Privacy Policy — Plan Roam

Effective date: 16 October 2026

Last updated: 26 October 2026

This version replaces the version of 22 July 2026. You can ask us for a copy of an earlier version at support@planroam.com.

This Privacy Policy explains how Plan Roam handles personal data when you use the Plan Roam apps, the website planroam.com and our related services. It is information for you, not a contract. Reading it or using Plan Roam does not mean you consent to anything. Where we rely on your consent, we ask for it separately, and you can withdraw it at any time.

Privacy at a Glance

Question	Short answer	Read more
Who is responsible for my data?	Plan Roam, operated from Türkiye by an independent developer. Contact: support@planroam.com	Section 1
What do you collect?	Your account and profile, the content you create (plans, places, photos, comments, messages), location when you allow it, purchase records, device data and usage data (in current app versions our own analytics; in older Android versions Google Analytics for Firebase)	Section 3
Who can see my content?	It depends on your settings. Public profiles and public content can be seen by anyone. If you open a place someone else created, that person can see that you viewed it. Live location is shown only to the audience you choose	Sections 6 and 7
Do you use AI?	Yes, for AI plans, AI stops, automatic translations and cover images, and to help check content. App version 1.5.0 and later ask for your permission before your first AI request, and you can withdraw it at any time in Settings → AI features. We translate your places with AI, and let an AI provider check them, only if you allowed AI features. We send the request text to our AI providers, not your name or e-mail address. Our AI providers may not use it to train their models	Section 8
Do you check content automatically?	Yes. Text and images are checked automatically, mostly by models on our own servers. An AI provider may also help check the places of users who allowed AI features. Repeated violations can lead to an automatic suspension. You can ask a person to review a decision	Section 9
Do you sell my data or show me ads?	No. We do not sell personal data and we do not show third-party ads. Current app versions do not track you across other companies’ apps or websites. Older Android versions (1.4.x) include Google Analytics for Firebase, which sends usage data and your advertising ID to Google	Sections 10 and 12
Will you send me marketing?	Only if you agree in the app: reminders and offers as push notifications (app version 1.5.0 and later). You can stop them at any time in Settings → Notifications. We do not currently send marketing e-mails or SMS	Section 11
Where is my data?	Our servers are in Germany and our database is in Belgium. We run Plan Roam from Türkiye. Some providers process data in the United States and other countries	Sections 12 and 14
How long do you keep it?	It depends on the data. For example: usage data 180 days; the text of AI requests 30 days; your account until you delete it, plus a 30-day restore period	Section 15
How do I delete my account?	In the app (Profile → gear → Account → Delete account; older versions: Account Settings → Delete Account), or by e-mail to support@planroam.com. You have 30 days to change your mind. Then we delete all your data, including your plans, places, photos, comments and messages. We keep only one-way codes of your device identifier and e-mail address for 12 months, to prevent abuse, and, for an App Store or Google Play subscription, a purchase record of its credits under one-way codes for at most 13 months, so that its credits are added correctly when it is restored on another account	Section 16
What are my rights?	Access, correction, deletion, a copy of your data, objection and more, depending on where you live	Section 17 and the regional sections
Can children use Plan Roam?	No. Plan Roam is only for people aged 18 or older	Section 19

1. Who We Are and What This Policy Covers

Plan Roam (“Plan Roam”, “we”, “us”) provides the Plan Roam mobile apps for iOS and Android, the website planroam.com and the related services (together, the “Service”). Plan Roam is operated from Türkiye by an independent developer. We are the developer shown on the Plan Roam listings in the Apple App Store and Google Play.

Plan Roam is the controller of your personal data. This means we decide why and how your personal data is processed.

Contact for privacy questions and requests: support@planroam.com. Please write “Privacy” in the subject line. You can write to us in English or Turkish. Section 17 explains how to make a request and how quickly we answer.

What this policy covers. This policy applies to:

the current Plan Roam apps for iOS and Android;
older versions of the apps that are still in use;
the website planroam.com, including the e-mail verification page and the pages that show shared plans and profiles; and
our servers at api.planroam.com and the e-mails and notifications we send.

App versions. In this policy, “older app versions” means app versions 1.4.x. “App version 1.5.0 and later” (or “current versions”) means the newer apps. Where they work differently, we say so. Some changes happen on our servers rather than in the app. We describe these as “from the server update that comes with app version 1.5.0”. They then apply to all app versions, including older ones.

Mainland China. The Service is not directed at users in mainland China.

2. How to Read This Policy

“Personal data” means information about you as an identifiable person, for example your e-mail address, your username or your device identifier.
“Content” means anything you create or upload in Plan Roam: for example profile details, plans, stops, notes, places, photos, comments, likes and messages.
“Connections” means the people you are connected with in Plan Roam.
This policy tells you what we do. Our Terms of Use set out the rules for using the Service.
The regional sections at the end add information that the law of your country requires. Please read the part that applies to you.

3. The Personal Data We Collect

We collect the data listed below. Some device and technical data (Section 3.12) is collected automatically whenever you use the apps, even without an account, because the apps and our servers cannot work without it. Account data (Section 3.1) is needed to create an account. Everything else is optional: if you do not provide it, only the related feature will not work.

3.1 Account data

Your name, username and e-mail address.
Your password, which we store only in a protected (hashed) form.
If you sign in with Apple or Google: the account identifier that Apple or Google gives us, and the e-mail address they share (with Apple, this can be a private relay address). With Google, we also receive your name. We do not store your Google profile picture.
A phone number, only if you gave us one. The apps do not ask for it.
Verification codes we send you, for example to confirm your e-mail address, to reset your password or to confirm a sign-in.
Whether e-mails reach your address: if our e-mail providers tell us that an e-mail to it bounced, was blocked or was reported as spam, we note this with the provider, the reason and the date.

