Privacy Policy

1.Who is the data controller

Kvart (the iPhone app and, once launched, the website) is run by PYRAMIDS ECOMMERCE DOO BEOGRAD (STARI GRAD), a company registered with the Serbian Business Registers Agency (Agencija za privredne registre, APR), company registration number (matični broj) 22316567, tax ID (PIB) 115796510, with its registered office at Obilićev venac 18, lokal 3.15, 11102 Beograd (Stari Grad), Serbia (“we” or “us”). We are the controller of your personal data: we decide why and how it is processed, and we are responsible for it.

We process data in accordance with the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti, Official Gazette of the Republic of Serbia No. 87/2018) and, where it applies (for example when you use Kvart from the European Union), the EU General Data Protection Regulation (EU) 2016/679 (GDPR). For any question about your data, email us at pyramids.bg@gmail.com or call +381 61 704 6765.

2.Using Kvart without an account

You don’t need an account to browse places, posts, the map, guides and rankings. In that case we don’t create a profile and don’t know who you are: we only process the technical data that comes with every request to our server (IP address, time, app and system version) and, if you allow it, your location on your device, as described under “Location”.

You can also report a post, comment or user profile without an account. Such a report reaches our server and goes into the same review queue as all other reports, and it is not linked to any account. To prevent abuse, all we keep with it is a one-way fingerprint of the IP address (a hash made with a secret key), which we use to limit reports to 10 per hour and delete after 2 days. A block made without an account applies only on that device.

3.What data we process

When you create an account and use Kvart, we process data you give us, data generated as you use the app, and data that Apple or Google send us at your choice:

• Account: the email address we receive from Apple or Google (or an Apple relay address if you hide your email), your mobile number and your password as an irreversible hash (if you sign in with your phone number), sign-in method, the unique identifier of your Apple or Google account, the date you joined and your app language.
• Profile: the name you display and your city, plus a short bio if you add one.
• Content: posts — reviews (text, overall rating, category and dish ratings) and other posts — with up to 9 photos, the place they’re about and labels such as “Hosted visit”; comments and replies; and new places you suggest (name, address, neighbourhood and type).
• Activity: likes, saved places and posts, your list of places and your answers when you compare two places, who you follow and who follows you, and your progress towards the “Local” (Lokalac) badge.
• Safety and moderation: reports you submit (what you report and the reason), reports by other users about you or your content, users you block (blocking also sends us a report automatically), moderation decisions with their reasons, and your appeals.
• Claiming a place profile: name, role at the place, email, phone number, verification method and a document if you send one (see “Place owners and claiming a profile”).
• Notifications: your notification token and notification settings — only if you turn notifications on.
• Technical and security logs: IP address, time and type of request, device model, system and app version, and sign-in records (time, method, success or failure).
• Correspondence: what you send us by email or tell us by phone, such as a question, request or appeal.

Apart from the password for signing in with your phone number, we don’t ask for any passwords, ID card, personal identification number (JMBG) or access to your contacts. Kvart has no payments, purchases, delivery or bookings, so we don’t process card details or any other financial data.

Please don’t include sensitive data (for example about health or religious beliefs) or other people’s personal data in your posts, comments or bio. If you do, it will be public like the rest of the post.

4.Signing in: Apple, Google or phone number

You sign in with Apple, with Google, or with your mobile number and a password.

• Apple: we receive the unique identifier of your Apple Account, your name (if you share it) and your email address. If you choose to hide your email, we only receive an Apple relay address and never see your real one.
• Google: we receive the unique identifier of your Google Account, your name and your email address. We never receive your Google password or access to any other data in your Google Account.
• Phone number and password: we use your number only for signing in and keeping your account secure (for example, when you ask for a new password, we check that you’re contacting us from that number). We don’t show it publicly, don’t give it to place owners and don’t send you marketing texts. We store your password only as an irreversible hash, so not even we can see it; the app sends it only over an encrypted connection (HTTPS) and doesn’t keep it on your phone (unless iOS itself saves it in your passwords).

