Privacy Policy
1. Introduction & scope
This Privacy Policy explains how [Company legal name] ("LARP," "we," "us") collects, uses, discloses, and protects personal information when you use the LARP apps, website, and services (the "Services"). It applies to Renters, Owners, and site visitors. Capitalized terms not defined here have the meaning in the Terms of Service.
2. Notice at Collection — what we collect, why, and how long
| Category | Examples for LARP | Source | Purpose | Retention (target) |
|---|---|---|---|---|
| Identifiers | Name, email, phone, account ID, IP address | You; your device | Create/operate account; communicate; security | While account active + a period after closure for legal/tax |
| Government identifier (Sensitive PI) | Driver's license / passport / ID document & number | You, via our verification vendor | Verify identity before first booking; fraud/safety | Vendor-held; minimized at LARP — see §6 |
| Biometric information (Sensitive PI / special category) | Live selfie, facial geometry / face-match used for liveness & identity | You, via our verification vendor | Confirm the ID belongs to you; prevent fraud | Purpose-complete or 3 years from last interaction, whichever is first — see §6 |
| Commercial information | Bookings, Sessions, transactions, reviews | You; the Services | Operate the marketplace; support; disputes | While account active + a period for legal/tax |
| Financial information | Payment card / bank details — collected and stored by Stripe, not LARP; LARP sees limited tokens/last-4 | Stripe | Process payments and payouts | Held by Stripe per Stripe's terms |
| Geolocation | Approximate location for discovery; meeting location of a Session (revealed after booking) | You; your device | Show nearby Cars; coordinate the meet | While needed for the Session |
| Audio/visual (User Content) | Listing photos, before/after Session photos, messages | You | Operate Listings/Sessions; evidence in disputes | While account active |
| Internet/device & usage | Device type, app/version, pages, cookies & similar tech | Your device | Security, analytics, improve the Services | — |
| Inferences (if any) | Preferences derived from use | The Services | Personalize discovery | — |
We do not knowingly collect driving records, DMV data, or vehicle telematics/GPS-during-driving — because LARP has no driving. Unlike a car-rental platform, we do not track a moving vehicle; we use only the agreed meeting location.
3. How we use personal information
To: provide and operate the Services; verify identity and prevent fraud; process payments/payouts via Stripe; enable bookings, Sessions, messaging, and reviews; provide support; ensure trust & safety and enforce our policies; comply with law (tax, dispute, law-enforcement requests); and, with any required consent, send communications and improve the Services. We process Sensitive Personal Information only for the limited purposes above (identity verification, fraud/safety, and as required by law), and not to infer characteristics — see §5.
4. How we disclose personal information; categories of recipients
We are not in the business of selling your data. We disclose personal information to:
- Payment Processor — Stripe (payments, payouts, Connect onboarding/KYC, tax forms).
- Identity-verification vendor (ID + selfie verification; acts as the biometric processor — see §6).
- Hosting/infrastructure (e.g., Supabase) and storage/CDN.
- Communications — email (Resend), push notifications (Expo), and, where used, an SMS provider.
- Analytics (if any).
- The other party to a booking — limited info needed to coordinate a Session (e.g., first name, profile, verified badge, and, after confirmation, contact details and meeting location).
- Legal/safety — to comply with law, enforce our terms, or protect rights and safety.
- Corporate transaction — to a successor in a merger/acquisition, subject to this Policy.
We require service providers to use personal information only to perform services for us.
5. Your privacy rights
5.1 California (CCPA/CPRA)
You have the right to: know/access the categories and specific pieces of personal information we collect; delete it (subject to legal-retention exceptions); correct inaccuracies; opt out of "sale"/"sharing" of personal information; and limit the use and disclosure of Sensitive Personal Information to permitted purposes. We will not discriminate against you for exercising these rights.
We do not sell personal information and do not "share" it for cross-context behavioral advertising. If this ever changes, we will provide a "Do Not Sell or Share My Personal Information" link and honor opt-out preference signals (e.g., GPC). Because we use Sensitive PI only for permitted purposes (identity verification, fraud/safety, legal compliance), we still provide a control and honor "Limit the Use of My Sensitive Personal Information" requests.
5.2 How to exercise rights
Submit a request in-app (Settings → Privacy), at [privacy request URL], or by emailing [privacy email]. We verify your identity before responding and may use an authorized-agent process. We respond within the timeframes the law requires (CCPA: generally 45 days, extendable).
