سياسة الخصوصية

TRIPPBO — PRIVACY POLICY Legal review draft | Prepared 14 October 2026 This Privacy Policy describes the collection and use of personal data by Trippbo OÜ in connection with its website, user accounts, social travel services, trip information and hotel accommodation bookings. A separate mobile application and Trippbo Frame product remain under development; this Policy must be reviewed against their actual processing before launch. We do not currently send promotional email newsletters, and private messaging is not currently offered. 1. Data controller and contact Trippbo OÜ, company registry code 17187333, Järvevana tee 9, 11314 Tallinn, Estonia, is responsible for the personal-data processing it determines as a controller. Privacy requests: info@trippbo.com. In certain travel, payment and infrastructure transactions, other organisations act as independent controllers or processors depending on their actual purposes and contractual roles. 2. Where data comes from We receive information (a) directly from you when registering, selecting profile settings, posting content, placing bookings or contacting us; (b) from a lead booker who supplies information about other guests; (c) from reservation providers and the accommodation establishment, such as confirmation, cancellation and refund status; and (d) automatically through essential technical operation, payment events and consent settings. We do not ask browsers for GPS permission for the current website functions; users may manually enter a location or destination. An approximate city/country may be inferred from an IP address where such processing occurs. 3. Data categories Account and eligibility: email, password verifier/hash, account and session IDs, date of birth used for the 16+ registration rule, username, profile photograph, account settings and access/security events. Do not disclose your password to support staff. Profile and community: optional biography, city/country, photographs, videos, captions, comments, reactions, following relationships, shared trips, saved travel memories, reports of content, moderation actions, appeal requests and related notifications. File metadata may include information such as capture date or embedded location if supplied in the file. Accommodation booking and guests: lead booker’s name and contact details, names of all adult and child guests, ages of child guests, destination/hotel, check-in/check-out dates, occupancy, requests, applicable cancellation terms, booking IDs, confirmation and provider status, payment amount, selected currency, changes, cancellations, refunds and service communications. Passport/ID photographs and passport numbers are not ordinarily requested in the current checkout, although hotels may separately require identification at check-in. Payments: Stripe payment and transaction references, processing status, amount, currency, refund or dispute status, billing details where collected, and limited card-related information returned by Stripe. Card details are entered through Stripe Elements; Trippbo’s reviewed social/NestJS code does not directly store full card numbers or CVV, but review of all Laravel hotel-backend flows remains subject to verification. Technical and support information: IP address where logged, browser/device details, security logs, cookies/local-storage choices, support email and correspondence, rights requests and audit evidence. We do not currently have verified evidence of live Google Analytics, Meta Pixel or Google Ads tracking in the reviewed source code; any production deployment is subject to a separate scan. 4. Why we process personal data, our lawful bases and who receives it Account creation, eligibility and security. We use your email address, account identifiers, password credentials and age-eligibility information to create and manage your account and provide secure access to Trippbo. The usual legal basis is performance of our contract with you (Article 6(1)(b) GDPR). For prevention of account abuse, security monitoring and fraud protection, we may also rely on our legitimate interests (Article 6(1)(f)), subject to an appropriate balancing assessment. Relevant data may be accessible to authorised Trippbo personnel and our hosting and technical service providers. We generally keep account information for the duration of the account, with limited exceptions for legally justified records and the time needed to complete deletion. Social profiles, photographs, trips and community functions. We process profile information, photographs, videos, saved travel memories, trips, comments, reactions and following relationships to provide the features you choose to use. This is ordinarily necessary to perform our contract with you (Article 6(1)(b)). Content may be seen by other registered users only in accordance with the visibility settings described in Section 5. Our hosting and storage providers process the information as necessary to run these features. Social content is generally retained until you delete it or close your account, except where a specific legal reason requires limited continued retention. Reports, moderation, appeals and platform integrity. We process content reports, relevant content and account details, moderation decisions, reasons, notifications and appeals to keep the community safe and enforce applicable platform rules. The basis may be a legal obligation (Article 6(1)(c)) where one applies, or our legitimate interests (Article 6(1)(f)) in preventing misuse, protecting users and resolving disputes. Authorised moderators, service providers and legally competent authorities may receive information when necessary. We retain only the records needed for the applicable purpose, compliance or defence of claims. Hotel reservations and information about fellow guests. We use booking contact information, the names of all guests, children’s ages, selected hotel, travel dates, occupancy and reservation terms to arrange, confirm, change or cancel accommodation bookings and provide booking