Privacy Policy

Floopel Privacy Policy

Floopel respects and is committed to protecting the privacy and Personal Data of its users.

This Privacy Policy explains how Floopel collects, obtains, uses, stores, shares, protects, and deletes Personal Data when you use the websites, applications, and services provided under the Floopel brand (collectively, the "Services").

Floopel applies the principles of purpose limitation, data minimization, transparency, security, accuracy, and storage limitation in accordance with applicable laws, including Indonesia's Law Number 27 of 2022 concerning Personal Data Protection.

Please read this Privacy Policy together with the Floopel Terms and Conditions.

1. Personal Data Controller and Processor

[LEGAL ENTITY NAME] acts as the Personal Data Controller for processing activities where Floopel determines the purposes and means of processing.

In providing Software as a Service (SaaS) to business customers, Floopel may also act as a Personal Data Processor when processing data under documented instructions from Partners or business customers.

The roles and responsibilities related to business customer data processing, including security, processing instructions, subprocessors, retention, export, and deletion, are governed by applicable commercial agreements or Data Processing Agreements (DPAs).

For services provided by third parties, including Partners, Organizers, Hosts, or Merchants, those parties may act as independent Personal Data Controllers for their respective processing purposes.

2. Minimum User Age

Account-based Floopel Services are intended for users who are at least 18 years old.

Floopel does not intend to collect children's Personal Data through its regular account registration process.

If Floopel becomes aware that an account was created by a user who does not meet the age requirement, Floopel may restrict access and take appropriate action to delete or otherwise handle the data in accordance with applicable laws and security requirements.

3. Personal Data We Collect

The categories of Personal Data processed depend on the features you use and the relevant processing purposes. Floopel does not necessarily collect every category listed below from every user.

3.1 Identity and Account Data

• Name and username.
• Email address.
• Date of birth or age eligibility information.
• Nationality or country code.
• Authentication method.
• Account identifiers from login providers such as Google, where applicable.
• Account status, profile status, and legal document consent records.

3.2 Authentication and Security Data

• Password hashes where password authentication is used.
• Relevant session identifiers and authentication tokens.
• IP addresses and device or browser information.
• Login records, security events, and access restriction information.
• Risk signals and information used to prevent fraud and system abuse.

Floopel does not intend to store passwords in plaintext.

3.3 Profile and Preference Data

• Profile pictures or avatars.
• Biographies and profile information provided by users.
• Interests, languages, and preferences.
• Saved or followed places, destinations, and content.
• Personalization and visibility settings.

3.4 Travel and Social Interaction Data

• Itineraries, destinations, and lists of places included in journeys.
• Private or public travel notes.
• Invitations and membership in collaborative trips.
• Relationships between organizers and participants.
• Community interactions and collaborative activities.

3.5 User-Generated Content

• Reviews and ratings.
• Comments and content reports.
• Uploaded photographs or media.
• Content attribution and provenance information.
• Moderation status and report-handling records.

3.6 Usage and Analytics Data

• Pages or content viewed.
• Search activities.
• Interactions with recommendations.
• Actions involving itineraries and social features.
• Activity timestamps and relevant technical metadata.

Search queries may inadvertently contain Personal Data. Users are advised not to enter sensitive information into search fields or public content.

3.7 Location and Gamification Data — If Enabled

If Quest or visit-verification features are enabled, Floopel may process:

• Temporary location coordinates and accuracy information.
• Verification timestamps and presence-verification results.
• Verification session and attempt identifiers.
• Application or device integrity information.
• Quest status, checkpoint progress, XP, Levels, Badges, and achievements.

Precise location data is used according to the requirements of the relevant feature and is not intended to operate as a continuous location-history tracking service.

3.8 Partner and Business Customer Data

Where business features are used, Floopel may process:

• Business identity and contact information.
• Organization or workspace information.
• Business licenses and verification documents.
• Authorized users and their permissions.
• Service configurations, subscriptions, and feature usage.
• API credential identifiers and integration configurations.
• Support, usage, and billing records.
• Business customer data processed as permitted under the applicable contract.

3.9 Transaction Data — If Enabled

If transaction features become available, Floopel may process order reference numbers, payment amounts, currencies, payment statuses, refund references, and related transaction information.

Primary payment credentials may be processed by licensed payment service providers according to the respective roles of the parties involved.

3.10 Support, Legal, and Safety Data

Floopel may process support correspondence, complaints, legal requests, consent records, account deletion records, and necessary audit information.

Emergency or safety contact information is collected only when a specific feature clearly requires it. A personal phone number is not automatically required as part of every user's regular profile.

4. Sources of Personal Data

Floopel obtains Personal Data from:

• Information directly provided by users.
• Identity providers selected by users.
• Devices or applications when relevant features are used with the required permissions.
• Partners or business customers in connection with lawful services.
• Other users through invitations and collaborative activities.
• Public or curated sources used lawfully.
• Floopel's security, analytics, and operational systems.

5. Purposes and Legal Bases for Processing

Floopel processes Personal Data for purposes relevant to the Services and based on appropriate lawful grounds under applicable law.