3.2 Profile data

Your profile photo, bio and join date.
A Pro badge that shows when you have an active Pro subscription. In the app it appears as a check mark and is called “Verified” (see Section 7).

3.3 Content you create

Plans: plan names, descriptions, cover images, stops (names, places, dates, times, notes and coordinates), and who created or changed them. Plans can be private, shared with your connections, or public.
Places: the title, description, photo and coordinates of places you add to the map, and the area (town and country) we derive from the coordinates.
Comments and likes on places.
Places you open: when you open a place created by someone else, we record that you viewed it. The creator of the place can see who viewed it (see Section 7).
Collaboration: invitations, join requests, plan members and their roles.

3.4 Messages (chat)

The messages you send in direct chats and plan chats, reactions, replies, edits and when messages were delivered and read.
A short preview of the latest message in a conversation, and message previews in notifications.

3.5 Connections, invitations and blocks

Connection requests, your connections, and the people you block.
For people suggestions (Section 7): which accounts we have shown you as suggestions and on which days, and, on a connection request you send to someone we suggested, a note that the request came from a suggestion.

3.6 Location

Device location, only if you allow it in your device settings. We use it to show you on the map, find places and plans near you, and draw routes.
Live location, only while you share it (see Section 6).
Map area: the part of the map you are looking at, which we use to load places and to deliver live positions to you.
Coordinates you choose: for example the pin of a place you add or a stop in a plan.
Place searches: the text you type and the map area you are viewing. In the iOS app, these are sent to Apple (Apple Maps) to find results; in the Android app, to Google (Places).
Address lookup: when you tap a point on the map, its coordinates are used to find its address or name. In the iOS app, the address is looked up with Apple (Apple Maps) and, if Apple Maps cannot answer, with OpenStreetMap (Nominatim). In the Android app, your device’s built-in address lookup is used first, then Google (Maps Platform) and, if neither can answer, OpenStreetMap (Nominatim).

3.7 Photos

Photos you upload (profile photo, plan cover, place photo).
The apps create a new copy of each photo before upload. Location data (GPS) and camera details stored in the photo file are not uploaded.
If you share a photo into Plan Roam from another app, the app may read the photo’s location on your device to suggest where the place is. That location becomes part of the place only if you save the place.
On iOS and Android, before you post a place photo, the app checks on your device whether the photo shows a large face or a lot of text (for example a selfie or an advert). This check does not identify anyone. Nothing from it is stored or sent to us.

3.8 AI requests

The text you type when you ask for an AI plan or AI stops, and the plan details needed for the request. We keep the text for up to 30 days (see Section 8).
Your choice about AI features (Section 8): whether you allowed them, refused them or withdrew your permission, when, the version of the permission screen, and the platform and app version you used. We also keep your last 20 choices.

3.9 Purchases and credits

What you bought (Pro subscription or credit pack), when, its status (for example active, renewed, cancelled or refunded) and the store’s transaction identifiers. Apple and Google send us notifications about purchases, renewals and refunds.
For each App Store or Google Play subscription, a purchase record that we keep separately from your account: one-way codes of the store’s identifiers of the purchase and of its paid billing periods, which credits of each paid billing period were added to an account or will not be added under our rules, whether the yearly bonus was added, and whether the store refunded the period. It is not deleted with your account (Section 16).
Your credit balance and credit history (credits received and spent, and why).
We never receive your card or bank details. Apple or Google handles payment.

3.10 Reports, safety and support

Reports you file, and reports other people file about you or your content. From the server update that comes with app version 1.5.0, a report includes a copy of the reported content, whichever app version was used.
Results of automated checks, warnings, suspensions and other safety measures, and any appeal you make.
Feedback you send in the app (rating, message, app and system version, language) and e-mails you send us.

3.11 Notification settings and terms acceptance

Your push-notification token and, in app version 1.5.0 and later, your notification choices, including whether you agreed to reminders and offers, and a record of each choice (date, platform, app version, language and the version of the text you saw).
If you turn off e-mail reminders with the link in one of our e-mails or with your e-mail app’s unsubscribe button: a record of that choice (Section 11).
A note that we sent you the welcome e-mail, so that you get it only once (Section 11).
In app version 1.5.0 and later: which version of the Terms of Use was in force when you signed up, and when.

3.12 Device and technical data

Device model, operating system and app version, language and, in app version 1.5.0 and later, time zone.
A device identifier created by the app. On Android it is based on the Android device ID (ANDROID_ID). On iOS it is based on an identifier Apple provides to app developers.
In app version 1.5.0 and later, a random install identifier created when you install the app.
The IP address of your device, sign-in times, and the IP addresses used to sign in on each device.
The approximate country your device connects from, which our network provider Cloudflare derives from the IP address (only the country, never a city or a precise location). We save it with the device record and show it in security e-mails in our new e-mail design (Section 11). We also add it to two usage events: the app’s first start and a completed sign-up (Section 10).
Before you create an account: when the app starts for the first time, it registers the device with our servers (device identifier, model, system and app version, language, push token and IP address). This happens even if you never create an account.
Server logs, which record requests to our servers, including the IP address, the address of the request (which can contain search terms or map coordinates), the browser or app type, and the time.

3.13 Guest browsing (app version 1.5.0 and later)

Without an account, you can look at public places, public plans and public profiles, and search. When you do, we process your device data (Section 3.12) and, unless you switch it off, usage data (Section 3.14).

3.14 Usage data

In app version 1.5.0 and later: events about how the app is used, for example screens opened, features used, errors and purchases started. Section 10 explains this and how to switch it off. Older Android versions include Google Analytics for Firebase (Section 10).