support. For the person making the booking, the main basis is performance of the booking contract (Article 6(1)(b)). Where another guest’s information is provided by the lead booker, the lawful basis must be assessed in the context of that processing and may include legitimate interests (Article 6(1)(f)), subject to the relevant protections and information duties. The necessary details are shared with third-party hotel reservation suppliers, booking distribution networks and the accommodation provider fulfilling the stay. Information is retained for the period necessary to provide the reservation and to satisfy applicable financial, legal and dispute-resolution requirements; it is minimised when the original purposes end. Payments, refunds, disputes and accounting. We use transaction references, the price, selected currency, billing information where required and transaction status to collect payments, process eligible refunds, respond to payment disputes and comply with accounting and tax duties. Depending on the specific processing, the lawful bases are contract performance (Article 6(1)(b)), legal obligations (Article 6(1)(c)) and legitimate interests for fraud and dispute management (Article 6(1)(f)). Relevant information may be shared with payment providers, financial institutions, authorised accounting service providers and competent authorities where legally required. Accounting source documents and required financial records are generally retained for seven years from the end of the relevant financial year; other payment data is retained only as long as legally justified. Technical operation and security. We may process session identifiers, essential device information, IP addresses where logged and security events to provide the service, authenticate users, identify misuse and resolve technical problems. Depending on the precise function, the basis may be contract performance, our legitimate interests in system security or a legal obligation. Information is accessible to authorised technical personnel and service providers who need it for these purposes. Cookie choices and consent records. We record privacy preferences and related decision information to respect users’ choices and, where applicable, demonstrate compliance with legal requirements. We rely on the appropriate legal basis for the particular record, including compliance with legal obligations or legitimate interests where justified. Records are available only to authorised personnel and relevant hosting providers. Preferences and consent records are retained for the period appropriate to their purpose. Our Cookie Policy explains the types of technologies and how choices can be changed. Support requests and privacy rights. We use the information contained in enquiries, support correspondence and requests to exercise privacy rights to respond, confirm identity where appropriate and keep an accountable record of how requests were handled. The basis is contract performance, legal obligation or legitimate interests, depending on the request. Access is limited to authorised support and compliance personnel and necessary service providers. We retain records for a justified period that reflects the request type and applicable legal duties. Optional analytics or marketing technologies. If Trippbo introduces optional measurement or advertising technologies, we will describe the actual purposes and recipients and obtain prior consent for device access where required by applicable law. The existence of a consent category does not mean that a particular tracking service is currently deployed. We do not currently send promotional email newsletters. Where we rely on legitimate interests, we consider the impact on your rights and freedoms. Where consent is the applicable legal basis, you may withdraw it without affecting processing lawfully carried out before withdrawal or processing supported by another valid legal basis. 5. Social visibility and privacy by default When created, photos, travel memories and trip information are Private by default. If you choose “Public”, they become accessible to other registered Trippbo users, not automatically to non-users. Additional privacy restrictions may apply where you choose them. Username, profile picture and city/country are initially visible to other signed-in users; bio is hidden by default. Available settings let you alter profile visibility. We do not use users’ Public-within-Trippbo images or stories in advertising outside Trippbo without a separate lawful arrangement. We do not currently offer user-to-user private messaging. Please check permissions before posting images of another person, especially a child. Technical tests are needed to verify that private-media URLs and API endpoints cannot be accessed without authorisation. 6. Children’s information and accounts aged 16–17 Only users aged 16 or older may register for Trippbo social functions. A person must be 18 or older to place a hotel booking under our Terms. A legally eligible adult may book accommodation for child guests; the current booking process collects their names and ages as needed by hotels. We process only information reasonably necessary for the travel purpose and apply particular care where minors’ data are involved. We do not knowingly permit social accounts for persons under 16. If we discover an underage account, we may investigate and take proportionate action in accordance with law. The Estonian age threshold for certain consent-based information-society processing is different from Trippbo’s own minimum registration age. Neither threshold removes separate duties to protect children. 7. Data about guests supplied by someone else If you are a fellow traveller rather than the main booker, we may obtain your name and, for children, age from the person making the booking; later updates may also come from a supplier or the hotel. We use those details only as necessary to arrange and support the reservation and satisfy applicable duties. Information required by Article 14 GDPR will be provided where relevant, within the applicable time or subject to an actual lawful exception. The lead booker is asked to inform guests about booking arrangements and this Policy. 