TERMS AND CONDITIONS

Last updated: 14.02.2022

Effective date: 14.02.2022

Thank you for using Citory!

These terms of use (“Terms of Use”, “Terms & Conditions”, “Terms” or “T&C”) outline the rules for the use of Citory’s all services, including its Website located at https://citory.co. 

By accessing this Website we assume you accept these Terms. Do not continue to use Citory if you do not accept all of the Terms stated on this page.

Applicability of the Terms of Use

Any use of Citory (“we”, “us” or “our”), its Website located at https://citory.co (“Citory”, “Site”, “Website” or “citory.co”), Citory’s apps or Citory’s other services, as a website visitor, a Guest or a Local, constitutes an agreement to all terms and conditions and warrants that Users understand, agree to and accept all terms and conditions contained here.

Locals on the platform and Guests using the platform are in compliance with the Citory Code of Conduct, part of these Terms.

Definitions

Citory: The entity and its services including the Website located at https://citory.co.

Users: The persons using Citory, Website, Citory’s apps or Citory’s other services as a website visitor, Guest or Local.

Locals: The suppliers of Citory offerings. Citory Locals are defined as such when their profile appears online on the platform and they can receive bookings via Citory.

Guests: The customers of Citory, using the platform to make a reservation or communicate with Locals.

Reservations (for Guests)

All reservations made via Citory (on Website or app) are automatically transferred to the Local requested.

A reservation is only valid when confirmed by Citory via email.

Guests making a reservation with Citory understand our cancellation policy.

Reservations (for Locals)

All reservations made by Guests via Citory engage the Locals to provide the service booked. 

Locals understand that cancellations and transfers have a negative impact on Guests satisfaction and will affect their performance on the platform.

Citory Locals are aware of our cancellation policy.

Payments

When making a reservation, Guests have to pay the full amount in advance. In this case Guests pay us the full amount stated on the Website which is paid to the Local, within 72 hours after the reserved event has taken place in a satisfactory manner, while deducting the Citory fee payable by the Local. As a Guest no additional payments are needed; when the reservation is confirmed by us, all payments are done.

Citory will facilitate the payment as a commercial agent on behalf of the Local. Therefore, by accepting these Terms, the Local enters into an agreement with Citory determining that Citory is authorized to negotiate or conclude the sale of the services provided by the Local on behalf of the Local.

Once Guests have made the payment, they have discharged their payment obligation, i.e. there is final settlement of the Local’s claim on Guest.

Applicable taxes

We provide services to our Locals and therefore we treat the Local as our legal customer. We will invoice the Local. On this invoice we will state our details, any applicable taxes and details of the service(s) provided by the Local to the Guest. As a Local you are responsible for providing the Guest with any documentation and/or invoice needed in compliance with the applicable tax law(s).

It’s a Local’s sole responsibility to determine which taxes are applicable and required to comply with the applicable local tax law and pay any corresponding taxes. These taxes can include value added taxes, surcharges, sales taxes, personal or corporate income taxes imposed or any other taxes which are levied upon reservations made through our Website or the payment thereof. Locals represent and warrant that they will pay such taxes in time and in compliance with the applicable tax law.

Proprietary Material

Citory content may not be used or copied without explicit authorization from Citory. All text, graphics, editorial content, data, formatting, graphs, designs, HTML, look and feel, photographs, music, sounds, images, software, videos, designs, typefaces and other content (collectively “Proprietary Material”) on this Website and on the apps of Citory is owned by Citory, or is used with the owner’s permission. This Proprietary Material is protected in all forms, media and technologies. Users may not copy, download, use, redesign, reconfigure, or retransmit anything from this Website and from the apps of Citory without Citory’s prior written permission.

Quality of information

While we do our utmost best to verify the quality of the events hosted by our Locals, we cannot guarantee these are flawless and neither can we guarantee that all content on our Website is without errors. In the event of misleading representation or misconduct on our Website or in the framework of the events held by Locals through our Website and/or services, we may decide, in our sole discretion, to credit the Guest with a refund for the reservation amount paid or part thereof and charge the Local with this amount. No action of us may be construed as accepting any liability other than as mentioned herein. 