3.15 Where the data comes from

From you, when you create an account, post content, use features or contact us.
From your device, automatically (device data, location if you allow it, usage data).
From other users, for example when they invite you, add you to a plan, mention you in content, or report you.
From Apple and Google, when you sign in with them, and when they tell us about purchases, renewals and refunds.
From map providers, which tell us the name of a place or area for a set of coordinates.
From our e-mail and network providers: Oracle and MailerSend tell us when an e-mail to your address bounced, was blocked or was reported as spam; Cloudflare tells us the approximate country of your device’s IP address.

4. Why We Use Your Data and Our Legal Bases

The table shows each purpose, the data we use and the legal basis under the GDPR and the UK GDPR. For users in Türkiye, the legal reasons under Article 5(2) of Turkish Law No. 6698 (KVKK) are in the table in the Türkiye section. For other countries, see the regional sections.

Purpose	Data used	Legal basis (EU/UK)	Required?
Create and run your account, sign you in, send verification and security e-mails (including new-device sign-in notices)	Account, device and technical data; in security e-mails, the device, IP address, approximate country and time of the sign-in or change	Contract; for account security: legitimate interests	Required for an account
Follow your choice to turn off e-mail reminders, and keep our e-mails deliverable (Section 11)	A one-way code (hash) of your e-mail address with your choice, its date and how you made it; what our e-mail providers report about your address (bounced, blocked, reported as spam or unsubscribed), with the provider, the reason and the date	Legitimate interests (following your choice and being able to show it; delivering account and security e-mails reliably)	—
Send you one welcome e-mail after your e-mail address is verified, on how to get started, without offers (Section 11)	Name, e-mail address, language; the note that we sent it	Legitimate interests (helping new users get started). You can object (Section 5)	—
Plans, places, comments, likes, chat, connections, invitations and collaboration	Content, profile, messages	Contract	Needed only for the feature you use
Show your content and profile to the people your settings allow	Profile, content	Contract	—
Show the creator of a place which users opened it	Your username and profile, the place you opened and when	Legitimate interests (letting creators see interest in their places). You can object (Section 5)	—
Suggest people you may know, and decide which accounts to suggest to whom (Section 7)	Your connections and their connections, the plans you are a member of, profile (name, username, photo, bio, join date), e-mail address and whether it is verified (only to recognise Plan Roam’s own accounts and real accounts), language, when you last used the app, connection requests, blocks, reports and other safety records, the accounts we have already shown you and when, and whether a connection request came from a suggestion	Legitimate interests (helping people find people they know, and suggesting real and relevant accounts). You can object (Section 5)	—
Translate place titles and descriptions, and notifications, into other languages automatically. We translate a user’s places with AI only if that user allowed AI features (Section 8)	Place text, notification text	Contract; legitimate interests (making content readable for all users)	Optional for your places: only if you allow AI features
Map, nearby places and plans, routes, place pins and place search	Device location, coordinates, map area, search text	Contract (features you use). The device permission is your choice	Optional
Live location sharing, only when you turn it on, to the audience you choose	Precise live location	Contract (a feature you ask for). The device permission is your choice	Optional
AI features (AI plans, AI stops, cover images), and a record of your choice about AI features	Your request text and plan details, time zone, language; your choice, when you made it, the platform and app version	Contract; for the record of your choice: legitimate interests (following your choice and being able to show it)	Optional: only when you use them and, in app version 1.5.0 and later, allow them (Section 8)
Purchases, credits and subscriptions, including refunds	Purchase records, credit history	Contract; legitimate interests (handling refunds and preventing fraud with credits)	Required for purchases
Safety and moderation: automated checks of text and images, decisions about where content appears (an AI provider reviews places only of users who allowed AI features), reports, blocks, warnings and suspensions	Content, messages, reports, account and device data	Legitimate interests (a safe service); legal obligation where the law requires us to act	—
Preventing abuse and fraud: limits on accounts and welcome credits per device, credit reversal after refunds, rate limits	Device identifier, IP address, account, purchase records	Legitimate interests	—
Preventing abuse after an account is deleted: stopping welcome credits from being claimed again, stopping people from getting around a suspension or closure with a new account, and applying the limit on accounts per device	One-way codes (hashes) of the device identifier and of the e-mail address of the deleted account, kept for 12 months (Section 16)	Legitimate interests (preventing abuse). You can object (Section 5)	—
Adding a store subscription’s credits correctly when it is restored on another account, also after an account is deleted: never twice for the same paid billing period, and, for a paid billing period that began after we started keeping these records, the credits of that period that no account received	Purchase record of the subscription: one-way codes (hashes) of the store’s identifiers of the purchase and of the paid billing period, which credits were added or will not be added, whether the yearly bonus was added and whether the period was refunded; no account, e-mail address, device identifier or payment amount (Section 16)	Legitimate interests (preventing abuse and providing the paid subscription correctly). You can object (Section 5)	—
Usage analytics and app tests (app version 1.5.0 and later), Google Analytics for Firebase (older Android versions)	Usage events, install and device identifiers, app and system version, language; for the app’s first start and a completed sign-up, the approximate country	Legitimate interests. In app version 1.5.0 and later you can switch it off; older Android versions have no switch (Section 10)	Optional
Notifications about activity (messages, invitations, plan changes, connection requests, likes, comments and updates about your places)	Push token, notification choices	Contract	Optional
Reminders and offers about Plan Roam (promotional notifications), only if you agreed in the app: for example a reminder before a welcome offer ends, or to use your AI credits	Push token, notification choices and the record of your agreement, language, time zone, platform and app version, sign-up date, offer status, credit balance and recent credit use, whether you have a Pro subscription, which first steps you have taken (for example creating a plan or a place, or adding a connection) and when you last used the app	Consent. You can withdraw it at any time (Section 11)	Optional: off until you agree
Service announcements from us (for example about changes to these documents, a service problem, planned maintenance or a required app update), by notification or e-mail	Push token, e-mail address, language, platform, app version	Legitimate interests (telling users about the Service)	—
Answer your questions, feedback and requests	E-mails, feedback, account data	Contract; legal obligation (for privacy requests)	—
Deal with legal claims and requests from authorities	As needed for the case	Legal obligation; legitimate interests	—
Run the website and keep it secure	IP address, browser data, pages requested	Legitimate interests	—

Our legitimate interests are: keeping Plan Roam safe and free of spam, abuse and illegal content; protecting accounts; following your e-mail choices and delivering our e-mails reliably; preventing fraud with credits and purchases; understanding how the app is used so we can fix problems and improve it; making content readable in other languages; letting creators see interest in their places; preventing the same abuse after an account is deleted; helping people find people they know through people suggestions; helping new users get started with a welcome e-mail; and telling users about the Service through service announcements. We have weighed these interests against your rights and freedoms. You can ask us for more details.

