Privacy policy
What we collect when you use Sivamo, why we need it, who sees it and how you stay in control.
This text is a draft. It may change before it is final.
Who we are
Sivamo is an app for groups of friends who plan a trip together, and for organizers (agencies, clubs, guides) who sell trips to groups. It is operated by Appy Solutions EOOD, a single-member limited liability company with its registered office at ul. Ivan Susanin 45, vh. A, Sofia 1618, Bulgaria, EIK 206612061 (“we”). We are the controller of the personal data described here.
When you ask for a seat on a departure sold by an organizer, the organizer also receives your booking details and is responsible, as a separate controller, for what it does with them to run the trip. Its contact details are on the departure page.
We have not appointed a data protection officer, because the law doesn't require one for what we do. For anything about your data, write to privacy@sivamo.app: a person reads every message.
The short version
- We collect what we need to run your groups, trips and bookings, and nothing for advertising.
- We don't sell your data and we don't show ads.
- Your budget and your health notes are yours: the other members don't see them.
- Your location is shared only if you turn it on, and only your last position is kept.
- Our servers and database are in the European Union.
- You can ask for a copy of your data, or for it to be deleted, at any time.
What we collect
Your account. Your email address, the name you show, your language and how you sign in. If you sign in with Google, Apple or Facebook, they give us your name and email address. If you sign in with a code sent by text message, we keep your phone number.
What you add to a group. The days you can come, your preferences, your budget, proposals, links, votes, comments, chat messages and photos, the plan, expenses, receipts, tickets and the files you upload.
Health notes. If you choose to add them in your preferences, we keep them only after you tick the box that allows it. They are encrypted, only you see them, and you can delete them at any time.
Bookings. When you ask for a seat on a departure: your name, contact details, the people you travel with, your answers to the organizer's questions and the state of your payments.
Identity checks. Some groups open to people you don't know may ask their owner, or the people who ask for a seat, to confirm their identity. The check is made by our provider, which sees your document; we receive and keep only the result (confirmed or not), its date and, if it failed, the reason, without data from the document.
Payments. Card payments are handled by Stripe. We never see or store your full card number; we receive the amount, the status and a reference for each payment.
Organizers and partners. The name shown to travellers, contact details, company details (legal name, registration number, tourism licence, insolvency protection, address) and the payout account, which is set up with Stripe.
Reports. When you report a page: the page, the reason, what you wrote and, if you give them, your name and email (the email is stored encrypted). To stop abuse we keep a scrambled form of your IP address, not the address itself. The organizer of the page doesn't see who reported it.
The waitlist and support. What you tell us when you join the waitlist, the questions you ask the support assistant and the messages you send to the support team.
Feedback. When you send feedback from “Help and feedback” in the app or on the site: the type (problem, idea or something else), your message, the images you attach and, on the site, the email you choose to leave (stored encrypted). With it we send technical details that help us fix the problem: the page address without the codes in it, the app or site version, language, theme, screen size, browser, whether you were online, the recent errors on that page and the id of the matching error report. If you are signed in, the report is linked to your account, so you can follow its status and our reply in “My feedback”. To stop abuse we count reports for an hour, per account or, without an account, per IP address.
Technical data. Your IP address, browser and device, the pages you open, and error reports when something breaks. We count visits with a random identifier; how it works is in the Cookie policy.
Data others give us about you
Sometimes it isn't you who gives us your data, but someone you travel with:
- Invitations. A member of a group can invite you by email. We use your address to send you the invitation and your personal link.
- Companions. When someone asks for seats for several people, or adds you to a trip, they give us your name.
- What others write. Members can mention you in messages, comments and photos, and the organizer's team can write to you about the trip.
- Expenses. An expense can carry your name, as the one who paid or as one of those who owe.
- “Can't come”. If you answer that on a trip link, we keep the name and the message you wrote, so the group or the organizer sees your answer.
What you wrote in a group, and the expenses you are part of, are also part of the others' trip. When you leave a group or your account is deleted, they stay visible to the other members, so the group's history and accounts still add up, as in any app for shared expenses. If you want something specific removed, write to privacy@sivamo.app.
What you must give us
- To have an account: an email address or a phone number, or a Google, Apple or Facebook account.
- To ask for a seat or send a request to an organizer: your name and email, so the organizer can answer you.
- To publish departures: the firm details the law asks to show on the departure page.
Without them we can't give you that part of Sivamo. Everything else (a photo, the short profile, your budget, health notes, your location) is optional.
Who sees your name
In Sivamo you choose who sees your name, photo, short profile and the trips you go on: (1) only the organizer and their team, (2) also the people in your groups of friends, (3) also everyone on the same trip (the default) or (4) anyone, including the people who follow the trip. The organizer and their team always see your name, so they can organize the trip. Those who can't see you see only your initial, and in their messages you appear as “Someone”. What you write in a group (messages, votes, comments) stays visible to the group. In a group of friends, members always see each other. Location on the map has its own consent. You can change your choice at any time in Settings or from the link at the bottom of the emails.
