Applies to: quouch-app.com (the “Website”), the Quouch mobile apps (iOS & Android) and related services (together, the “Services”).
Quouch UG (haftungsbeschränkt) ("Quouch", "we", "us") is committed to protecting your personal data. This Privacy Policy explains what we collect, why we collect it, how we use it, who we share it with, how long we keep it, and the rights you have. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the German Telecommunications Telemedia Data Protection Act (TTDSG).
If anything here is unclear, please contact us at hello@quouch-app.com.
---
1. Who we are (Controller)
Controller: Quouch UG (haftungsbeschränkt) Lohmühlenstraße 65, 12435 Berlin, Germany Email: hello@quouch-app.com
Data Protection Officer (DPO): We have not appointed a DPO because we are not legally required to do so under Art. 37 GDPR. For all privacy matters, contact hello@quouch-app.com.
Supervisory authority: You have the right to lodge a complaint with your local supervisory authority. For Berlin, this is the Berliner Beauftragte für Datenschutz und Informationsfreiheit.
---
2. What data we collect and why
We only collect personal data that we truly need, for specific purposes, and on a lawful basis. The data we collect depends on how you use our Services.
A) Account and Profile
Data: Name, email, password (hashed), username, profile photo, pronouns (if you choose to provide), short bio, city/country, languages, host/guest preferences, safer-space filters you select. Quouch is a queer community. Some things you choose to share (pronouns, safer-space filters, why you want in) can count as special-category data under Art. 9 GDPR, because they can reveal sexual orientation or gender identity. We only use that to run this space: who gets in, who sees whom, and the filters people set for their own safety. We do not sell it. We do not use it for ads. We do not try to infer it from your photos. You can leave optional fields blank. Purposes: Create and manage your account, enable community features, display your profile to other users if you choose to make it visible. Legal basis: Performance of a contract (Art. 6(1)(b) GDPR); our legitimate interests to provide and secure the Services (Art. 6(1)(f) GDPR). Where this is special-category data, we rely on your explicit consent when you choose to provide it (Art. 9(2)(a)) and, for information you make visible on your profile, Art. 9(2)(e).
B) Onboarding and Community Safety
Data: Application messages and answers to onboarding questions; status (pending/approved/declined); internal review notes. Purposes: Assess eligibility, community safety, reduce spam/abuse. Automation: We use Gemini (Google) to assist reviewers by highlighting signals in the application message text only. Decisions are not made solely by automated means. Special categories: Joining a queer community can involve special-category data. We use application answers only to decide eligibility and keep the space safer. If you put extra sensitive information in a free-text box we did not ask for, we do not use it for anything else and we delete or restrict it when we find it. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) to protect our community; legal obligations where applicable (Art. 6(1)(c)); Art. 9(2)(a) where you choose to provide special-category data.
C) Hosting and Booking
Data: Host listing details (home description, photos), approximate location (city/area) and, if provided for booking logistics, exact address; availability, booking information, messages between host and guest. Purposes: Enable listings, show relevant results on maps, manage bookings, messaging between users, fraud prevention, dispute handling. Legal basis: Contract (Art. 6(1)(b)); legitimate interests in running a safe platform (Art. 6(1)(f)); legal obligations (Art. 6(1)(c)) for tax/accounting. Location sharing controls: By default, we show only an approximate location on public maps and to non‑booked users. If a booking is confirmed, we may share the exact address between host and guest for the legitimate purpose of the stay and logistics.
D) Payments and Subscriptions
Data: Name, email, price, currency, plan, transaction IDs, partial card details (last 4), billing address (if provided). Processor: Stripe. Purposes: Process payments, prevent fraud, manage receipts, comply with financial and tax laws. Legal basis: Contract (Art. 6(1)(b)); legal obligations (Art. 6(1)(c)); legitimate interests in preventing fraud (Art. 6(1)(f)).