Apple and Google also provide their sign-in services under their own privacy policies. When you delete your account, we unlink it from your Apple or Google account, immediately delete the phone number and password hash on your account, and, for Apple, revoke the sign-in token. The phone number and IP address in sign-in records (time, method, success or failure) are kept as security logs for 12 months and then deleted.

5.Why we process data and on what legal basis

Each processing activity relies on one of the legal bases in Article 12 of the Serbian Law on Personal Data Protection (and Article 6 GDPR):

• Performance of our contract with you (the Terms of Use): creating and running your account, signing in, your profile, publishing and showing posts, photos and comments, likes, saves, follows, the “Local” badge and the “For you” feed.
• Legitimate interests: keeping accounts and the service secure, preventing abuse and spam, moderation and handling reports, detecting fake reviews and keeping ratings and rankings fair, verifying claim requests, aggregate statistics for places, promoting Kvart on our official channels with content that is already public, improving the app, and establishing or defending legal claims. We weigh these interests against your rights, and you can object to this processing.
• Consent: location and notifications — only if you allow them in iOS or turn them on in the app. You can withdraw consent at any time; this doesn’t affect the lawfulness of processing before withdrawal.
• Compliance with legal obligations: responding to courts and competent authorities, removing illegal content once we become aware of it (Serbian Law on Electronic Commerce), keeping data where the law requires it, and answering your requests to exercise your rights.

To have an account you need a sign-in method, a display name and a city; without them the account can’t work. Everything else — bio, location, notifications — is optional, and Kvart works fine without it.

The “For you” feed and recommendations may take into account your city, the people you follow and what you like and save; under “Following” you see only posts from people you follow.

We don’t make decisions based solely on automated processing that have legal effects on you or similarly significantly affect you. Automatic rules (for example, limits on how many posts, comments and reports can be made in a given period) only protect against abuse; removing content and restricting or closing an account is decided by a member of our team.

6.Location

Kvart only asks for location access “while using the app”, and only when you tap the location button on the map, choose “Nearest” or start choosing a place for a post — never at launch and never in the background. If you say no, everything else still works, just without distances and nearby places.

Distances, nearby places and the “Are you here?” prompt are calculated on your device. We don’t store your location, don’t attach it to your posts and don’t build a history of your movements; a post shows only the place you choose, not where you posted from. Even when you suggest a new place (“Add it”), we don’t send your location — we put the place on the map based on the address you enter.

If the app asks our server for nearby places, it sends only an approximate location, which is used solely to answer that request, is not written to logs and is not stored. You can withdraw permission at any time in your iPhone settings (Privacy & Security → Location Services → Kvart).

7.Photos and camera

Kvart has no access to your whole photo library. You pick photos in the iOS system picker and the app receives only the ones you select — up to 9 per post. Camera access, if the app asks for it, is used only for the photo you are taking for a post at that moment. You choose a document for claiming a place profile yourself, in the system file picker.

Before upload, the app saves each photo as a new image, resizing larger ones; this removes extra data (EXIF), including where the photo was taken and device details. Photos in posts are public, just like the post itself.

Don’t post photos in which other people can be clearly recognised without their consent. If a person shown in a photo sends us a justified request, we remove that photo.

8.Notifications

Notifications are off by default. When you turn them on in the app settings, iOS asks for your permission and Apple assigns your device a notification token, which we store with your account.

We send notifications (for example about a new comment, reply or follower, or the outcome of a claim request) through the Apple Push Notification service, so the token and the notification text pass through Apple’s servers. We don’t send marketing notifications without your separate consent.

You can turn notifications off in the app (Settings → Notifications) or in your iPhone settings; whether their content shows on the lock screen is up to your iOS settings.

9.Place owners and claiming a profile

Kvart creates and maintains place profiles even before owners join, based on publicly available information (name, address, phone number, opening hours, type of place, menu and prices) and guests’ posts. We process this information on the basis of our legitimate interest in giving users accurate information about places. If any of it relates to you as an individual (for example when a business trades under your own name), you can ask us to correct it or object.

When you submit a claim request, we process your name, your role at the place (owner, manager or staff), email, phone number, the place concerned, the chosen verification method and, if you send one, a document (for example an APR registration decision). We use this data only to verify the request and to contact you about the place profile, and we don’t show it publicly.