We rely on your consent only for reminders and offers (Section 11). For the other purposes above we do not rely on your consent, with one exception: the device permissions (location, camera and notifications) are your choice, and you can turn them off at any time in your device settings. In some countries, device permissions and live location sharing count as consent under local law; the regional sections say where.

The permission for AI features. App version 1.5.0 and later ask for your permission before your first AI request (Section 8). This permission is your choice, and we follow it. Under the GDPR, the UK GDPR and the Turkish KVKK, it is not the legal basis for the processing: the legal basis is the one in the table above (contract for the AI features you ask for; legitimate interests for translating and checking your places). If you refuse or withdraw the permission, we stop the related processing. We do not switch to another legal basis to continue it.

5. Your Right to Object

You can object. Where we rely on legitimate interests, you can object at any time, on grounds relating to your particular situation. Write to support@planroam.com. We will then stop, unless we have compelling legitimate grounds or need the data for legal claims.

You can withdraw your consent to reminders and offers at any time, without giving a reason: switch off Settings → Notifications → “Reminders & offers” (app version 1.5.0 and later), or turn off notifications in your device settings. Older app versions never receive them.

You can switch off usage analytics in Settings → “Share usage data” (app version 1.5.0 and later).

You can withdraw your permission for AI features in Settings → AI features (app version 1.5.0 and later). It takes effect at once.

You can ask us not to suggest your account to other users. Write to support@planroam.com. We will then no longer show your account in other users’ people suggestions.

You can turn off e-mail reminders with your e-mail app’s unsubscribe button or, in reminders in our new e-mail design, with the link in the reminder. The welcome e-mail has the same link, and we do not send it once you have turned off reminders. Account and security e-mails cannot be turned off.

6. Location and Live Location

Device location. With your permission, the app uses your device’s location to show you on the map, find nearby places and plans, add places and draw routes. You can change the permission at any time in your device settings.

Live location sharing is off unless you turn it on. You decide who sees your live position on the map:

Private: no one.
Connections: your connections.
Public: everyone using Plan Roam who is viewing the map, except people you have blocked.

You can also share your live location inside a plan. The members of that plan then see your position with your name, username and photo.

Safety note. Choosing “Public” lets people you do not know see where you are. Please choose carefully.

How it works. While sharing is on, the app sends your position to our servers about every 5 seconds while the app is open and about every 30 seconds in the background, when you have moved about 20 metres or more. We keep only your latest position: for sharing on the map, for about 2 minutes after the last update; for sharing inside a plan, for up to 10 minutes after the last update. We do not store a location history. To deliver positions to the people who can see you, we also keep the map area they are viewing for up to 6 hours.

How it stops. Sharing stops when you choose Private or turn off plan sharing, when you sign out, or when you remove the location permission.

In the background. On iOS, sharing continues in the background with the “Always” location permission. On Android, app version 1.5.0 and later shows a notification that stays visible while sharing is on. Older Android versions use the background location permission instead, after explaining this in the app.

7. What Other People Can See

Plan Roam is a social service. Depending on your settings, other people can see the following:

Your profile (username, name, photo, bio, join date and the Pro badge) is public. In app version 1.5.0 and later, people without an account and people who open a share link can also see it.
The Pro badge (a check mark next to the name, called “Verified” in the app) shows that the user has an active Pro subscription. It does not mean that we have verified anyone’s identity.
Public plans, public places and comments on public places can be seen by anyone, including people without an account (app version 1.5.0 and later) and through share links.
Content you share with your connections is visible to your connections. Plan content is visible to the plan’s members.
Your connections list (the people you are connected with) can be seen by other users who can see your profile.
Places you open: the creator of a place can see that you viewed it. If you create a place, you can see who viewed it.
Live location: visible only to the audience you choose (Section 6).
Messages show your name and profile to the people in the chat. Messages you sent stay in the other people’s chat history, also after you leave a chat. When your account is permanently deleted, your messages are removed and the other people see “Deleted account” (Section 16).
Blocked users cannot see your live location or send you direct messages. While they are signed in to the app, we also hide your profile, places and comments from them. Content you make public can still be seen by people who are not signed in.
Photos are delivered through web addresses. Anyone who has the address of a photo can open it, even without an account. Keep this in mind before you send someone a link.

Automated tools and human review may limit where content appears (Section 9).

People suggestions. In the app, we suggest people you may know. We find them among the people your connections are connected with, the people who are members of the same plans as you (small and recent plans count more) and, especially when you have few connections, active accounts, mostly ones that use the app in your language. We prefer accounts with a complete profile that have used the app recently. Accounts without a profile photo are not suggested. If a person has set their connections list so that only they can see it, we do not use their connections to suggest people to other users. A suggestion can show how many connections you have in common, and some of them.

We never suggest Plan Roam’s own accounts (staff, brand, test, app-store review and system accounts), people you are already connected with or have a pending request with, accounts you blocked or reported, accounts that blocked you, people whose connection request you declined or who declined yours in the last 6 months, or accounts that recently broke our rules or were reported by several users.

