Privacy Policy
Version 1, effective 5 October 2026
[OWNER: publish this version only once the retention clean-up (plan Stage 5) and the Export / Erase tools (plan Stage 4) are live: this policy promises both.]
This policy explains what personal data the App collects, why, who sees it, how long we keep it, and the rights you have. It covers everyone who uses the App: Guests, and Partners: Providers, Guesthouse owners and Zone Managers.
The English version of this policy is the binding one. Translations into other languages are made by AI, for your convenience only; if a translation differs from the English, the English prevails.
1. Who we are
The App at localinfo.club is run by DBM AI Ltd, a company registered in England and Wales (company number
12834746), registered office 60 26th Avenue, Hull, England, HU6 9SJ ("we", "us").
We are the controller of the personal data described in this policy: we decide why and how it is used.
- Privacy questions and requests: contact@dbm-ai.com
- Anything else: contact@dbm-ai.com
- Post: DBM AI Ltd, 60 26th Avenue, Hull, England, HU6 9SJ
2. Words we use
- Guest: a person using the App to find and book activities.
- Provider: a business or person offering activities through the App.
- Guesthouse: a host whose QR code a Guest scanned; its owner earns a share of our commission.
- Zone: an area the App runs in.
- Zone Manager: the person or business that runs a Zone under an agreement with us.
- Partner: a Provider, Guesthouse owner or Zone Manager.
- Request: a Guest asking for offers. Offer: a Provider's answer. Booking: the Offer a Guest chose.
- Strike: a confirmed no-show, or a late cancellation.
3. What we collect about Guests
| What | When and how | Why |
|---|---|---|
| Phone number (required) | on the phone screen, before your first Request | to identify you; to keep your reliability record; so you can find your booking (phone number + date); so a Zone Manager can call you if there is a dispute about a Booking |
| Email address (optional) | on the phone screen, if you give it | to send your booking confirmation and a secure link back to your booking |
| Language | the language of the page when you give your phone number | to write to you in your language |
| Device and session identifiers | cookies (section 13) | to keep your session and your bookings on your device |
| One location reading (GPS coordinates and their accuracy) | only when you tap "use my location" | to confirm you are in the Zone |
| Your party and timing (number of adults and children, day and time) | the questions before a Request | to match you with suitable Offers |
| Requests, the Offer you chose, your Booking and its check-in code | while you use the App | to deliver your Booking |
| Reliability record: the outcome of each Booking (completed, no-show, early cancellation, late cancellation), with a category and a short note written by the Zone Manager | after each Booking ends | to protect Providers from repeat no-shows (section 6) |
| Ratings: stars and an optional comment | after a completed Booking, if you choose to rate | to give Providers an honest public rating |
| IP address | every time your device contacts the App | to block password-guessing and booking-lookup abuse |
| Records of the emails and calls we send | when we send them | proof of delivery and fixing faults |
We do not ask for your name. We collect no payment card details today (see section 12).
Some of this data is created by others, not by you: the outcome of a Booking and its note are recorded by the Provider and the Zone Manager (who rules on any disagreement).
4. What we collect about Partners
| Partner | What we collect | What Guests can see |
|---|---|---|
| Provider | name; login email; contact phone; address and map location (also per activity); photo; bio; activities, prices and schedule; commission rate; ratings received; a count of no-show reports the Zone Manager found to be false; booking and settlement records | name, address, map location, photo, bio, activities, prices and rating. Never your contact phone or email |
| Guesthouse owner | name; login email; guesthouse name and address; commission share; booking and settlement records | the guesthouse name, on the welcome page |
| Zone Manager | name; login email; the Zone's contact phone; settlement records | nothing. Your contact appears in the welcome emails we send to Partners in your Zone |
Your account may be set up for you by us or by your Zone Manager, using details you gave them. Guests' ratings and comments about a Provider are personal data about that Provider too.
5. Why we use your data, and our lawful basis
UK data protection law requires a lawful basis for each use. We do not rely on consent for any of them.
| Use | Lawful basis |
|---|---|
| Your phone number, Requests, Bookings, check-in, booking confirmation email; Partner accounts and their records | Contract: we need it to provide the service you asked for (UK GDPR Art. 6(1)(b)) |
| The reliability record and the Strike gate; keeping a hashed phone number with its Strikes after erasure (section 11); the location check; security limits on logins and booking lookups; showing ratings | Legitimate interests: protecting Providers and the service from no-shows and abuse (Art. 6(1)(f)) |
| Booking and settlement financial records | Legal obligation: tax law requires us to keep them (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have weighed them against your interests and rights, and you can object (section 10).
