Privacy Policy

Last updated: [DATE]

Effective date: [DATE]

Note for development: This is a comprehensive draft. It MUST be reviewed by a qualified lawyer with GDPR/data privacy expertise before publication. Do not launch without legal sign-off.

1. Who We Are

Travajo ("we", "us", "our") is a community platform for digital nomads and working travelers, operated by [COMPANY NAME], [REGISTERED ADDRESS].

Data Controller: [COMPANY NAME / YOUR NAME] Contact: privacy@travajo.com

2. What Data We Collect

2.1 Data You Provide

| Data | When Collected | Purpose | |------|---------------|---------| | Email address | Registration | Account management, notifications, password recovery | | Username | Registration | Public identity on the platform | | Password (hashed) | Registration | Authentication (we never store plaintext passwords) | | Profile information (bio, skills, social links, website) | Profile setup (optional) | Community interaction, displayed on profile | | Avatar image | Profile setup (optional) | Visual identity. EXIF/metadata stripped before storage | | Travel status | User-initiated | Community feature ("who's here") | | Check-in data (city, dates) | User-initiated (opt-in) | Presence features, travel history on profile | | Posts, comments, reactions | Community participation | Core platform functionality | | Reports | User-initiated | Content moderation | | Payment information | Premium/business signup | Processed by Stripe — we never store card details |

2.2 Data We Collect Automatically

| Data | Purpose | Retention | |------|---------|-----------| | IP address | Security, rate limiting, abuse prevention | 90 days, then deleted | | User-agent string | Security, device compatibility | 90 days | | Pages visited / feature usage | Platform improvement, analytics | Aggregated, anonymized | | Cookies (session, preferences) | Authentication, settings persistence | See Cookie section |

2.3 Data We Do NOT Collect

Real name (not required, not stored separately from username)
Phone number
Government ID / passport details
Precise GPS location (check-ins are city-level only, user-initiated)
Contacts or address book
Background location tracking
Biometric data

3. How We Use Your Data

| Purpose | Legal Basis (GDPR) | |---------|-------------------| | Providing the platform and its features | Contract performance | | Account management and authentication | Contract performance | | Sending essential notifications (security, account changes) | Contract performance | | Content moderation and safety | Legitimate interest | | Preventing abuse, fraud, and spam | Legitimate interest | | Responding to legal requests | Legal obligation | | Sending optional notifications (new posts, replies) | Consent (opt-in) | | Marketing emails | Consent (opt-in, can unsubscribe) | | Analytics and platform improvement | Legitimate interest (anonymized/aggregated) | | Displaying advertising | Legitimate interest |

We never:

Sell your personal data to third parties
Share your email address with other users
Use your data for profiling or automated decision-making that affects your rights
Share individual user data with advertisers (only aggregated, anonymized insights)

4. Data Sharing

We share your data only in these circumstances:

| Recipient | What Data | Why | |-----------|----------|-----| | Other users | Username, avatar, bio, posts, comments, travel status (based on your privacy settings) | Core platform functionality | | Community moderators | Username, posts/comments in their city, reports | Content moderation | | Platform administrators | Account data, moderation history | Platform management | | Stripe (payment processor) | Email, payment details | Subscription billing | | Cloudflare (CDN/security) | IP address, request data | DDoS protection, performance | | Cloudflare R2 (storage) | Uploaded media files | Media hosting | | Email provider (Postmark/SES) | Email address, notification content | Sending emails | | Error tracking (Sentry) | Error context (may include anonymized user actions) | Bug fixing | | Law enforcement | As required by valid legal process | Legal obligation |

We do NOT share data with:

Data brokers
Advertising networks (Google Ads targeting is contextual, based on page content, not user profiles)
Social media platforms (unless you explicitly share content)

5. Your Privacy Controls

5.1 Profile Privacy

You control the visibility of your data:

| Setting | Options | Default | |---------|---------|---------| | Check-in / presence | Nobody, Verified Nomads, All Members, Public | Verified Nomads | | Travel history | Private, Verified Nomads, All Members, Public | Private | | Bio / skills / social links | Public, Private | Public | | Post history | Always public (community content) | Public | | Email | Never displayed to other users | Private (enforced) |

5.2 Notification Preferences

You can control which notifications you receive (email, in-app) and opt out of non-essential communications at any time.