What we remember. So that people you do not add make room for others, we remember which accounts we have shown you as suggestions and on which days. We keep this for 30 days after we last showed you an account. For an account we showed you on several days without you adding it, we keep it a little longer, so that the account does not come back too soon, but never more than 90 days after we last showed it. If you send a connection request to someone we suggested, we note on the request that it came from a suggestion, only to count how useful suggestions are. The note is deleted when the request is accepted, declined or withdrawn. Other users cannot see these records.

Your account in other people’s suggestions. Your account can be suggested to other users in the same way. If you do not want this, write to support@planroam.com and we will stop suggesting your account (Section 5).

8. AI Features

Which features use AI.

AI plans: you describe a trip and we create a plan.
AI stops: we suggest stops for an existing plan.
Automatic translation: titles and descriptions of places written by users who allowed AI features are translated into other languages so that other users can read them. From the server update that comes with app version 1.5.0, some notifications from us are also translated.
AI cover images for plans.
Content review: automated tools, which can include an AI model, may help decide where places appear (Section 9). An AI provider reviews places only of users who allowed AI features.

What we send to our AI providers.

For AI plans: the text you type, your time zone, your language and the current date and time.
For AI stops: the text you type, the plan name, the names of the existing stops and of the neighbouring stops, your time zone and language.
For translations: the place text or notification text to be translated.
For cover images: the plan name, a short summary and the names of landmarks.
For automated review of places (when we use it): the place’s photo, title, description, coordinates and town and country.
We do not send your name or e-mail address. A pseudonymous code derived from your account ID may be attached, so that the provider can help us prevent abuse.

Which providers. Our servers choose the AI provider, whatever app version you use. Until the server update that comes with app version 1.5.0, AI text and AI images use Google (Gemini API); if a cover image could not be created, a short description derived from the plan (without account data) could be sent to the public image service Pollinations.ai. From that update, for all app versions, AI text features use Anthropic (Claude) or, when Anthropic is not available, Google (Gemini API); AI images use Google (Gemini API); automated review of places, when we use it, uses Anthropic (Claude); and Pollinations.ai is no longer used.

Your permission for AI features. In app version 1.5.0 and later, the app asks for your permission before your first AI request (an AI plan or AI stops), also when you use the app without an account. The permission screen says what is sent (the text you type and trip details such as plan and place names, your language and time zone; for checks of places, also the place’s text, photo and location), that your name and e-mail address are never sent, and to whom: Anthropic (Claude) for text, with Google (Gemini) as a backup, and Google (Gemini) for cover images. You can withdraw the permission at any time in Settings → AI features. It takes effect at once. You can allow AI features there again later.

If you have not given your permission in app version 1.5.0 or later (for example, you chose “Not now”), the app does not make the AI request: nothing is sent to AI providers and no credits are used.
Older app versions (1.4.x) cannot ask for this permission. If you have never made a choice, the AI plans and AI stops you request in an older app version still work. If you refused or withdrew the permission in a newer app version, our servers also refuse AI requests from older app versions, and no credits are used.
Your places. We translate the title and description of your places with AI, and let an AI provider review them (Section 9), only if you allowed AI features. Otherwise, your places are not translated with AI, and, where a review is needed, a person reviews them instead. Our administrators also do not translate your places with AI unless you allowed AI features. If you allow AI features later, we may translate your existing places that are missing translations, and send your places that are waiting for a review to the automated review.
If you withdraw your permission, this applies from then on. Translations already made stay with the place until you change its text or delete the place.

How the providers handle it. Anthropic processes this data on our behalf and may not use it to train its models. Anthropic deletes API inputs and outputs within 30 days, unless content is flagged for misuse of its services. We use the paid Gemini API. Under Google’s terms for its paid services, Google processes these requests under its data processing terms, may not use them to train its models or to improve its products, and keeps them only for a limited time, to detect misuse and to meet legal requirements.

We do not use your data to train AI models.

Please do not include personal information about yourself or other people in AI requests.

What we keep. AI plans and stops are saved as part of your plans, and we record in our data which plans and stops were created with AI. The app does not currently label AI plans, AI stops, AI cover images or automatic translations as AI-generated, but they are created by AI. AI cover images are generated by Google’s image model, which may add an invisible watermark. We keep the text of your AI requests with your credit history for up to 30 days, to handle questions about credits and to prevent abuse. After that, we remove the text and keep only the feature used and the number of credits. When your account is permanently deleted, we delete your credit history too (Section 16).

AI output can be wrong. It is created automatically and may be inaccurate or out of date. Check opening hours, prices, safety, entry rules and travel conditions yourself before you rely on them.

9. Automated Checks, Moderation and Decisions

We use automated tools and human review to keep Plan Roam safe.

Automated checks of text and images. Text you post or send (chat messages, comments, your name and bio, plan text and place text) and images you upload are checked automatically for abusive, hateful, sexual or other harmful content. The models run on our own servers. A message, comment, profile text, plan text or photo that fails the check is not posted. A place that fails the check is not shown to other users; it stays visible only to you.
Automatic suspension. Each blocked message, comment, profile text, plan text or image counts as a violation (places are not counted). An account is suspended automatically after 3 blocked images in total, or after 20 blocked texts within 30 days. While an account is suspended, it cannot be used: you cannot sign in or use the Service. A subscription you bought through the App Store or Google Play is not cancelled or paused by the suspension (see our Terms of Use, Section 18). We make these decisions automatically because this is necessary to enforce our Terms of Use, which are part of our contract with you. You can ask a person to review the decision at support@planroam.com.
Where content appears. Automated tools (including AI models) and human review may limit where content appears: for example only to you, only to you and your connections, or not in public areas such as the public map and search.
Automated review of places. When we use it, an AI provider (Anthropic) helps decide where a place appears (Section 8). We use it only for places of users who allowed AI features. Places of other users are reviewed by a person instead.
Reports from users. If several users report a place, it can be hidden until it has been reviewed.
Limits per device. To prevent abuse, we limit how many accounts can be created on one device, and welcome credits are limited to one account per device. After an account is deleted, we apply these limits, and stop people from getting around a suspension or closure, using only one-way codes of the device identifier and e-mail address, which we keep for 12 months (Section 16).
Private messages are checked automatically before delivery (if our checking service is briefly unavailable, messages are delivered without the check). We do not read private messages as a matter of routine. A person may look at a message when it has been reported to us, when this is needed to investigate abuse, fraud or a security problem, or when the law requires it.