We verify by calling the place’s phone number or by checking the document. Don’t send us your ID card, passport or other identity documents; if a document contains data we don’t need (such as a personal identification number), feel free to cover it. The legal basis is taking steps at your request so you can use our services for places, and our legitimate interest in preventing anyone from claiming a place that isn’t theirs.

Official replies are published in the place’s name. The statistics an owner sees (views, saves, new reviews) are shown only in aggregate: we count views without recording who viewed which place, so owners can’t see who viewed or saved their place. Owners can’t edit or delete guests’ reviews or ratings.

Any services for places agreed outside the app are governed by a separate agreement and a separate privacy notice.

10.What’s public and what’s private

• Public — visible to everyone, including visitors without an account, and, once the website launches, on the internet, where search engines may index it: your name, city, bio, “Local” badge, the month and year you joined, the number of your posts, followers and following, your follower and following lists, published posts with photos and ratings, labels, comments and replies, and like counts.
• Visible to people who follow you — your list (places ranked by how much you liked them) and the places you want to try (saved places). Visitors without an account and users who don’t follow you can’t see them. Others only see the places on your list that you have a published review of.
• Private — visible only to you, and to authorised members of our team only when needed to run the service, provide support or moderate: your email address, phone number and sign-in method, saved posts, what exactly you like (others see only the total), blocks, reports (a reported user isn’t told who reported them unless the law requires it), location, settings, posts awaiting review (“Pending”) and claim requests.
• On our channels — if we share your public post on Kvart’s official social media accounts, as described in the Terms of Use, your name is shown there with the content, and that network also processes the post under its own rules. We remove such a post at your request.

Place owners see public posts about their place like everyone else and can reply, but they can’t see your email or any other private data. Once a post is removed or deleted it is no longer public, but anything others have saved outside Kvart in the meantime (such as a screenshot) is beyond our control.

11.Who we share data with

We don’t sell your data or give it to anyone for advertising. Data is shared only with:

• Alibaba Cloud (Alibaba Cloud International) — hosting: servers, database and photo storage in its Frankfurt data centre (Germany, EU), as our processor.
• Apple — for Sign in with Apple, notifications and showing the map (MapKit); when the map loads, Apple receives the technical data needed to display it, such as your IP address. Google — for Sign in with Google; when you sign in, Google receives technical data such as your IP address and processes it under its own privacy policy. Google is also the provider of the email service (Gmail) behind our address pyramids.bg@gmail.com, so messages you send us, including attachments, are also processed by Google. They also provide these services under their own terms and privacy policies. If you contact us via Viber (Rakuten Viber) or WhatsApp (Meta), for example to reset your password, those messages are also processed by that app’s provider under its own rules, including outside Serbia and the EU; if you prefer not to, call us by phone.
• Professional advisers (lawyers, accountants, auditors) where necessary, under a duty of confidentiality.
• Courts and competent authorities — only where the law requires it or where necessary to protect someone’s life, safety or rights.

Processors may use data only on our instructions and only for the service we engaged them for, under a duty of confidentiality. If Kvart or part of it were transferred to another legal entity (for example a company set up for Kvart), the data would pass to it with the same obligations under this policy, and we would tell you in advance.

12.Where data is stored and transfers outside Serbia

We store your data on Alibaba Cloud servers in Frankfurt, Germany (EU). Germany is an EU member state and a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (Convention 108), so under the Serbian Law on Personal Data Protection it is considered to provide an adequate level of protection, and no separate authorisation is needed for this transfer.

Apple and Google may also process data outside Europe, including in the United States. These transfers rely on the safeguards those companies apply, such as standard contractual clauses and certification under the EU–U.S. Data Privacy Framework, and, for Sign in with Apple or Google, on the transfer being necessary to provide the service you choose.

If any provider (for example, technical support for our hosting) processes or accesses data outside Europe, we allow this only with appropriate safeguards provided for by law, such as standard contractual clauses.