5.3 Blocking

You can block other users, which prevents them from seeing your profile, posts, and presence data.

6. Your Rights (GDPR and Equivalent)

If you are in the EU/EEA/UK, or a jurisdiction with equivalent data protection laws, you have the right to:

| Right | How to Exercise | |-------|----------------| | Access — get a copy of your data | Settings > Export Data, or email privacy@travajo.com | | Rectification — correct inaccurate data | Edit your profile, or email privacy@travajo.com | | Erasure ("right to be forgotten") | Settings > Delete Account, or email privacy@travajo.com | | Restriction — limit processing of your data | Email privacy@travajo.com | | Portability — receive your data in machine-readable format | Settings > Export Data (JSON format) | | Objection — object to processing based on legitimate interest | Email privacy@travajo.com | | Withdraw consent — for consent-based processing | Notification settings, unsubscribe links, or email privacy@travajo.com |

We will respond to rights requests within 30 days.

Account Deletion Process

When you delete your account:

Immediately: Account deactivated, profile hidden, removed from presence lists
After 30-day cooling-off period: Personal data permanently deleted (email, password hash, IP logs, profile data, avatar)
Content handling: Posts and comments are anonymized (author shown as "[Deleted]"), not deleted, to preserve community discussions
Exceptions: Data required for legal compliance or ongoing disputes may be retained as required by law

7. Data Security

We protect your data through:

Encryption in transit (HTTPS/TLS on all connections)
Encryption at rest for sensitive data (passwords hashed with bcrypt)
Access controls (role-based, principle of least privilege)
Regular security updates and patching
Image EXIF/metadata stripping before storage (protects GPS location in photos)
Rate limiting and abuse prevention
Immutable audit logs for moderation actions

No system is 100% secure. If we discover a data breach affecting your personal data, we will notify you and relevant authorities within 72 hours as required by GDPR.

8. Cookies

Essential Cookies (Always Active)

| Cookie | Purpose | Duration | |--------|---------|----------| | Session cookie | Authentication, CSRF protection | Browser session | | Preferences | UI settings (mod mode, theme) | 1 year |

Optional Cookies (Consent Required)

| Cookie | Purpose | Duration | |--------|---------|----------| | Analytics | Anonymous usage statistics | 1 year | | Advertising (Google Ads) | Contextual ad serving | Varies |

You can manage cookie preferences through our cookie consent banner. Essential cookies cannot be disabled as they are required for the Platform to function.

9. Data Retention

| Data Type | Retention Period | |-----------|-----------------| | Account data (active users) | Duration of account | | Account data (deleted users) | 30 days after deletion request, then permanently deleted | | Posts and comments (deleted users) | Anonymized and retained indefinitely (community content) | | IP addresses | 90 days | | Moderation logs | Retained indefinitely (legal compliance, immutable audit trail) | | Law enforcement request records | 7 years | | Payment records | As required by tax/financial law |

10. International Data Transfers

Your data may be processed in countries outside your home country. We ensure appropriate safeguards through:

Standard Contractual Clauses (EU-approved)
Processing in countries with adequate data protection (as determined by the EU Commission)
Contractual obligations on service providers

11. Children

Travajo is not intended for users under 18. We do not knowingly collect data from minors. If we discover that a user is under 18, we will terminate their account and delete their data.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-platform notification at least 30 days in advance. Continued use after changes constitutes acceptance.

13. Contact & Complaints

Privacy questions: privacy@travajo.com Data protection complaints: If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority.

UK: Information Commissioner's Office (ICO) — ico.org.uk
EU: Your national Data Protection Authority
Australia: Office of the Australian Information Commissioner — oaic.gov.au