Your rights. If a decision affects you, you can ask why it was made, explain your point of view, contest it and ask for a person to review it. Write to support@planroam.com. We will reply as soon as we can, and within the time limits the law sets. Section 17 and the regional sections explain your rights about automated decisions.

10. Usage Analytics, Device Storage and Tracking

Usage analytics in app version 1.5.0 and later. We measure how the app is used with our own analytics, stored on our own servers. Examples of events: screens opened, features used, errors, purchases started, notifications opened, and that a search was made (not what you searched for). Events are linked to your account when you are signed in, and to your install identifier and device identifier. They do not contain the text of your messages or AI requests, or your precise location. The events for the app’s first start and for a completed sign-up also contain the approximate country your device connected from (only the country, Section 3.12), so that we can count installs and sign-ups per country. We keep all events for 180 days.

We may also show different versions of some screens (for example the subscription screen) to different installs, to test which works better. The version you see is recorded with your install.

How to switch it off. Go to Settings → “Share usage data”. This is also available when you use the app as a guest. After you switch it off, the app stops sending usage events from that device and, if you are signed in, our servers also stop recording usage events for your account. The app may still send its install identifier with its requests. We use it for the screen tests described above and to link a sign-up to the version of the screens that was shown, not to record usage events. Events collected before you switched it off are deleted after 180 days, or when your account is deleted.

Older Android versions (1.4.x) include Google Analytics for Firebase, a Google service. It automatically collects app-usage events, an app-instance identifier, your device’s advertising ID, device information, purchase events and an approximate location derived from your IP address, and sends them to Google. Google keeps this data according to its own settings and terms. These versions have no in-app switch. You can reset or delete your advertising ID in your Android settings, or update the app to stop this collection.

Older iOS versions (1.4.x) do not include an analytics tool. They show Apple’s “Allow tracking” prompt, but they do not read the advertising identifier and do not track you, whatever you choose.

No cross-app tracking, no advertising. Current app versions do not track you across other companies’ apps or websites. We do not show third-party ads, and we do not sell personal data. (For older Android versions, see the Google Analytics for Firebase paragraph above.)

Data stored on your device. The apps store data on your device that they need to work:

sign-in tokens (on iOS in the Keychain; on Android, app version 1.5.0 and later encrypt them with a key protected by the Android Keystore);
the device identifier and, in app version 1.5.0 and later, the install identifier;
your settings, and a local copy of your data (for example plans, chats, places and recent searches), which is removed when you sign out (older Android versions keep recent map searches until you clear the app’s data or uninstall it);
in app version 1.5.0 and later, usage events waiting to be sent.

Sharing photos into the app on older iOS versions. Older iOS versions (1.4.x) pass a photo you share into Plan Roam through the device’s general clipboard, where other apps on your device can read it. App version 1.5.0 and later use a private, temporary channel instead.

11. Notifications and Messages From Us

Push notifications are delivered through the Apple Push Notification service (iOS) and Firebase Cloud Messaging by Google (Android). A notification can show the sender’s name and a preview of a message.

We send notifications about activity (messages, invitations and plan changes, connection requests, likes and comments, and updates about your places). We send reminders and offers (promotional notifications, for example a reminder before a welcome offer ends or a reminder to use your AI credits) only if you agreed in the app (app version 1.5.0 and later). Nothing is switched on in advance, and saying no changes nothing else. Older app versions and people who use the app without an account never get them. We never send them between 9 pm and 8 am in your time zone. When you agree, say no or withdraw, the app shows the date it saved your choice. Every two years after you agree, we remind you in the app that you agreed and how to stop; to keep receiving them you do not need to do anything. We may also send service announcements (for example about changes to these documents, a service problem or a required update) to everyone who has notifications turned on, including people who use the app without an account.

Your choices.

In app version 1.5.0 and later, go to Profile → gear (Settings) → Notifications. You can switch off each category: Messages, Places (likes, comments and updates about your places), Trips (plan invitations and changes) and Friends (connection requests). “Reminders & offers” is off until you agree: turning it on shows what you agree to, and turning it off takes effect at once. On Android, reminders and offers appear under the notification channel “Reminders & offers”. The “Push notifications” row opens your device’s notification settings.
In all versions, you can turn off notifications in your device settings. Service announcements cannot be switched off in the app; you can turn them off in your device settings.
We always send account, security, purchase and important service notices.