When rendering our service, the information we disclose is based on the information provided to us by the Locals. Although we will use reasonable skill and care in performing our service and verify (most of) the Locals we cannot guarantee that all information is accurate, complete and/or correct. Each Local remains responsible at all times for the accuracy, completeness and correctness of the (descriptive) information displayed on our platform.

Therefore, use your own best judgment when using any of the services provided by our Locals. Notwithstanding the foregoing, we, including without limitation any content, data and any information related hereto, is provided on an “AS IS” and “AS AVAILABLE” basis, without any warranties of any kind, express or implied, including but not limited to warranties of title or non-infringement or implied warranties of use, merchantability or fitness for a particular purpose or use.

Warranties

Citory does not warrant that this Website and/or our services will be uninterrupted or error-free. It may correct, modify, amend, enhance, improve and make any other changes to the Website and services at any time or discontinue displaying or providing any content or features without a notice to any user.

Disclaimer

We do our very best to make sure all the information we provide you is 100% correct. However, as we are human beings too, errors are made. We hereby disclaim all warranties and conditions with regard to the use of our Website and/or services, including the availability, reliability, or quality of our Website and services, the events distributed through us, including the nature and quality of the events, and is not and shall not be responsible for any error, fault or mistake of any and all content and information received through our users , including by Locals or Guests. We do not endorse any entity, product or service mentioned in any user generated content available on our Website.

Liability

Citory’s responsibility is limited to facilitating the availability of our Website, application and services. The participation in any of the events hosted by the Locals is at your own risk. Citory’s liability for damages shall be limited to the amount paid by Guests. Except as provided herein, in no event shall Citory be liable for any indirect, special, incidental or consequential damages of any kind, whether in an action of negligence or other tortuous actions resulting from or arising out of participation in any of the events hosted by the Locals.

Indemnity

By using any service of Citory, including using this Website, you indemnify and hold harmless Citory and its directors, officers, agents, employees, subsidiaries, and affiliates from any actions, claims, losses, damages, liabilities and expenses including legal fees arising out of your use of this Website or your violation of these Terms.

Severability

If any of the provisions of the Terms are found to be inconsistent or invalid, all other provisions will not be affected and the rest of the Terms will continue to be valid.

Modification

The Terms may change over time. We will notify you before any material changes take effect so that you have time to review the changes. If you disagree with the revised Terms, you may terminate the Terms immediately as provided in these Terms. Your continued access to or use of Citory will constitute acceptance of the revised Terms.

Termination

You may terminate the Terms at any time by sending us an email or by deleting your account. Citory may terminate the Terms and your account for any reason by giving you 30 days notice via email or using any other contact information you have provided for your account. Citory may also terminate the Terms immediately and without notice and stop providing access to Citory if you breach these Terms, our other policies, the applicable laws, or we reasonably believe termination is necessary to protect Citory, its Users, or third parties. If your account has been inactive for more than one year, we may terminate your account without prior notice.

Issues and Complaints

We’ll assist you in case of issues or complaints where possible. In case of a complaint about, or issue with the platform, app or services, please contact Citory to resolve the problem. In case of a complaint about an event you agree to contact Citory within 1 day after the complaint has arisen and you agree to cooperate with and assist Citory in good faith. You also agree to provide Citory with such information and take such actions as may be reasonably requested by Citory. As a Local you agree that in case of a no show or dissatisfactory deviations in the event caused by you, the Guest will be refunded and you won’t receive payment. As a Guest you understand that in case of a no show or no completion of/interruptions during the event caused by you, you as a Guest are responsible for any damages up to the amount paid.

In case of any damage claims or other complaints related to the event exceeding the amount paid, Citory will mediate in finding a reasonable solution between Guest and Local.

Any claim or complaint against Citory in respect of the service must be promptly submitted, but in any event within 14 days after the reserved event has taken place. Any claim or complaint that is submitted after the 14 days period, may be rejected and the claimant shall forfeit his/her right to any (damage or cost) compensation.

Governing Law and Jurisdiction

To the extent permitted by law, these Terms and the provision of our services shall be governed by and construed in accordance with Turkish law and any and all dispute arising out of these Terms and our services shall exclusively be submitted to the competent Court in Ankara, Turkey.

Code of Conduct for Citory Locals

Citory Locals are expected to adhere to and respect the Citory Locals Code of Conduct. The Citory Locals Code of Conduct contains quality standards as well as basic requirements for hosting.

