then overwritten — used solely for disaster recovery, not as additional archiving.
• Agency data (licence, registration/VAT numbers): retained while the agency is registered on the platform, and for as long afterwards as required by accounting/tax rules.

6. Data processors (third parties)

We use the following processors/service providers to operate the service. Where each is an external provider, we have a data processing agreement (DPA) in place:

Review note before publishing: the list above reflects providers actually integrated/planned in the code and docs/HANDOVER.md §2 (the "Compliance" section there lists the same set awaiting confirmation). The SMS provider and the actual hosting account have not yet been finalized by the client (Hetzner is architecturally confirmed in docs/plan.md/deploy/DEPLOY.md, but a specific account/region is pending) — name them explicitly before publishing and obtain/attach a DPA for each. Internal self-hosted monitoring (Uptime Kuma) is deliberately not listed — it only checks the site's public availability endpoint and does not process users' personal data.

7. International data transfers

Most of the providers above (Cloudflare, Google/Firebase, Anthropic, DeepL) are global providers that may process data outside the European Economic Area (EEA). Where this occurs, the transfer relies on one of the following mechanisms:

• an EU Commission adequacy decision (where applicable), or
• Standard Contractual Clauses (SCCs) offered by each provider as part of its data processing agreement.

Review note before publishing: for each finalized provider, verify the specific transfer mechanism and name it explicitly (not just in general terms).

8. Your rights

As a data subject, you have the right to:

• access your personal data,
• rectify inaccurate data,
• erasure ("the right to be forgotten") — to the extent described in section 5 above,
• data portability — receiving your data in a structured, machine-readable format,
• object to processing based on legitimate interest,
• restrict processing in the cases specified by the GDPR.

Self-service in Settings:

• "Download my data" — exports a copy of your profile, listings, messages, and saved searches as JSON; prepared within 24 hours.
• "Delete account" — triggers the deletion/anonymization process described in section 5. This action cannot be undone.

For requests not available self-service (e.g. objecting to processing, questions about international transfers), write to us at {{CLIENT_EMAIL}}. We respond to requests within one month of receipt, in line with the GDPR.

9. Cookies

For details on the cookies we use, see the separate Cookie Notice (Cookies). The service uses only strictly necessary cookies — no third-party advertising or analytics tracking.

10. Data security

We protect your data with appropriate technical and organizational measures, including:

• encrypted connections (HTTPS/TLS) for all traffic between your device and our servers,
• passwords are stored only in hashed form, never as readable text,
• access to production data is restricted to staff who need it for their work,
• photos are automatically stripped of EXIF metadata (including GPS location) before storage,
• regular dependency security scanning and access controls (rate limiting) on login and publishing endpoints.

We do not store payment card data — this version of the service has no payments in its offering.

11. Contact and complaints

For any questions about this policy or the processing of your personal data, contact us at {{CLIENT_EMAIL}}.

If you believe our processing of your personal data violates the GDPR or ZVOP-2, you have the right to lodge a complaint with:

Information Commissioner of the Republic of Slovenia (IP RS) Dunajska cesta 22, 1000 Ljubljana, Slovenia gp.ip@ip-rs.si · www.ip-rs.si

12. Changes to this policy

We may update this policy from time to time — for example, due to changes in law or new service features. We'll notify you of material changes through the service (an in-app notice or email) and update the date at the top of this document. We recommend reviewing this page periodically.