5.1 Account Management

To create accounts, authenticate users, manage profiles, verify age eligibility, and deliver requested Services. The legal basis may include contractual necessity, user requests, or legal obligations.

5.2 Discovery and Travel Planning

To provide place information, itineraries, saved preferences, social interactions, and collaborative features based on the provision of the Services and user actions.

5.3 Personalization and Recommendations

To tailor user experiences based on relevant interests, preferences, and activities, subject to appropriate lawful grounds and user controls.

5.4 Security and Fraud Prevention

To detect unauthorized access, prevent abuse, protect accounts, and maintain system integrity based on applicable legal obligations or legitimate interests.

5.5 Quest Verification

If enabled, to verify activity or presence evidence initiated by users, protect achievement integrity, and prevent manipulation. Location collection is subject to relevant notices and device permissions.

5.6 Analytics and Product Development

To understand Service usage, improve quality, and measure performance through appropriately limited data. Analytics technologies requiring consent will only be used with consent or another applicable lawful basis.

5.7 Transactions and Business Services

If enabled, to manage transactions, subscriptions, billing, support, refunds, or accounting obligations based on contracts and applicable legal requirements.

5.8 Communications and Marketing

To deliver service information, security notices, account-related communications, and marketing where an appropriate lawful basis exists. Users may opt out of non-essential marketing communications.

5.9 Legal Obligations and Data Deletion

To comply with applicable laws, respond to lawful requests, handle disputes, document consent, and perform account deletion.

6. Precise Location Data and Quest Verification

If location-based Quest features are enabled, Floopel may request access to precise location information to verify user activities or presence.

Collection occurs within the relevant verification flow and after the required device permissions are granted.

Under the proposed Quest V1 policy, raw location evidence has the following deletion deadlines:

• 24 hours after a verification attempt reaches its terminal state; or
• 24 hours after a verification session expires if no completed attempt exists.

The cleanup process may have an additional grace period of no more than 6 hours after the applicable deletion deadline.

Raw location data is not intended to be permanently retained as movement history or included in ordinary application logs, business analytics, or shared content.

Floopel may retain minimal verification outcomes necessary for achievement integrity, auditing, and abuse prevention, subject to an appropriate lawful basis and retention period.

These specific provisions apply once the relevant Quest features have been enabled and the operational policy has been approved.

7. Use of Artificial Intelligence

Floopel may use artificial intelligence to assist with information discovery, planning, content preparation, recommendations, and Service quality improvements.

User data stored within the system does not automatically constitute permission or a legal basis for AI model training.

Before using Personal Data for model training or improvement beyond the previously disclosed Service purposes, Floopel must determine the purpose, lawful basis, permitted data categories, retention, processing providers, and relevant user controls.

Sensitive audit records, secret credentials, private information, and raw precise location evidence are not used as AI training inputs by default.

8. Personal Data Sharing and Disclosure

Floopel may share Personal Data on a limited basis with relevant parties according to appropriate processing purposes and lawful grounds.

8.1 Service Providers

These may include cloud, storage, database, email, security, monitoring, mapping, analytics, support, AI, and payment providers where applicable.

Disclosure is limited to Service requirements and subject to relevant contractual arrangements and data protection safeguards.

8.2 Partners and Business Customers

Data may be shared to the extent necessary for services, collaboration, transactions, or business processes selected by users.

Each party's role as a controller or processor is determined by the relevant processing activity and applicable agreements.

8.3 Other Users and the Public

Profile information, reviews, itineraries, or other content may be visible to other users according to the applicable visibility settings.

8.4 User-Directed Sharing

When users share information with third-party applications, that information may subsequently be processed under the third party's privacy policies.

8.5 Authorities and Legal Requirements

Floopel may disclose information where required by law, pursuant to lawful requests, or when necessary to address security incidents, fraud, or the establishment, exercise, or defense of legal rights.

8.6 Corporate Transactions

In connection with mergers, acquisitions, restructuring, financing, or business transfers, Personal Data may be processed or disclosed subject to legally required safeguards and notices.

9. International Data Transfers

Certain service providers may process or store Personal Data outside Indonesia.

International transfers will be conducted using safeguards required under applicable law, including assessments of data protection standards, adequate and binding protections, or consent where necessary.

Information about relevant processing providers, processing locations, and transfer mechanisms is available at [PROCESSOR AND PROCESSING COUNTRY REGISTER LINK].

This register must be verified before this Privacy Policy becomes effective in production.

10. Data Storage and Retention

Floopel retains Personal Data only for as long as necessary to fulfill processing purposes, deliver the Services, comply with legal obligations, maintain security, handle disputes, or preserve Service integrity where a lawful basis exists.

Retention periods depend on the data category and applicable requirements.

10.1 Account and Profile Data

Retained while the account is active and the data remains necessary. Once an account deletion request is received, the account enters the deletion process with a default 30-day grace period, after which the data is handled according to the deletion policy and lawful exceptions.