6. Your reliability record and the Strike gate
The App works only if people turn up. So we keep a simple record of how each of your Bookings ended.
- A Strike is a confirmed no-show, or a late cancellation (cancelling inside the activity's own notice period). Cancelling early is never a Strike. A cancellation that was the Provider's fault never counts.
- Every Strike involves a person. A late cancellation or a no-show becomes a Strike only after the Zone Manager has ruled on it; the App only suggests which it was.
- What Providers see: when a Provider receives your Request, they see a summary of your record (how many Bookings were completed, missed or cancelled, and the Zone Manager's short notes). They never see your phone number, email or any detail that identifies you.
- The Strike gate: if you reach 5 Strikes, you can still make Requests, but only after the App confirms, by a location reading taken in the last 12 hours, that you are in the Zone. This is not a ban: it lifts itself each time you are confirmed in the area.
- Strikes count for 24 months, then they are deleted and stop counting.
If you think a Strike is wrong, email contact@dbm-ai.com with your booking details. A person will review it, and you can ask us to correct your record.
7. Who receives your data
We never sell personal data.
Within the App
- Providers receive your Request (activity, party, day and time), your reliability summary, and only the result of a location check as a badge ("in the area", "unconfirmed" or "no location"), never your coordinates. A Provider whose Offer you chose also sees that Booking and its check-in code. Providers never receive your phone number or email.
- Guesthouse owners see the Bookings that earn them a share (the activity and the amounts). They do not receive Guests' contact details.
- Zone Managers run their Zone on our behalf. They see the Bookings and reliability rulings in their Zone, and your phone number if they need to call you about a dispute.
Companies that process data for us (processors)
| Company | What they do for us | Where |
|---|---|---|
| Amazon Web Services (EC2, SES) | host the App, its database and its backups; send our emails | Frankfurt, Germany |
| Twilio | place phone calls to Providers announcing a new Request. The call says the party size, the day and the time. It contains nothing that identifies a Guest | United States |
| OpenAI | translate text Partners write (activities, bios, features, conditions) and the App's own wording. No Guest data is sent | United States |
Each processor acts only on our instructions, under a contract that requires it to protect the data.
Others
- OpenStreetMap Foundation (UK) supplies the map images. Your device asks its servers for them directly, so it receives your IP address. It also runs Nominatim, the address search used only in the back office by Zone Managers and us, which receives the searcher's IP address and the address typed. It handles both under its own privacy policy.
- We may disclose data where the law requires it, for example to the police or a court, or to protect someone's safety.
8. Transfers outside the UK
- Our servers are in Germany. UK law recognises the European Economic Area as giving adequate protection, so no extra safeguard is needed.
- Twilio and OpenAI are in the United States. For each we rely on the UK Extension to the EU-US Data Privacy Framework (the "UK-US data bridge"), or, where a provider is not certified under it, the UK International Data Transfer Addendum to the EU standard contractual clauses. Contact us for a copy of the safeguard.
9. How long we keep data
| Data | How long | Then |
|---|---|---|
| Guest session | 30 days after it expires (sessions last 14 days) | deleted |
| GPS coordinates | 24 hours | the coordinates are wiped; only the in-area result stays |
| Requests and Offers | 12 months | the link to the Guest is removed |
| Strikes and the reliability record | 24 months, rolling | deleted; older Strikes stop counting |
| Guest phone number, email and language | 24 months after your last activity | deleted |
| Bookings and financial records | 6 years (tax law) | if you ask us to erase your data, the link to you is removed straight away; the amounts stay |
| Ratings | while the Provider is on the App | nothing more (already anonymous to Providers) |
| Records of emails and calls sent | 90 days | deleted |
| Partner login sessions | until they expire (2 weeks) | cleared every day |
| Background task records (an email we queued may hold your address) | 30 days | deleted |
| Partner accounts | while active, then 12 months after you leave | deleted or anonymised; financial records stay for 6 years |
| IP addresses kept for security limits | 24 hours | deleted |
| Server logs (which include IP addresses) | 14 days | deleted |
| Backups | 14 days | overwritten |
Data you ask us to erase may remain in a backup for up to 14 days, until that backup is overwritten. We do not restore it from backups except to recover from a failure, and if we do, we erase it again.
