Locals.org, Inc.
Privacy Policy

Locals.org, Inc.
Privacy Policy

Locals.org, Inc.
Privacy Policy

Last updated: Apr 12, 2022

Effective date: Apr 22, 2022

This privacy policy explains how we, Locals.org, Inc. of 8 The Green, Suite #10745, Dover, DE 19901, USA (“Locals.org”, “we”, “us”, “our”) process your personal information (“you”, “your”) when you use our website, app or other services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By clicking the button “Continue” in our mobile application Locals.org (“App”) or by using our Website located at www.locals.org (“Website”), you acknowledge and (if applicable) agree to the information set out in the following Privacy Policy.

Please do not use our services unless you are 18 years old or over.

Please note:

  • Individuals in the European Economic Area (EEA) and the UK should also read our section about “Your EEA & UK Data Privacy Rights”.

  • Individuals in California should also read our section about “Your California Data Privacy Rights”.

  • Individuals in Nevada should also read our section about “Your Nevada Data Privacy Rights”.

1. Who does this privacy policy apply to?

This policy applies to:

  • our Website and App users;

  • our hosts who post experiences in our service; and

  • persons who interact with us, when you call us, chat with us, or email us.

This policy applies to you whether you act in your personal capacity or as an employee or agent of an organization.

2. What types of information do we collect?

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.

We will process the following information which may be considered personal information:

  • Your user details when you sign up as a user of our services, such as your name, surname, date of birth, age, gender, your story, your city or place, your occupation, your image, and contact details such as your telephone number and email address.

  • Transaction information such as your donations in our app, including date of donation / purchase, currency, amount, payment type and the last four digits of your card number.

  • When accessing our services, your device and browser will automatically provide unique information such as account ID, mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, operating system, browser type, time zone setting, location and date and time of access.

  • Our systems may record usage data about how you navigate and engage with our services, use our features, download materials, security logs will be kept, online activity data such as clickstream data with URLs visited previously, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our services.

  • Some of our features rely on real-time information about the location of your device where you enabled the functionality on your device.

  • Information that you provide about your interests and occupation or that we otherwise collect about your preferences and interests known, observed or inferred.

  • Third party data about you such as your interaction with our posts and content and ‘likes’ on social media platforms, such as Twitter and Instagram, TikTok, profile information, preferences and interests from advertising and analytics partners, information from our suppliers, and information from other users about you.

  • When we send you emails or other communications, we may collect technical interaction information, such as open rates and if you clicked on any content.

  • When you contact or visit us, we may process the details of your request, communications, complaints, or other interaction.

  • Your phone contact list so that you can choose to invite your phone contacts to join the App or see which phone contacts are already on the App.

  • If you are the phone contact of an App user we may use your phone number to invite you to use the App but only if the existing registered App user requests that we do this.

  • Your Instagram ID and your Instagram photo-stream, if you choose to link your Locals account to your Instagram account.

  • Sensitive personal information, if you choose to provide it, for example in your bio. This could be information such as, for example, about your political opinions, religious or philosophical beliefs, health or sexual orientation. If you choose to use our App and to share sensitive personal information on it (e.g., as part of your biography, in a message, or event invite), this will constitute your explicit consent to our processing that information. You will be free to edit or remove such information at any time if you no longer wish to share such information.

Our social media community is based on transparency and each user must share some basic information about themselves and their image before joining. We will carry out a basic check of your details before approving your application to join. We will be unable to unlock all features of our app, provide some of our services or respond to your enquiries unless you provide the required personal information.

3. Data accuracy

We will rely on the information provided by you as accurate, complete, and up to date, and we would be grateful if you could inform us of any changes.

4. What information do we collect and why?

Generally, we will use your personal information to (i) provide our services and enable you to use our service features, (ii) respond to your queries, (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of our services; and (v) comply with the law.

* If you are an individual in the EEA or the UK, we have to inform you about the “legal ground” for us to use your “personal data”. This will typically be the performance of our contract with you (based on our Terms of Use) or our legitimate interest to use your personal data to ensure that our services are provided properly, efficiently and securely, as is further explained in the table below.

Where we rely on legitimate interests as the legal basis for processing personal data, we have considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose data are being processed and concluded that the processing is, on balance, fair.

PPurpose

Personal information

Legal ground for processing* (for individuals in the EEA and UK only)

To assist and contact you in relation to your enquiry or to send you information which you have requested about our services.

  • contact details

  • details of your request

Necessary for our legitimate interest in responding to queries, maintaining business relationships and administering our business or to take necessary steps at your request prior to entering into a contract with you.

To register you as a service user when you sign up for our services and to enable you to use our services and service functionalities.

  • user details

  • contact details

  • device & browser data

  • usage data

  • phone contact list

Necessary for the performance of our contract with you and for our legitimate interest in running our social media community.