E) Communications
Data: Transactional emails (e.g., verification, notifications, receipts), support emails, newsletter preferences. Processor: Brevo (transactional and newsletters). Purposes: Operate the service, send important notices, send newsletters if you subscribe. Legal basis: Contract (Art. 6(1)(b)) for service messages; consent (Art. 6(1)(a)) for newsletters; legitimate interests (Art. 6(1)(f)) for service quality and abuse prevention.
F) Analytics and Product Improvement
Tools: Amplitude, Google Analytics 4 (GA4). Data: Pseudonymous usage data (events, device/browser info, pages/screens visited). IP addresses are truncated/anonymised where available. Purposes: Understand how the Services are used, fix issues, plan improvements. Legal basis: Consent via Cookie Banner (TTDSG/GDPR) for non-essential analytics. If you do not consent, we minimise or disable these tools.
G) Advertising and Social Media
Tools: Meta Ads and TikTok Ads (including pixels/SDKs where permitted) and custom audiences (hashed contact lists).
Purposes: Measure ad performance, avoid showing ads to existing users, re‑engage users, and run campaigns.
Legal basis: Consent (Art. 6(1)(a) GDPR; TTDSG). In the EU/EEA we do not load on‑site Meta/TikTok tracking. Where permitted outside the EU/EEA, trackers load only after consent via Cookiebot.
Custom audiences (email uploads): We may upload hashed email addresses to Meta and TikTok to build exclusion/re‑engagement audiences. We upload only minimal identifiers (email, hashed) and never special‑category data. Platform providers act as independent controllers for matching and ad delivery. You can opt out at any time (see Section 7) and we will suppress your email from future uploads.
Our compliance commitments:
- We do not send special-category data (pronouns, filters, application answers, or anything that reveals sexual orientation or gender identity) to ad platforms. We do not try to infer it for advertising.
- In the EU/EEA, we do not load the Meta Pixel or TikTok SDK in our Services at this time. Ads may run without on‑site tracking.
- Where ad tools are permitted (e.g., outside the EU/EEA), they load only after prior consent via Cookiebot and remain disabled otherwise.
- We do not build lookalike audiences from data that reveal or could reasonably be used to infer protected characteristics.
H) Maps and Geolocation
Web maps: Mapbox on the Website. Mobile maps: OpenStreetMap (OSM) in the app. What loads: When a map tile loads, Mapbox/OSM may receive your IP address and device data as independent controllers. Legal basis: Consent (TTDSG) where required for third‑party embeds; contract/legitimate interest for core functionality (e.g., displaying location after booking). Controls: On the Website we use a consent‑controlled, two‑click loader so third‑party map content only loads after you enable it via Cookiebot, unless it is strictly necessary for a requested function (e.g., after a booking is confirmed).
I) Error Monitoring and Security
Tool: Sentry. Data: Minimal technical data about errors (e.g., timestamps, URLs, device/browser info, anonymised IP / user ID if necessary). We configure Sentry to avoid capturing sensitive payloads. Purposes: Keep the Services stable and secure, diagnose and fix bugs. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
J) Infrastructure and Internal Operations
Hosting/Cloud: Google Cloud Platform (GCP). Automation: Google Apps Script to pass limited data to our CRM (Brevo). Website: Framer (frontend; no direct personal data stored by Framer beyond what your browser sends to load assets). Legal basis: Contract (Art. 6(1)(b)) and legitimate interests (Art. 6(1)(f)).
K) App Stores
If you install the app, the Apple App Store or Google Play process data as independent controllers. Please see their privacy information in the respective stores.
---
3. Cookies, SDKs and Consent (TTDSG)
We use Cookiebot to display a consent banner, block non‑essential cookies/SDKs by default, and maintain a consent log. You can withdraw or change your consent at any time in the banner settings.
Categories:
- Essential (required to provide the Services, e.g., security, login, load balancing).
- Analytics (e.g., GA4, Amplitude).
- Marketing (e.g., Meta/TikTok pixels/SDKs).