1. Quality Standards

Local quality at Citory is defined by the following standards:

Passion

Passionate Locals are the heart of Citory. Our promise to Guests is to offer them a unique experience, led by Locals that are passionate about the topic of the experience, have a personal connection to it, and deep knowledge of it.

As a Local, you are expected to communicate this passion with your Guests:

• Know your topics in depth, extra research and preparation work can make a world of difference.
• Be fully present during the experience, for example avoid getting distracted by your mobile phone.
• Be open and reactive to the feedback you receive from Guests and Citory.

Authenticity

Citory Locals want to share the real soul of their city, offering an authentic experience to Guests.

Provide an authentic experience by sharing a unique perspective, unveiling secret gems, providing unique access to your Guests. Remember that Guests booked you because they are looking to experience something they could not do by themselves!

Connection

Connecting cultures and people is our mission. Connect with your Guests at all the steps of their Citory journey.

Before meeting the Guests: 

• Be available to reassure your Guests and answer their questions. They might need some extra information, or simply reassurance that they picked the right Local and experience.
• If any changes are necessary on the route or plan for the experience, communicate it clearly to your Guests. Make sure that they are comfortable with the changes. 

During the experience:

• Pay attention to your Guests’ needs: specific groups (elderly, children, persons with disabilities) may need special care.
• Face your Guests and make pauses when giving an explanation to make sure everyone in the group feels involved and engaged.
• Be mindful of cultural differences, remember that different people may expect different behaviors and have different sensitivities. Remain curious and keep an open mind. 

After the experience:

• Following up on the experience and sharing extra information and tips with the Guests can go a long way!

Not meeting these standards will result in an incompatibility to work as a Citory Local. If you need any extra support or coaching, we are here for you! Get in touch with our team to receive help & resources. 

1. Hosting requirements

The following requirements are minimum standards that Locals must fulfill to keep a Citory profile. Any breach of these requirements will result in a performance breach and may lead in your removal from the platform.

Professionalism

Locals are required to respect the following professional standards:

• Being available and reachable by both the Guests and Citory, in particular for any urgent or time sensitive issue, and around the time of a booking.
• Having an appropriate presentation and outfit, respecting hygiene standards.
• Communicating with Guests and Citory in a polite and respectful manner.
• Respecting the commitment that is a booking. Unforeseen situations can of course happen, but being late, canceling or not showing up to a booking without informing your Guests and without a valid reason is not acceptable.
• Avoiding any inappropriate behavior such as smoking during a tour.

Brand loyalty

Citory Locals represent the Citory community, and are therefore expected to respect the following limitations:

• Citory experiences should always be private. Unless specifically stated otherwise, or requested by Citory with the agreement of all parties, groups from different bookings cannot be mixed, and no other participants but the Guests are allowed to join.
• Experiences must always be led by the Local of the booking, Locals should never send another person to fill in for a booking.
• Locals must refrain from expressing negative feelings about Citory, or complaining about it or any of its parties in front of the Guests or on public platforms. All complaints and feedback should be addressed directly to the Citory team.
• Be mindful of your online presence and set your privacy settings accordingly. Keep in mind the Citory image when sharing your social profiles.
• Use the Citory platform genuinely to promote your profile and offer experiences to Guests but refrain from using the Citory platform to conduct other business with Guests (for example by trying to bypass the online booking system) or other Locals.
• Remain impartial and keep a service mind and a calm temper when interacting with Guests.
• Locals should not solicit tips and do not discuss remuneration with Guests.

Safety

Locals commit to maintaining high standards of safety and security when providing a service to Guests. The following standards apply:

• Citory Locals should always avoid unsafe situations and assess experiences for potential hazards or critical points. 
• Informing Guests of relevant safety procedures when necessary, keeping the relevant emergency numbers and being aware of the closest medical facilities is a must.
• Locals must never be intoxicated on an experience unless wine or beer tastings are included in the experience (for example, Wine & Tapas). In addition, Locals commit to never purchasing an alcoholic drink for a minor.
• Possession or use of illegal drugs on experiences will result in instant removal from Citory platform. 
• Emotional or intimate involvement with any Guest – whether real or perceived, and as assessed by Citory in its sole discretion, will lead to the instant removal from the platform. Citory Locals are in a position of trust and are expected to act accordingly at all times while on a tour.
  Locals should never enter Guests’ private rooms to avoid any possible misunderstandings or misinterpretations.