To share information about you with our social media community, such as your username, story, image, bids and other user information which is visible by all members of our social media community.

  • user details

  • transaction information

  • phone contact list

Necessary for the performance of our contract with you and for our legitimate interest in running our social media community.

To enable you to make purchases or donations through our App.

  • Date of purchase or donation

  • Currency of transaction

  • Transaction value

  • Payment type

  • The last four digits of your card number

  • Recipients of donations made through the App

Necessary for our legitimate interest in facilitating our services.

To enable you to operate your account as a host and attendee and to provide offers and interact with our social media community.

  • user details

  • contact details

  • device & browser data

  • usage data

  • transaction information

Necessary for the performance of our contract with you and for our legitimate interest in providing meaningful features to our hosts.

To fulfil your requests and send you service communications and notifications about matters relevant to your use of our services and your engagement with us, such as information about offers you might be interested in, targeted content, confirmations of donations, details of events, surveys, changes in our terms, etc.

  • user details

  • contact details

  • preferences and interests

  • location

  • device & browser data

  • usage data

Service communications are necessary for the performance of our contract with you. Other notifications are necessary for our legitimate interest in satisfying your requests, facilitating our services and organising related business activities. Push notifications are generally subject to your consent given on your device.

To send you promotional information through various marketing channels including post, email, social media, telephone, SMS, etc. about our services and our organisation, reviewing and optimising campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.


For example, we use your contact details to display relevant ads through Instagram or other social media platforms. Social media and advertising providers may use their own information about you to help us make our ads most relevant.

  • user details

  • contact details

  • preferences and interests

  • location

  • device & browser data

  • usage data

  • email interaction data

  • third party data

Some of our promotions are necessary for the performance of our contract with you. We will also use your information as is necessary for our legitimate interest in understanding your interests for direct marketing purposes from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics.

We will obtain your consent and provide you with an “opt-out” option where required by law. For example, your consent will be required to place cookies or similar technologies on your device or to read information on your device.

To improve and develop our services, including to:

  • obtain feedback;

  • record likes and preferences;

  • conduct statistical analysis

  • use Google Analytics to understand the demographics of our users;

  • make services and features more relevant;

  • improve user experience; and

  • work with third parties and evaluate data to improve and develop our services.

  • usage data

  • device & browser data

  • aggregated data

Necessary for our legitimate interest in delivering our services properly, efficiently and understanding our users’ needs. We will use cookies and similar technologies if you provided your consent.

To ensure proper administration of our business, including to:

  • keep appropriate records about how our services are used;

  • resolve complaints;

  • conduct troubleshooting;

  • manage our business relationships and identify opportunities;

  • register interactions with our communications, such as emails;

  • enforce our terms; and

  • debt collection.

  • user details

  • contact details

  • usage data

  • details of your requests

  • aggregated data

Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and necessary for compliance with a legal obligation to which we are subject.

To engage our third party service providers who may process your information on our behalf to facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, payments, plugins, communications, accounting, security and others.

  • all information necessary to enable the relevant service

Some activities are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring the proper operation of our services.

To monitor our networks, Website, App and systems for suspicious activities, test and audit our systems and deploy appropriate security measures.

  • usage data

  • device & browser data

  • security logs

Necessary for our legitimate interest to ensure the security of our organisation, people and services and necessary for compliance with a legal obligation to which we are subject.

To monitor operations, user activity and networks for fraud prevention and crime detection purposes, including information from third parties who may help us verify your identity or alert us about suspicious activities. Upon sign up, we may ask for your telephone number to send you a verification code.

  • user details

  • contact details

  • usage data

  • browser & device data

  • interaction data

  • transaction information

Necessary for our legitimate interest in detecting and preventing fraud and illegal conduct and necessary for compliance with a legal obligation to which we are subject.

To share information with our group companies.

  • any necessary information on a proportionate and lawful basis

Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies.

To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business.

  • data necessary in connection with the event

Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.

To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.


To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.

  • Any information subject to mandatory processing or disclosure, where this is proportionate and lawful

Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims, to fulfil our duty of care owed to third parties or, where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws.

5. No processing of payment details

We will not receive or store any of your payment details, this is fully handled by the relevant payment service provider. If/when you make any purchases in a Locals store, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details or personal data related to the payment. We only keep the data concerning transaction dates, currencies, value, the last four digits of your card number and the subject of the transaction.

6. Cookies and similar technologies

Please, read our Cookie Notice on how we use cookies and similar technologies.

7. Sharing your information

We will generally not share your information except with (i) our third party service providers and advisors who may process personal information on our behalf, (ii) our advertising, marketing and analytics partners, as explained above, (iii) our group companies for the purposes set out above, (iv) persons or authorities where we are compelled by law, (v) to the relevant entity in case of a merger, acquisition or collaboration, and (vi) other third parties where you have provided your consent. Your stories may be shared between Locals and Instagram if authorised by you. From time to time Locals may offer the functionality for you to choose to synchronise your Locals events with third party event platforms and relevant personal information may be shared with such third party event platforms in this case. We share analytical data with Amplitude, Appsflyer, Segment, Firebase.