- Functional/Media (e.g., embedded maps).
Important: In the EU/EEA, we do not load Meta or TikTok tracking technologies on our site/app. Outside the EU/EEA, these load only after consent. You can revisit your choices anytime via the Cookie settings link in the footer or the Cookiebot icon.
---
4. Do we share your data?
We do not sell your personal data. We share data only with:
a) Processors (acting on our instructions)
- Brevo (email delivery and newsletters)
- Stripe (payments)
- Amplitude (product analytics)
- Google Analytics 4 / Google Tag Manager (analytics/tag orchestration)
- Sentry (error monitoring)
- Google Cloud Platform (GCP) (hosting)
- Cookiebot (consent management)
- Google Apps Script (limited automation to Brevo)
We sign Data Processing Agreements (DPAs) with processors and require appropriate security and confidentiality.
b) Independent controllers or joint controllers
- Meta and TikTok for ads/attribution (only with consent)
- Mapbox (web maps) and OpenStreetMap (mobile maps) when you load map tiles
- Apple App Store and Google Play when you install/manage the app
In these cases, the third party determines its own purposes/means of processing. Please see their privacy notices.
c) Legal and safety
We may disclose data when required by law or to protect vital interests, investigate fraud/abuse, or defend legal claims.
---
5. International transfers
We primarily use EU/EEA data regions where available (e.g., EU regions in GCP, Amplitude EU Residency, Sentry EU, GA4 EU data settings). When transfers to third countries occur (e.g., to the United States), we rely on adequacy decisions (where applicable) or Standard Contractual Clauses (SCCs), and implement additional safeguards such as encryption, strict access controls, minimisation, and audit.
---
6. How long we keep data (retention)
We keep personal data only as long as necessary for the purposes described, or as required by law. Typical retention periods:
- Account data: Kept while your account is active; deleted or anonymised within 30 days after you request deletion, unless legal retention applies.
- Transactions (Stripe): 10 years where required for tax/accounting under German law.
- Support emails: 24 months after the last interaction.
- Newsletter preferences and consent logs: 36 months to evidence consent/withdrawal.
- Analytics and event data (Amplitude/GA4): 14 months (or shorter if you change preferences).
- Sentry error data: 90 days.
- Application reviews and moderation notes: 12 months to manage appeals and community safety.
- Server logs: 30 days, unless needed to investigate incidents.
We document exact retention values in our internal Record of Processing Activities.
---
7. Your rights
Under the GDPR, you have the following rights:
- Access to your data and copy of it (Art. 15)
- Rectification of inaccurate data (Art. 16)
- Erasure (Art. 17) and restriction (Art. 18)
- Data portability (Art. 20)
- Objection to processing based on legitimate interests or direct marketing (Art. 21). This includes the right to object to custom audiences: email hello@quouch-app.com and we will exclude your email from future uploads.
- Withdraw consent at any time without affecting prior processing (Art. 7(3))
- Not to be subject to a decision based solely on automated processing (Art. 22). We do not make such decisions.
To exercise your rights, contact hello@quouch-app.com. We may need to verify your identity before responding.
---
8. Children
Our Services are not directed to children under 16. We do not knowingly process children’s data. If you believe a child has provided us data, contact us to delete it. Minimum age: You must be 16 or older to use Quouch in Germany and the EU. We do not collect parental consent mechanisms.
---
9. Legal bases summary (Art. 6 GDPR)
- Contract (Art. 6(1)(b)): Account, profile, hosting/bookings, payments, essential communications.
- Legal obligation (Art. 6(1)(c)): Tax/accounting, responding to lawful requests.
- Legitimate interests (Art. 6(1)(f)): Security, fraud prevention, community safety, diagnostics, product improvement where strictly necessary.
- Consent (Art. 6(1)(a)): Newsletters, non‑essential analytics, advertising trackers, map embeds where not strictly necessary.