5.3 UK-GDPR / GDPR (UK/EU users)
Where UK-GDPR/GDPR applies (we have a UK nexus), you also have rights to access, rectification, erasure, restriction, portability, and objection, and to withdraw consent at any time. See §7.
5.4 Marketing communications & text messages (SMS)
We send transactional messages (about your account, bookings, and Sessions) by in-app notification, push, email, and SMS. With your consent, we may also send promotional messages. You can opt out of promotional email via the unsubscribe link, of push in your device settings, and of promotional SMS by replying STOP (reply HELP for help). Message and data rates may apply. Opting out of promotional messages won't stop transactional messages needed to run your bookings.
6. Biometric Information Privacy
6.1 What we collect and why. To confirm that you are who you say you are before your first booking (because Owners meet Renters in person), our verification vendor captures a government ID and a live selfie, and generates facial geometry / a biometric face-match to confirm liveness and that the selfie matches the ID. This is biometric information.
6.2 Consent first. We obtain your written consent before any biometric capture, via the Biometric Consent Notice, and we log the consent version and timestamp. You can use LARP without booking and without verifying; verification (and this consent) is required only to book.
6.3 Who stores it (minimization). Our verification vendor is the biometric processor; we design the flow so that LARP minimizes or avoids storing raw biometric identifiers itself, retaining instead a verification result/status and reference.
6.4 Retention & destruction schedule. Biometric identifiers and biometric information are retained only as long as needed for the verification purpose and are destroyed when the initial purpose has been satisfied or within 3 years of your last interaction with LARP, whichever occurs first, and on your erasure request (subject to lawful exceptions). We (and our vendor by contract) follow this schedule.
6.5 No sale. We do not sell, lease, trade, or otherwise profit from your biometric information, and we do not disclose it except to our verification vendor to perform the verification, as you authorize, or as required by law.
6.6 Security. Biometric data is protected using reasonable safeguards at least as protective as we use for other confidential information (see §9).
7. UK-GDPR / GDPR details (UK/EU nexus)
- Controller: [LARP entity]. EU/UK representative / DPO (if required): [as applicable].
- Lawful bases (Art. 6): performance of a contract (providing the Services); legitimate interests (security, fraud prevention, improving the Services); consent (where required, e.g., marketing); legal obligation (tax, disputes).
- Special category data (Art. 9): biometric data used to identify you is special category data; our lawful condition is your explicit consent (see §6).
- Automated decision-making (Art. 22): identity verification uses automated processing (liveness/face-match) to confirm your identity. Where this would produce a legal or similarly significant effect, you may request human review of the decision by contacting us.
- International transfers: data may be processed in the US/UK; transfers use appropriate safeguards (SCCs / UK IDTA / adequacy).
- Your rights & complaints: access, rectification, erasure, restriction, portability, objection, and withdrawal of consent; you may complain to the UK ICO or your local supervisory authority.
- Retention: as in §2 and §6; we keep data only as long as necessary.
8. Cookies & similar technologies
We use cookies, web beacons, and similar technologies for security, functionality, and analytics. Our Cookie Policy (published before launch) will detail how to manage preferences, including any cookie-preference link in the website footer.
9. Security
We use reasonable administrative, technical, and physical safeguards (e.g., encryption in transit, access controls, row-level data isolation, least-privilege keys). No system is perfectly secure; we cannot guarantee absolute security. If a breach occurs, we follow applicable breach-notification laws.
10. Children
The Services are not directed to anyone under 18, and we do not knowingly collect their personal information. If you believe a minor has provided us data, contact us and we will delete it.
11. Account & data deletion
You can delete your account and data from within the app (Settings → Account → Delete) and at a public web page (no app install required). On deletion, we remove or de-identify personal information and instruct our verification vendor to delete biometric data, while retaining records we are legally required to keep (e.g., transaction/tax/dispute records) for the required period, and then deleting them. To remove an early-access sign-up before launch, email us (see §13).
12. Changes to this Policy
We'll post the new "Last updated" date and, for material changes, provide additional notice. Continued use after the effective date means you accept the updated Policy.
13. Contact
Privacy questions / requests: [privacy email] · Mailing address: [to be provided] · EU/UK representative or DPO (if any): [as applicable].