8. Sharing, suppliers and processors Infrastructure: HostUp operates the principal hosting and storage infrastructure stated to be in Sweden (EU); Trippbo uses PostgreSQL, NestJS and S3-compatible object storage in its stack. Internal application architecture alone does not identify additional sub-processors or a company’s GDPR role. Hotel bookings: booking details are shared, to the extent necessary, with third-party hotel reservation suppliers and distribution networks, and with the hotel or accommodation provider fulfilling the stay. Such information is used to arrange or confirm reservations, manage changes, cancellations and refunds, and provide support. Recipient roles as controllers or processors vary according to their contractual and legal responsibilities. We maintain records of actual recipients and provide recipient identities in response to valid access requests to the extent required by applicable data protection law. Payment: Stripe processes payment transactions and may act as a processor for some operations and an independent controller for others under the applicable service documents. Banks/card schemes may also receive information as required to execute or dispute a transaction. Other integrations: the technical team identified use of map and font services, which may receive technical request data depending on how they load. No other recipient or advertising vendor is asserted to be in use without validation. We also disclose personal data where a legal obligation requires it, or where reasonably necessary for legal proceedings or to protect against fraud, subject to the relevant lawful basis and safeguards. 9. Transfers outside the EEA Our primary hosting is located in Sweden. Nevertheless, accommodation bookings in countries outside the EEA may require sending guests’ information to the booking supplier, overseas hotel or service partner. Stripe or other providers may process information internationally according to their service arrangements. Where Chapter V GDPR applies, we use an appropriate EU adequacy decision, the relevant Standard Contractual Clauses and any necessary supplementary safeguards or another valid mechanism. You can request information about the safeguards relevant to your transaction at info@trippbo.com. 10. Storage periods, deletion and backups Social-account data, associated posts, comments, memories, interactions and media are scheduled for removal when you delete the account, subject to necessary processing steps, applicable rights of others and specific legal retention duties. The media-deletion mechanism uses a retry queue; deletion may not be instantaneous for every stored file. Your data export is available in JSON for supported structured account data; images and videos are not embedded as binary copies in the export. You can contact us to request access to the media as part of your GDPR rights where applicable. Accounting source documents and required financial records are retained for seven years from the end of the financial year in which the relevant record was entered, subject to any longer duty or lawful claim hold applicable to specific records. Do not assume that every field of every historical booking needs to remain identifiable for seven years; we minimise information where possible. Other retention periods are determined by purpose, security needs, legal duties and limitation periods and must be specified in an internal schedule. At the date of this draft, Trippbo has confirmed that there is no operating backup system. This is an operational risk identified for remediation and does not promise any backup-based recovery. Any future backup programme must state its locations, retention and deletion-on-restore process before these descriptions are updated. 11. Your rights and how to exercise them Subject to legal conditions and exceptions, you may request access, rectification, erasure, restriction, objection, portability of qualifying data and withdrawal of consent. You may lodge a complaint with a competent supervisory authority, including the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). Contact info@trippbo.com or use available in-account rights request tools, including Download My Data and Data Deletion Requests. We generally respond within one month, subject to a lawful extension or verification requirement. Account deletion does not automatically erase booking and tax records that must lawfully remain. 12. Cookies and local storage We use essential session technologies and certain user-preference storage, including settings that remember your cookie choices and certain website preferences. Optional analytics and marketing categories are disabled by default unless activated with valid consent. Users can open Cookie Settings from the footer to change their choices. Local-storage keys are not necessarily browser cookies, but device storage/access rules may still be relevant. See https://social.trippbo.com/cookies/. 13. Security, incidents and automated decisions We use role-based access controls, technical security controls and limited-purpose links for some private media, alongside logging and monitoring designed to detect misuse. No technical system is risk-free. We assess personal-data incidents and notify authorities or affected persons where the GDPR requires. We do not make a verified claim that decisions carrying legal or similarly significant effects are made solely by automation; Stripe and other providers may perform fraud detection under their own service arrangements. 14. Changes and contact We will update this Policy when processing or law materially changes, showing an accurate effective date and providing additional notice where legally required. Requests and questions: info@trippbo.com. Relevant policies: https://social.trippbo.com/terms/ and https://social.trippbo.com/cookies/.