Location on the group map
If the group's owner turns on the group map and you agree on the consent screen, we process your device's location (coordinates, accuracy and time) during the trip's days, only while the app is open, to show your last known position to the group members allowed to see it: in a group of friends, the members who also share theirs; on an organizer's departure, the organizer's team and, if you both choose “Visible to the group”, other participants.
We keep only your last position and delete it when you stop sharing, when you leave the group, when the owner turns the map off, and 24 hours after the trip ends. “Share my location now” sends your position once to the organizer's team and the members sharing theirs, and is deleted after one hour.
The legal basis is your consent, which you can withdraw at any time with “Stop sharing”. Locations are not used for advertising, analytics or profiling, and are not sent in notifications or emails.
The AI features
Some features use AI: importing an offer, ideas for where to go, making the plan, summaries, translations of messages and comments, and the support assistant. For these, we send the AI provider only what the feature needs, for example the text of the offer or the group's decisions. Your health notes and your exact budget are not sent.
Our AI provider is Anthropic. It processes this data on our behalf and, under its commercial terms, does not use it to train its models. If you connect your own AI account (through OpenRouter), the text for your requests goes to the provider you chose, under your own terms with it.
The support assistant in the app is an AI, not a person. It answers from our help articles. AI answers can be wrong: check what matters (prices, opening hours, safety) before you rely on it.
Automated decisions
We don't make decisions about you based only on automated processing that have legal effects for you or affect you in a similar way (art. 22 GDPR). The AI makes suggestions; you and your group decide. Lists such as “Trips with free seats” are matched to the group's countries, dates and theme, not to a profile of you. Reports are decided by a person.
Why we use your data, and on what legal basis
- To provide the service you asked for (your account, groups, the plan, the trip, bookings and payments): the contract with you (art. 6(1)(b) GDPR).
- To keep the service safe and working (preventing abuse and fraud, fixing errors, limiting requests, counting visits in aggregate, handling reports, reading the feedback you send): our legitimate interest (art. 6(1)(f) GDPR).
- Location, push notifications and health notes: your consent (art. 6(1)(a) and, for health notes, art. 9(2)(a) GDPR), which you can withdraw at any time.
- Invoices, payment and tax records, and the duties of the Digital Services Act for reports: our legal obligations (art. 6(1)(c) GDPR).
We send emails about your trips, bookings and account. Other emails, such as the digest of a group, can be turned off in Settings or from the link at the bottom of each email.
Where your data is kept
Our database, files and backups are in the European Union. Some providers (for example Anthropic, Stripe, Cloudflare, Google, Apple and Facebook) may process data outside the European Economic Area. In that case the transfer relies on an adequacy decision, such as the EU–US Data Privacy Framework, or on the European Commission's standard contractual clauses.
How long we keep it
- Your account and your groups: as long as you have the account. When it is deleted, we delete or anonymize your data within 30 days, except what the law requires us to keep and what stays with the group, as explained above.
- Bookings on a departure: anonymized 24 months after the departure ends, or 30 days after you ask the organizer to delete them.
- A departure draft started without an account: 30 days.
- Questions to the support assistant: the text is deleted after 90 days.
- Feedback and the images attached to it: deleted 12 months after you send it. If your account is deleted sooner, the report stays without your account and email.
- The waitlist: 12 months after your last request, if you weren't let in.
- Reports and our decisions on them: as long as we need them to handle the report, to answer a complaint about the decision and to meet our duties under the Digital Services Act.
- The result of an identity check: as long as we need it for the group or the request it was made for.
- Location: only your last position, as described above.
- Invoices and payment records: as long as tax and accounting law requires.
- Backups: encrypted, and deleted after 30 days.
Your rights
You have the right to access your data, to have it corrected or deleted, to restrict or object to how we use it, to receive it in a portable format, and to withdraw your consent at any time, without affecting what was done before.
Some choices are in the app: Who can see me and the notifications are in Settings. For everything else, write to privacy@sivamo.app. We answer within one month.
You can also complain to a data protection authority:
- in Bulgaria, where we are: the Commission for Personal Data Protection (CPDP), bul. „Prof. Tsvetan Lazarov” 2, Sofia 1592, www.cpdp.bg;
- in Romania: the National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro;
- or the authority of the country where you live or work.
Security
Connections are encrypted, some personal details (such as health notes and reporters' emails) are stored encrypted, backups are encrypted, and only the people who need it can reach the systems. Error reports are cleaned of personal data before they are sent. No system is perfectly safe: if a breach puts your data at risk, we will tell you and the authority, as the law requires.
Children
You need to be at least 16 to create an account. Younger travellers can take part in a trip with a parent or guardian, who is responsible for what they share.
Changes to this policy
When we change this policy, we update the version date at the top. If the change matters for how we use your data, we tell you by email or in the app before it applies.