10.2 Content and Collaborative Data

Private content may be deleted when no longer necessary. Public or shared content may be deleted or anonymized based on other users' rights, Service integrity, and an appropriate lawful retention basis.

10.3 Quest Location Evidence

If Quest V1 is enabled under the approved design, raw location evidence has a deletion deadline of 24 hours after the relevant verification terminal state or session expiry, with an additional cleanup period of no more than 6 hours.

10.4 Security and Audit Records

Retained for limited periods based on security, fraud prevention, compliance, and legal requirements. Final periods are determined by the approved retention schedule.

10.5 Payment and Accounting Records

If transaction features are enabled, relevant records are retained in accordance with applicable accounting, taxation, and legal requirements.

10.6 Backups

Backups are subject to approved retention and rotation schedules. Restoration procedures must prevent accounts or Personal Data that have already been permanently deleted from becoming active again.

Note: Final retention periods for security records, audit records, consent evidence, backups, and other categories not yet established must be completed in accordance with an approved retention policy before publication.

11. Account and Personal Data Deletion

Users may request account deletion through account settings or Floopel's official channels.

To prevent misuse, Floopel may require fresh authentication and confirmation.

After receiving a request, Floopel may promptly:

• Restrict normal account access.
• Revoke relevant active sessions and credentials.
• Hide public profiles.
• Stop personalization or marketing activities that are no longer necessary.
• Record the request and deletion deadline.

The current default grace period is 30 days. The applicable grace period is displayed and recorded when the request is created.

Before the deadline and before irreversible processing begins, users may cancel their requests through the restricted identity verification process.

After the grace period, data is handled under three categories:

• ERASE: Identity and private data that is no longer necessary is deleted.
• ANONYMIZE: Certain data may be retained without a re-identifiable user identity where a lawful basis exists.
• RETAIN: Minimal data necessary for legal obligations, security, fraud prevention, or disputes is retained on a limited basis.

Certain collaborative content may remain available under the attribution "Deleted User" where necessary to protect other users' rights and permitted by law.

Floopel will address deletion within relevant systems and processing providers according to contractual and legal obligations.

Backup restoration procedures must prevent deleted account data from being reactivated after deletion is complete.

If an account also has an active Partner or Admin profile, deletion may require coordination with Floopel support.

12. Your Personal Data Rights

Subject to applicable law, users may have the right to:

• Obtain information about Personal Data processing.
• Access and obtain copies of Personal Data.
• Correct or update inaccurate data.
• Withdraw consent for processing based on consent.
• Request termination, restriction, or deletion of processing under legally defined circumstances.
• Object to decisions based solely on automated processing where applicable.
• Request data transfer or access in formats required by law.
• Submit complaints or pursue legal remedies under applicable regulations.

Requests may be submitted to [PRIVACY EMAIL].

Floopel may require proportionate identity verification before processing requests.

The exercise of certain rights may be subject to lawful exceptions, including mandatory data retention and protection of other parties' rights.

13. Personal Data Security

Floopel implements technical and organizational measures appropriate to the risks involved in processing Personal Data.

Security measures may include:

• Encryption of sensitive data.
• Appropriate credential hashing.
• Session and authentication management.
• Role-based and permission-based access controls.
• Request rate limiting and abuse prevention.
• Security auditing and system monitoring.
• Secrets management.
• Minimization of Personal Data in logs and analytics records.

No system is completely free from security risks.

If a Personal Data protection failure occurs and meets applicable notification requirements, Floopel will undertake incident containment, investigation, and notification to affected parties or authorities within the legally required timeframe.

14. Cookies, Local Storage, and Similar Technologies

Floopel may use cookies, local storage, or similar technologies for authentication, security, preferences, and session continuity.

Analytics or marketing technologies requiring consent will be subject to appropriate notice and preference-management mechanisms.

Under this draft policy, Floopel does not use browser fingerprinting as a default user-growth mechanism.

15. Communications and Notifications

Floopel may send communications necessary for:

• Account authentication and security.
• Invitations or collaborative activities.
• Important Service changes.
• Account deletion requests and completion notifications.
• Transaction or service notifications where relevant features are enabled.

Non-essential marketing communications are separate from critical Service notifications.

Users may opt out of marketing communications through available mechanisms without disabling necessary security or Service-related notifications.

16. Changes to This Privacy Policy

Floopel maintains this Privacy Policy through a versioned document system.

Material changes affecting Personal Data processing or user rights may require notice and renewed consent where required by law or the applicable Service mechanism.

Administrative changes or non-material clarifications may be communicated without renewed consent where permitted by law.

Acceptance of relevant document versions may be recorded for accountability and compliance purposes.

If users decline material changes, access to features requiring acceptance may be restricted without limiting statutory rights.

17. Privacy Contact and Complaints

If you have questions, wish to exercise your Personal Data rights, or want to submit a privacy-related complaint, please contact:

• Data Controller:[email protected]
• Privacy Contact:[email protected]
• User Support: [email protected]

Floopel will handle requests and complaints in accordance with the applicable procedures and legal requirements.