8. Third parties may process your information

Our services may contain links to other websites, third party services, such as Twitter, Instagram, TikTok and plugins. You should check the privacy statements of these third party providers before you use them as we are not responsible for how they may process your personal information.

9. How long is your information kept?

We will keep your personal information for as long as is necessary for the purposes listed above or longer if required by law.

After the retention period, your personal information will either be securely deleted or anonymised and it may be used for analytical purposes. You must back up your data if you wish to keep it for longer.

10. How do we secure your information?

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of the personal information we hold. We also seek to ensure our third-party service providers do the same.

We will endeavour to use the least amount of personal information as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate.

Our staff will access your personal information on a “need to know” basis.

11. Where is your information processed?

We may transfer your personal information to our group companies, suppliers and other third parties in countries different to your country of residence.

In addition, data may be transferred to our subsidiaries or processors in third countries or subcontractors of our processors in third countries.

Some of our group companies and the third parties described in this Privacy Policy that provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. If you are using Locals in the UK or EEA, in the event your personal information is transferred, stored or processed outside of the UK or EEA, we will ensure – if and as required by applicable laws - that any such transfer meets the requirements of the GDPR or UK GDPR (as applicable), or that the transfer is otherwise subject to prescribed safeguards such as approved ‘Standard Contractual Clauses’. We will take all steps reasonably necessary to ensure that your personal information is treated securely and, as applicable, in accordance with this Privacy Policy, GDPR, UK GDPR and Data Protection Act 2018. You can obtain more details of the protection given to your personal data when it is transferred outside the EEA or the UK by contacting us using the details below.

12. Opt-out

If you would like us to stop sending you marketing communications and to process your personal information for direct marketing purposes, please let us know using the contact details below.

You can request to stop receiving our marketing communications at any time by clicking on the unsubscribe link at the bottom of each marketing message.

13. Contact us

Please email us if you have any queries or concerns about how we use your personal information. We will try to resolve your query without undue delay.

E-mail: privacy@locals.org

14. Updates

If we make any changes to our policy you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.

If you do not agree with the changes, please do not continue to use our website or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.

15. Your California data privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA Privacy Notice for California Residents.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our SERVICE that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Privacy Officer.

15. Your California data privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA Privacy Notice for California Residents.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our SERVICE that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Privacy Officer.

16. Your Nevada data privacy rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to our Privacy Officer. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

17. Your EEA & UK data privacy rights

This section provides further disclosures and describes the rights in relation to your personal data that you may have under The General Data Protection Regulation (“GDPR”) if you are an individual in the EEA or the UK General Data Protection Regulation (“UK GDPR” if you are an individual in the UK.

A. Personal data
“Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.

B. How do we process your information and why?
We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above.

We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.

C. Data subject rights
Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:

  • Right to information about matters set out in this policy. You may also contact us for further details about our retention policy and international data transfers.

  • Right to make an access request to receive copies of personal data.

  • Right to rectification of any inaccurate or incomplete personal data.

  • Right to withdraw consent previously provided, without affecting the lawfulness of our processing based on consent before its withdrawal.

  • Right to object to our processing of personal data for direct marketing purposes, or that is based on our legitimate interests, and any automated decision-making and profiling.

  • Right to erasure of personal data, in certain circumstances.

  • Restriction on the processing of personal data in certain circumstances.

  • Right to data portability from one service provider to another, where applicable.

  • Right to lodge a complaint with your country’s supervisory authority, such as the Information Commissioner’s Office in the UK.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter. You can exercise these rights directly with us by submitting a request at privacy@locals.org. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

C. Data retention
Generally, we will keep your personal information for 6 years from collection but often earlier deletion will be mandated by our retention policy. We delete most of your information after you delete your account, unless we are required to keep it for longer for legal purposes. Your communication history with others (including photographs posted in the chat and comments functions) may be retained but on an anonymous basis if reasonably possible. Some data may be retained in analytics systems for data analytics purposes. Please get in touch for more information.

The discovery app of activities and communities full of inspiring, mindful and entrepreneurial people.

© 2021–2022 LOCALS LTD, all rights reserved.

The discovery app of activities and communities full of inspiring, mindful and entrepreneurial people.

© 2021–2022 LOCALS LTD, all rights reserved.

The discovery app of activities and communities full of inspiring, mindful and entrepreneurial people.

© 2021–2022 LOCALS LTD, all rights reserved.

The discovery app of activities and communities full of inspiring, mindful and entrepreneurial people.

© 2021–2022 LOCALS LTD, all rights reserved.

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