Code of Conduct for Citory Guests

Citory connects Guests to Locals around the world, offers genuine experiences and builds bridges between cultures.

To ensure the connections created are mutually beneficial and respectful, any usage of the Citory platform must be in line with our Code of Conduct by which users agree:

• To respect the professionalism of their Local

• To not behave in an offensive, aggressive, threatening, harassing, racist or xenophobic nature, or with sexual connotations, inciting violence, discrimination or hatred towards their Local and surrounding people

• To not to try to bypass the online booking system of the Platform and arrange a similar experience without booking it on the platform

• To not contact a Citory Local for a purpose other than:

• Arranging details of the booking for a Citory experience; 

• Arranging details of the meeting with the Local; 

• Asking for Local tips & advice

• To respect Local customs and rules & regulations

Citory Services to Guests

Citory is an online platform for Guests seeking to engage with Locals all over the world to offer them the most outstanding cultural and gastronomic experiences in a city. We are a marketplace where demand (Guests) meets supply (Locals).

Through our Website, Guests can book local experiences with Locals all over the world.

By making a reservation through our platform, Guests enter into a direct contractual relationship with the Local with whom they make a reservation. From the point when the booking is made, Citory acts solely as an intermediary between the Guest and the Local. Citory is not a party to any agreement between the Guest and the Local and is not liable for any (attributable) failure to perform or other damages arising out of the relationship between the Guest and the Local.

With every booking it is required that at least one person who is 18 years old or older is present during the experience.

Citory Services to Locals

Citory is an online platform for Locals seeking to engage with Guests from all over the world to offer them the most outstanding cultural and gastronomic experiences in a city. We are a marketplace where demand (Guests) meets supply (Locals).

Citory offers Locals the possibility to offer local experiences to Guests via the platform (Website and Citory apps) as well as through partnerships with other companies.

Citory promotes the Local’s profile as well as offerings and helps them succeed in their endeavor as a Citory Local.

Diversity, Equity and Inclusion

By facilitating access to different cultures and everything the world has to offer, we hope
to inspire people to learn, create equity in pay for Locals and increase awareness and empathy to spark positive change. This intention underpins everything we do.

We believe that celebrating the diversity of our Local community, all of our Guests, and our team will make the world a better place.

Contact

Please contact us if you have any questions or concerns from the contact information below:

info@citory.co

Privacy Policy

Last Updated: [14.02.2022] Effective Date: [14.02.2022] This Policy, while keeping legal and technical jargon to a minimum, describes our privacy practices in plain language to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information.

1. Who We Are

Citory (“we”, “us” or “our”) is an entity owning and operating the website located at https://citory.co (“Citory”, “Site”, “Website” or “citory.co”).

2. Where This Privacy Policy Applies

This Privacy Policy applies to websites (including the Website), apps, events and other services we operate as Citory. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services. Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy – not this Privacy Policy – applies.

3. Information We Collect

As of [14.02.2022] we only accept early application forms to create a waitlist of our future community of Guests and Locals. Therefore, as of  [14.02.2022] you can only fill in the waitlist forms on the Website. When you fill in these forms, you provide us with at least your full name, email address, gender, city and country you are from, your phone’s operating system, and how did you hear about Citory. If you want to be a Local, you additionally provide us with a very short answer of why you want to be a local. As of  [14.02.2022] we do not collect any other information from you other than the information explained above. But when we launch other services, we may ask you to give us additional information about you. We can’t help you experience the local story of the city or tell people this story without some information about you, such as basic profile details and the types of local things you want to experience. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

• As of [14.02.2022] we only accept early application forms to create a waitlist. When you fill in these forms, you provide us with at least your full name, email address, gender, city and country you are from, your phone’s operating system, and how did you hear about Citory. If you want to be a Local, you additionally provide us with a very short answer of why you want to be a local.
• When you complete your profile, you can share with us additional information, such as details on your bio, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
• When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
• When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
• When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
• If you contact our customer relations team, we collect the information you give us during the interaction.
• If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
• Of course, we also process your chats with other users as well as the content you publish, as necessary for the operation of the services.