E-mail. We send e-mails about your account and its security: for example verification and sign-in codes, notices when your password or e-mail address changes, new-device sign-in notices, security alerts, and notices when your account is scheduled for deletion, closed, restored, deleted or suspended. We also reply to your requests. We may also send you service announcements by e-mail (for example about planned maintenance) and messages from our team about your account (for example that we added credits); you cannot turn these off. Security e-mails can show the device, the IP address and the time, so that you can tell whether it was you. We are moving our e-mails to a new design, one type of e-mail at a time. In the new design, security e-mails also show the approximate country (Section 3.12) and give the time in your device’s time zone if we know it, otherwise in UTC, and reminders contain a link to turn them off. Account and security e-mails cannot be turned off. While your e-mail address is not verified, we send up to two reminders before the account is deleted (Section 15). You can turn them off with your e-mail app’s unsubscribe button or, in the new design, with the link in the reminder. We then keep a record of your choice: a one-way code (hash) of your e-mail address, the choice, its date and how you made it, but not the address itself. After your e-mail address is verified (if you sign up with Apple or Google, right after you sign up), we send you one welcome e-mail on how to get started, without any offers. It has the same link to turn off reminders, your e-mail app’s unsubscribe button works for it too, and we do not send it if you have turned off reminders. If our e-mail providers tell us that an e-mail to your address bounced, was blocked or was reported as spam, or that you unsubscribed through them, we note this with your account. When one provider blocks your address, we send codes and account notices through our other provider, and we send no reminders to an address that reported us as spam or unsubscribed. We also do not send the welcome e-mail to such an address, or to an address our e-mails cannot be delivered to. A note that an e-mail bounced or was blocked can be removed before your account is deleted, for example when the provider no longer blocks your address or when we remove your address from the provider’s suppression list. A spam report or an unsubscribe stays noted until you change your e-mail address or your account is deleted. Replies to our e-mails go to support@planroam.com. We do not currently send marketing e-mails or text messages (SMS).

12. Who Receives Your Data

We do not sell personal data and do not share it for advertising.

We share personal data only with the recipients below, and only as far as each one needs it.

Service providers process data on our behalf to provide their services to us, under their terms of service and, where they offer them, their data processing terms, which include confidentiality and security commitments. We choose providers that protect personal data at least as well as this policy describes.
Providers under their own terms process data under the terms of the Google service we use: ML Kit and, in older Android app versions, Google Analytics for Firebase.
Independent recipients process data for their own purposes when you use their services through Plan Roam. These are Apple and Google for sign-in and app-store purchases, Google for Google Maps features, Apple for Apple Maps, and public map and image services. Their own privacy policies also apply. Google acts as an independent controller for data that its Maps features collect; see the Google Privacy Policy. We send them only the data needed for the feature you use.
Other users and the public, as described in Section 7.
Authorities, as described in Section 13.
A buyer or successor, if Plan Roam or the Service is sold, merged or transferred. The data would then be used under this policy, and we would tell you before your data becomes subject to a different privacy policy.

Data is sent over encrypted connections (TLS), either continuously while the Service runs or when you use the related feature. In the last column, “DPF” means the EU-U.S. Data Privacy Framework (with its UK extension where the provider states it), as stated by each provider; “SCCs” means the European Commission’s standard contractual clauses.