Special categories (Art. 9 GDPR): Where you choose to share data that can reveal sexual orientation or gender identity, we process it only to run the community (Art. 9(2)(a); Art. 9(2)(e) for what you make visible on your profile). We do not use it for ads, analytics products, or inference from photos. Extra sensitive text we did not ask for is deleted or restricted when we find it.
---
9.1 Sensitive data — clear commitments
- Quouch is a queer community. Optional profile fields and safer-space filters can be special-category data. We use them only to run this space.
- You can leave optional fields blank. If you put extra sensitive information in a free-text box we did not ask for, we do not use it for anything else and we delete or restrict it when we find it.
- Staff and vendors may not use special-category data for advertising, lookalikes, or product analytics. Error tools are configured to drop those fields.
10. Security
We implement appropriate technical and organisational measures, including encryption in transit and at rest, access controls and least‑privilege, regular backups, logging and monitoring, and staff training. We also minimise data passed to third parties (e.g., redacting error payloads to Sentry; restricting analytics identifiers).
---
11. How we use AI assistance (Gemini)
We use AI tools to assist human reviewers by highlighting potential risks in application messages. We send only the free-text application message, not your name or email. That message may include things you chose to say about who you are; we use the output only to help a human reviewer. We do not send it to ad platforms. Decisions are not made solely by automated means. Processing may involve transfers outside the EU/EEA; where applicable, we rely on Standard Contractual Clauses (SCCs) and implement additional safeguards.
---
12. Third‑party details (overview)
Below is an overview of key third parties. Exact data categories depend on your settings and consent.
- Brevo (Sendinblue SAS, EU): Transactional and marketing emails. Processor.
- Stripe (EU/US): Payments and anti‑fraud. Processor/independent controller for some activities. SCCs may apply.
- Amplitude (EU/US): Product analytics. Processor. SCCs; EU data residency available.
- Google Analytics 4 and Tag Manager (EU/US): Analytics/tag orchestration. Processor/independent controller per service terms. SCCs; IP anonymisation.
- Meta Ads / TikTok Ads (various): Ads/attribution and custom audience matching of hashed emails. Independent controllers. Loaded only with consent and subject to opt‑out.
- Mapbox (US/EU) and OpenStreetMap (EU community): Map tiles. Independent controllers when tiles load.
- Sentry (EU/US): Error monitoring. Processor. EU data residency available.
- Google Cloud Platform (EU/EEA preferred): Hosting. Processor. SCCs and EU regions where configured.
- Cookiebot (Cybot A/S, EU): Consent management. Processor.
- Apple App Store / Google Play: App distribution. Independent controllers.
- SimpleForm: Dev‑only; we do not send personal data.
We can provide signed DPA copies and a current sub‑processor list on request.
---
13. Sources of data
We primarily collect data directly from you. We may also receive:
- Technical data from your device/browser.
- Payment results from Stripe.
- Analytics/diagnostics from Amplitude/GA4/Sentry (subject to your consent settings).
- Public/aggregated data used for safety and fraud prevention.
We do not buy data from data brokers.
---
14. Is providing data mandatory?
Certain data is needed to create an account, use core features, or make payments. If you do not provide such data, some features may not work. Optional fields can be skipped.
---
15. Changes to this policy
We may update this policy from time to time. We will post changes here and, if significant, notify you via email or in-app. The latest version will always be available on our website.
---
16. Contact
Questions or requests about this policy and your rights: Email: hello@quouch-app.com Postal: Quouch UG (haftungsbeschränkt), Lohmühlenstraße 65, 12435 Berlin, Germany
---
Annex: Cookie and SDK list
Cookiebot provides a live overview of cookies and SDKs and their purposes. You can view and manage your preferences at any time via the consent banner.
---
Annex: Key definitions (short)
Personal data: Information that identifies or can identify a person. Processor: A provider that processes data on our instructions. Controller: The entity that decides why and how personal data is processed. Special categories: Sensitive data such as sexual orientation or health. SCCs: Standard Contractual Clauses for international transfers.