Information we receive from others

In addition to the information you may provide us directly, we receive information about you from others, including:

• Users They may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
• Social Media You may decide to share information with us through your social media account.
• Other Partners We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.

Information collected when you use our services

When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

• Usage Information Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other users (e.g., users you connect and interact with, when you interact with them, number of messages you send and receive).
• Device information We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
• Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude). The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it. Similarly, if you consent, we may collect photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

4. Cookies and Other Similar Data Collection Technologies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Citory, do not currently respond to DNT signals.

5. Why and How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

A. To administer your account and provide our services to you

• Create and manage your account
• Provide you with customer support and respond to your requests
• Complete your transactions
• Communicate with you about our services

B. To help you connect with other users

• Recommend you Locals
• Show Local profiles to Guests

C. To provide new Citory services to you

• Register you and display your profile on new Citory features and apps
• Administer your account on these new features and apps

D. To operate advertising and marketing campaigns

• Administer sweepstakes, contests, discounts or other offers
• Perform and measure the effectiveness of advertising campaigns on our services and marketing campaigns promoting Citory and our services
• Communicate with you about products or services that we believe may interest you

E. To improve our services and develop new ones

• Administer focus groups, market studies and surveys
• Review interactions with customer relations teams to improve our quality of service
• Understand how users typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how users react to it)
• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

F. To prevent, detect and fight fraud and other illegal or unauthorized activities

• Find and address ongoing, suspected or alleged violations of our Terms & Conditions, notably through the review of reports and interactions between users
• Better understand and design countermeasures against violations of our Terms & Conditions
• Retain data related to violations of our Terms & Conditions to prevent against recurrences
• Enforce or exercise our rights, for example our Terms & Conditions
• Communicate to individuals who submit a report, what we’ve done as a result of their submission

G. To ensure legal compliance

• Comply with legal requirements
• Assist law enforcement

To process your information as described in this Privacy Policy, we rely on the following legal bases:

• Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to maintain your account and your profile, make it viewable to Guests or allow you to search Locals and to otherwise provide our free and paid features to you and other users.
• Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
• Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents users give us and decisions they may have taken to opt-out of a given feature or processing.
• Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

6. How We Share Information

Since our goal is to help you experience the local story of the city or tell guests this story, the main sharing of Locals’ information is with Guests. We also share some users’ information with service providers and partners who assist us in operating the services, and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

• With other users You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. If someone submits a report involving you (such as a claim you violated our Terms & Conditions), we may communicate to the reporter actions, if any, we took as a result of their report.
• With our service providers and partners We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. Our service providers and partners must agree to strict confidentiality obligations.
• For corporate transactions We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
• With law enforcement / when required by law We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
• To enforce legal rights We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
• With your consent or at your request We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.

7. Cross-Border Data Transfers

Sharing of information laid out in Section-6 involves cross-border data transfers to other jurisdictions that may have different laws about data processing. When we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the European Commission or other competent governmental body, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism.

8. Your Rights

• Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact us.
• Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
• You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
• Account closure. You can close your account by using the corresponding functionality directly on the service.
• Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or variations of those terms). You can exercise this right by contacting us.
• Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, object to or restrict its processing, please contact us.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our service, the other user will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older. In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

9. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. Note that we will close your account automatically if you are inactive for a period of one year. After your account is closed, we will delete your personal information, as laid out below:

1. To protect the safety and security of our users, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
2. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:

• a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to evidence our compliance with applicable law.
• b) We maintain limited information on the basis of our legitimate interest: we keep customer relations records and supporting data as well as imprecise location of download/purchase for five years to support our customer relations decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our users.
• c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

10. Children’s Privacy

Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

11. Job Candidates, Contractors and Vendor Representatives

We process the personal information of our job candidates, contractors and vendor representatives, as part of our recruitment and talent management operations and our management of the services that contractors and vendors provide to us. If you are a job candidate, contractor or vendor representative of Citory, certain relevant terms of this Privacy Policy apply to our processing of your personal information. If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations. We keep your personal information only as long as necessary for those purposes.

12. Privacy Policy Changes

This policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

13. Contact

Please contact us if you have any questions or concerns from the contact information below: info@citory.co