13.No ads, no tracking

Kvart doesn’t use your device’s advertising identifier (IDFA) and doesn’t track you across other apps and websites, which is why it never asks for tracking permission. The app contains no advertising SDKs or third-party behavioural analytics tools, and we don’t sell or rent out data.

If you turn on sharing analytics with app developers on your iPhone, Apple sends us crash and error reports from which we can’t tell who you are. You control this setting in iOS.

On your device, the app keeps what it needs to work: your sign-in session, chosen language, drafts, recently viewed places and settings. Drafts and recently viewed places stay on your phone and aren’t sent to us, and the sign-in session is deleted when you sign out.

When the website launches, we will use only cookies that are strictly necessary for sign-in, security and remembering your language; for any other cookies we will ask for your consent first. If we introduce sponsored content, it will be clearly labelled (“Sponsored”, “Paid partnership”) and won’t be shown based on tracking your behaviour outside Kvart.

14.How long we keep data

• Account and profile: for as long as you have an account.
• Sessions (staying signed in): they expire and are deleted 180 days after last use, and immediately when you sign out or delete your account.
• Posts, photos, comments, likes, saves and follows: until you remove them or delete your account. Deleted content is removed from the app and our live databases immediately; if it is the subject of a report or proceedings at that moment, we keep it hidden until they are concluded.
• Blocks: for as long as the block is in place, and at the latest until you delete your account.
• Reports and moderation decisions: while the account concerned exists and for up to 3 years after it is deleted, for consistent moderation and to defend legal claims. Content removed for breaking the rules is kept hidden, as evidence, for up to 12 months after removal.
• IP address fingerprint kept with reports made without an account: 2 days.
• Claim requests: while the request is being handled; if approved, while you manage the place profile and for 12 months afterwards; if rejected or withdrawn, 6 months from the decision. Any document you sent is deleted no later than 30 days after the decision, and we keep only a note of how verification was done.
• New place suggestions: until the suggestion is checked. An approved suggestion becomes part of the place information, and the record of who sent it is kept while you have an account; a rejected suggestion is deleted after the check.
• Notification token: while notifications are on. We delete it when you turn them off, sign out or delete your account, and within 30 days if Apple tells us the token is no longer valid (for example after you delete the app).
• In-app notifications (your notifications list): deleted automatically after 180 days.
• Location: not stored.
• Security logs (including sign-in records): 12 months. Server access logs (IP address, time, request): 30 days.
• Correspondence with us: until the matter is resolved, then for up to 2 years so we can show how we handled it (for example a request to exercise your rights).
• Backups: made daily and each kept for 30 days, so deleted data disappears from them within 30 days at the latest.

Where proceedings before a court or authority are under way, we keep the data needed for them until they end. Aggregate statistics that can’t identify you (such as the number of views of a place profile) may be kept longer.

15.Deleting your account and what remains

You can delete your account at any time, right in the app: Profile → Settings → Delete account. Deletion is permanent and can’t be undone; if you just want a break, signing out is enough.

We immediately delete your profile (name, city, bio), all your posts and photos, including those pending review, your comments and replies, likes, saved places and posts, your list, follows and followers, blocks, the “Local” badge, and any claim requests still under review. The exception is posts, comments and photos we previously removed for breaking the rules (see below). Place ratings are recalculated without your reviews.

We unlink your Apple or Google account (for Apple, we also revoke the sign-in token), delete the phone number and password hash on your account, delete your notification token and end all active sessions. The phone number and IP address in sign-in records (time, method, success or failure) are kept as security logs for 12 months and then deleted. Data disappears from backups within 30 days at the latest.

After deletion, only the following remains:

• your reports, but without your name or anything else that shows who you are;
• moderation decisions concerning you, security logs, correspondence with us and records of an approved place claim — until the periods under “How long we keep data” expire;
• posts, comments and photos we previously removed for breaking the rules — as evidence, hidden and no longer linked to your account, for up to 12 months after removal;
• official replies and news published in the name of a place you manage — they stay on the place profile, without your name;
• places you suggested that we approved — they remain as place information, no longer linked to you;
• data needed for a report, proceeding or authority request that was under way when you deleted your account — until it is concluded.