10. Your rights
You have the right to:
- access the personal data we hold about you, and get a copy;
- rectify (correct) data that is wrong or incomplete;
- erase your data (section 11 explains one limit);
- restrict how we use your data while a complaint is checked;
- object to uses based on legitimate interests (sections 5 and 6). We will stop unless we have compelling grounds that override your interests, for example protecting Providers from repeat no-shows;
- portability: receive the data you gave us in a machine-readable file (we provide it as a JSON file).
How to use them: email contact@dbm-ai.com. We first check that you are who you say you are:
- Guests: we call you back on your phone number, or ask for the check-in code of one of your Bookings.
- Partners: we reply to your login email address.
We answer within one month. If a request is complex, we may extend this by up to two more months and will tell you why. There is no charge, unless a request is clearly unfounded or excessive.
There is no button in the App to delete your own data. This is deliberate: it protects you if someone else gets hold of your phone, and it keeps the no-show record Providers rely on (section 11).
11. Erasure and the Strike record
When you ask us to erase your data:
- If you have no Strikes in the last 24 months, we delete everything we hold about you, except the anonymised financial records the law requires us to keep (section 9).
- If you have Strikes in the last 24 months, we delete everything (including your email address in our records of emails we sent you) except a scrambled code made from your phone number (a keyed hash: nobody reading it can see the number) and the Strikes themselves. If the same phone number is used in the App again, the Strikes are matched back to it. They are deleted when they reach 24 months, and the code goes with them.
Why: otherwise anyone could erase a no-show record and book again with a clean history, and Providers would lose the protection the record gives them. We keep the minimum needed for that purpose, for no longer than the Strikes would have counted anyway.
12. Payments
No payments go through the App today: you pay the Provider directly.
When payments are switched on in a Zone, they will be processed by Stripe. Your card details will go directly to Stripe and will never reach our servers. Stripe will act as an independent controller for its own fraud-prevention and legal-compliance processing, under its own privacy policy. [OWNER: add, when payments are specified, who receives each payment and what records each party keeps.]
13. Cookies and browser storage
We use only cookies that are strictly necessary for the App to work. We use no advertising, analytics or tracking cookies, so we do not show a cookie banner.
| Name | What it does | How long it lasts |
|---|---|---|
guest_session |
keeps your current Guest session (signed, so it cannot be forged) | 14 days |
guest_device |
links your device to your sessions and Bookings (signed) | 14 days |
lang |
remembers the language you chose | 1 year |
csrftoken |
protects forms against cross-site attacks | 1 year |
sessionid |
keeps a Partner logged in | 2 weeks |
bk-collapsed (browser storage, not a cookie) |
remembers whether you folded the booking banner | until you clear it |
You can delete cookies in your browser's settings at any time. Without them, the App cannot keep your session or show you your Bookings on that device.
14. Your location
- We ask your device for its location only when you tap "use my location". Your browser asks your permission first, and you can say no: you can still choose your Zone by hand or by scanning a QR code.
- We store one reading (coordinates and accuracy) and use it to work out whether you are in the Zone.
- Providers see only the result ("in the area", "unconfirmed" or "no location"), never your coordinates.
- The coordinates are wiped after 24 hours. Only the result stays, with your session.
15. Children
You must be 18 or over to make a Request. Children in your party appear only as a number. We collect no other information about them.
16. Keeping data safe
- All connections to the App are encrypted (HTTPS).
- Guest cookies are signed so they cannot be altered.
- Only people who need it can see personal data: a Provider sees only their own Requests and Bookings, and a Zone Manager only their own Zone.
- Login attempts and booking lookups are limited, to stop guessing.
If a data breach puts your rights at risk, we will report it to the ICO within 72 hours, and tell you directly if the risk to you is high.
17. Complaints
If you are unhappy with how we use your data, please tell us first at contact@dbm-ai.com.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator: ico.org.uk/make-a-complaint, helpline 0303 123 1113.
18. Changes to this policy
- Each version of this policy has a number and a date, shown at the top.
- Guests always see the current version, linked on the phone screen and at the foot of every page.
- Partners are asked to accept their updated terms when they next log in after a change; the current policy is linked on that page.
- For an important change, we will make it visible in the App before it takes effect.
Earlier versions are available on request from contact@dbm-ai.com.