If the account had been permanently closed for breaching the rules at the time of deletion, we keep a one-way fingerprint of the Apple or Google account identifier or phone number (a hash made with a secret key that is kept separately) for up to 3 years, solely to prevent the account from being reopened. This fingerprint can’t be used to recover the identifier.

You can open a new account later, but a deleted account and its content can’t be restored. If you can’t access the app, you can also request deletion by email (see “Your rights”).

16.Your rights

Under the Serbian Law on Personal Data Protection (and the GDPR, where it applies) you have the right:

• of access — to find out whether and what data about you we process, and to get a copy;
• to rectification — you can change your name, city and bio in the app (Profile → Edit profile); for anything else, write to us;
• to erasure — you can delete your whole account yourself in the app settings, and your own reviews, posts and comments from the “⋯” menu (Delete post / Delete); other data we delete at your request (except data we must or may keep by law);
• to restriction of processing in the cases provided by law (for example while we check whether data is accurate);
• to data portability — to receive the data that comes from you and that we process on the basis of contract or consent in a structured, machine-readable format, or to have us transmit it to another controller where technically feasible;
• to object to processing based on legitimate interests — we then stop, unless there are compelling legitimate grounds that override your interests or the processing is needed for legal claims;
• to withdraw consent for location and notifications, in your iPhone settings or in the app;
• not to be subject to a decision based solely on automated processing that has legal effects on you or similarly significantly affects you.

Send your request to pyramids.bg@gmail.com with “Kvart” in the subject line, or call us on +381 61 704 6765. To protect your data, we may ask you to confirm your identity, for example by writing to us from the email address linked to your account.

We reply without undue delay and in any case within 30 days of receiving your request. We may extend this by up to a further 60 days where necessary because of the complexity or number of requests, in which case we will tell you within 30 days and explain why. Exercising your rights is free; for manifestly unfounded or excessive requests, especially repeated ones, we may charge the necessary administrative costs or refuse to act, giving our reasons.

If you believe we process your data unlawfully, you have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti, Bulevar kralja Aleksandra 15, Belgrade, www.poverenik.rs), and the right to judicial protection. If you live in the EU, you can also contact the supervisory authority in your country. We’d appreciate the chance to sort things out with you first.

17.Minors

Only people who are 18 or older can create a Kvart account; by creating an account you confirm that you are at least 18. Kvart doesn’t knowingly collect personal data from minors.

If we learn that an account is used by someone under 18, we close the account and delete its data, except data we must keep by law. A parent or guardian can contact us using the details in this policy.

18.Data security

We apply appropriate technical and organisational measures: all communication between the app and our servers is encrypted (HTTPS); passwords are stored only as an irreversible salted hash (using the scrypt algorithm), and session tokens are stored only in hashed form; we strip metadata from photos; only authorised team members who need it for their work can access data, and moderation actions are logged; and we make daily backups.

No transmission or storage of data over the internet is completely secure. If a personal data breach occurs, we will notify the Commissioner as required by law, as a rule within 72 hours of becoming aware of it, and notify you without undue delay if the breach is likely to result in a high risk to your rights and freedoms.

19.Changes and language

We may change this policy when we change Kvart or when the law changes. The current version is always available in the app (Settings → Privacy Policy), with the date of the last update at the top. We will tell you about important changes in the app at least 15 days before they take effect, unless the change is required by law or for users’ safety. If a change requires your consent, we will ask for it separately.

This policy is published in Serbian, English and Chinese. In case of any discrepancy, the Serbian text prevails.

20.Contact

Controller: PYRAMIDS ECOMMERCE DOO BEOGRAD (STARI GRAD)

Registered with the Serbian Business Registers Agency (Agencija za privredne registre, APR)

Company registration number (matični broj): 22316567

Tax ID (PIB): 115796510

Address: Obilićev venac 18, lokal 3.15, 11102 Beograd (Stari Grad), Serbia

Email: pyramids.bg@gmail.com

Phone: +381 61 704 6765 (within Serbia: 061 704 6765)

Send privacy questions, requests to exercise your rights, notices of illegal content and appeals against moderation decisions to the email address above, with “Kvart” in the subject line.