Recipient and location	Role and purpose	Data	When	Kept by the recipient	Safeguard for EU/UK transfers
Oracle (Oracle Cloud Infrastructure), servers in Frankfurt, Germany (privacy)	Service provider: hosting of our servers since 11 October 2026, including the live-location cache and our own moderation models; sending our e-mails (OCI Email Delivery)	All data our servers process, including the e-mails we send you (e-mail address, name, e-mail content)	Continuous; e-mails when we send you one	Until we delete it or stop using the service. Addresses to which an e-mail could not be delivered, or from which it was reported as spam, stay on Oracle’s suppression list (so that no more e-mails are sent to them) until we remove them	Data is stored in the EU. Oracle’s standard terms for its cloud services
Hetzner Online GmbH, a company based in Germany; the server we used is in the United States (privacy)	Service provider: our previous hosting provider, until 11 October 2026	Data our servers processed before 11 October 2026	No longer used to run the Service. The server is kept only as a short-term backup and will be deleted	Until the server is deleted	Hetzner’s standard terms for its hosting services
MongoDB, Inc. (MongoDB Atlas) on Google Cloud, St. Ghislain, Belgium (privacy)	Service provider: database	Account, profile, content, messages, purchase records, usage data	Continuous	Until we delete it. Deleted data can remain in encrypted backup copies until they expire (Section 15)	Data processing terms with SCCs; DPF
Cloudflare, Inc. (USA; photos stored in the EU; global network) (privacy)	Service provider: storage and delivery of photos; network proxy and security for our servers and website, including the approximate country of an IP address (Section 3.12); website hosting; access control for our administration tools (from the server update that comes with app version 1.5.0)	Photos and images; all app and website traffic, including IP addresses	Continuous	Photos until we delete them. Traffic logs per Cloudflare’s terms	Data processing terms with SCCs; DPF
Anthropic, PBC (USA; requests may be processed in other countries) (privacy)	Service provider: AI text features, translations, automated review of places (from the server update that comes with app version 1.5.0, for all app versions)	AI request text and plan details; place and notification text to translate; place photo, text and coordinates for review; a pseudonymous code	When you use AI features, when text is translated, or when a place is checked automatically (your places only if you allowed AI features)	Up to 30 days (longer only if flagged for misuse)	Data processing terms with SCCs
Google LLC — Gemini API (USA and other countries) (privacy)	Service provider (paid Gemini API, under Google’s terms for paid services and its data processing terms): AI images; AI text until the server update that comes with app version 1.5.0, and afterwards when Anthropic is not available. Google may not use these requests to train its models	AI request text and plan details; image prompts (plan name, short summary, landmark names); place text to translate	When you use AI features	For a limited time, only to detect misuse and to meet legal requirements	Google’s data processing terms; Google states DPF certification
Pollinations.ai (country not known; no privacy contact published)	Independent recipient (public service): backup for cover images, until the server update that comes with app version 1.5.0	A short image description derived from a plan, without account data	Only if the main image service failed	Not known	None
Google LLC — Google Maps Platform (USA and other countries) (privacy)	Independent recipient (independent controller): maps and place search in the Android app (and Android’s built-in address lookup); address lookup by our servers for the Android app; place search by our servers	Search text, map area, coordinates of pins and stops, device IP address, identifiers used by Google’s software	When you search or use the map	According to Google’s terms	Google’s controller terms; DPF
Apple Inc. — Apple Maps (MapKit and Apple Maps Server API) (USA) (privacy; privacy contact)	Independent recipient: maps, place search, address lookup and route lines on iOS; address lookup by our servers for the iOS app; place search by our servers	Search text, map area for place search (iOS), coordinates for address lookup, coordinates of plan stops for route lines (iOS), device IP address	When you use the map or search	According to Apple’s terms	SCCs (Apple)
OpenStreetMap Foundation — Nominatim (UK) (privacy)	Independent recipient (public service): address lookup, as a backup; the town and country of places you add	Coordinates of a pin, without account data	When the other address services fail, and when you add a place	According to the OpenStreetMap Foundation	UK adequacy decision for transfers from the EU; no contract with us
OSRM routing service operated by FOSSGIS e.V. (Germany) (privacy)	Independent recipient (public service): route lines between plan stops	Coordinates of plan stops, without account data	When a route is drawn	According to the operator	In the EU; no contract with us
Apple Inc. — Apple Push Notification service (USA) (privacy contact)	Service provider: push notifications on iOS	Push token; notification text (which can include names and message previews)	When a notification is sent	According to Apple’s terms	SCCs (Apple)
Google LLC — Firebase Cloud Messaging (USA and other countries) (privacy)	Service provider: push notifications on Android	Push token, Firebase installation identifier, notification text	When a notification is sent	Installation identifiers up to 180 days after deletion, per Google	Firebase data processing terms; DPF
Google LLC — Google Analytics for Firebase (USA and other countries) (privacy)	Provider under its own terms (Google Analytics terms): usage statistics, older Android app versions only	App events, app-instance identifier, advertising ID, device data, approximate location	Continuous while the older Android app is used	According to Google’s settings and terms	DPF
Google LLC — ML Kit (Android) (privacy)	Provider under its own terms: software in the Android app that checks photos on the device	Photos are processed only on your device. ML Kit sends Google basic device and app information and error reports	When you post a place photo	According to Google’s terms	DPF
Google LLC — Perspective API (USA) (privacy)	Service provider: backup text check, used only when our own text model is not in use. This backup is switched off in our live service. Google has announced that this service ends on 31 December 2026	Text to be checked	Only in that case	Not stored (we ask Google not to store it)	DPF
MailerSend, Inc. (USA; data centres in the EU) (privacy)	Service provider: our second e-mail provider; sends our e-mails when Oracle’s e-mail allowance is used up, Oracle’s e-mail service is not available or Oracle does not deliver to your address; tells us when an e-mail bounced or was reported as spam	E-mail address, name, e-mail content (codes; security notices with device model, IP address, approximate country and time; account notices; reminders and the welcome e-mail)	When we send you an e-mail through MailerSend	According to MailerSend’s terms. Addresses to which an e-mail could not be delivered, or from which it was reported as spam, stay on MailerSend’s suppression list until we remove them	Data processing terms; DPF (EU-U.S.)
Apple Inc. — Sign in with Apple, App Store (USA) (privacy contact)	Independent recipient: sign-in and payments, renewals and refunds	Sign-in identifiers and e-mail (or relay e-mail); purchase records with an identifier based on your account ID	When you use them	According to Apple’s terms	SCCs (Apple)
Google LLC — Google Sign-In, Google Play (USA and other countries) (privacy)	Independent recipient: sign-in and payments, renewals and refunds	Sign-in identifiers, name, e-mail; purchase records with an identifier based on your account ID (in older Android app versions, the account ID itself). Google’s sign-in software may also collect information under the Google Privacy Policy, such as a phone number, device identifiers, approximate location and usage data	When you use them	According to Google’s terms	DPF

Our own servers. The automated moderation models for text and images (Section 9) run on our own servers, which are hosted by Oracle (see the Oracle row). No other third party receives that data for moderation, except as shown in the Perspective API row and, for the automated review of places, the Anthropic row.

13. Disclosure to Authorities

We disclose personal data to authorities only where the law requires or permits it, for example:

orders of courts or public prosecutors;
requests of the Turkish Information and Communication Technologies Authority (BTK) under Law No. 5651;
requests of the Turkish Personal Data Protection Authority or another data-protection authority; and
other legally binding requests from competent authorities.

We may also disclose data if we believe in good faith that it is necessary to prevent a threat to someone’s life or safety, including reports to authorities that the EU Digital Services Act requires.

We check the legal basis and scope of each request. We disclose only the minimum necessary. We tell the affected user, unless the law or the safety of others prevents it.

14. International Transfers

Operated from Türkiye. Plan Roam is operated from Türkiye, so personal data may be accessed from Türkiye to run the Service.
Main servers in the EU. Our servers are in Germany and our database is in Belgium. Photos are stored in the EU. Until 11 October 2026, our servers were hosted by Hetzner; the server we last used there is in the United States (Section 12).
Providers in other countries. Some providers process data in the United States and other countries: Anthropic, Google, Apple, Cloudflare’s global network and MailerSend (see Section 12). Anthropic stores API data in the United States and may process requests in other countries.

Safeguards for transfers from the EU/EEA and the UK. The GDPR and the UK GDPR apply to our processing in full, although we are based in Türkiye (Article 3(2) GDPR). Where a provider in the United States states that it is certified under the EU-U.S. Data Privacy Framework (and its UK extension), we rely on that certification. These are Google, Cloudflare, MongoDB and MailerSend (for MailerSend, the EU-U.S. framework; MailerSend stores e-mail data in the EU). Otherwise we rely on the European Commission’s standard contractual clauses: for Anthropic, those in its data processing terms (with the UK Addendum); for Apple, the standard contractual clauses that Apple states it uses for its own transfers (see the Apple Privacy Policy). Türkiye does not have an EU or UK adequacy decision. We access data held by our providers in the EU only as far as needed to run the Service, over encrypted connections. You can ask us for information about the safeguards for data accessed from Türkiye, and for a copy of the safeguards described here, at support@planroam.com.

For users in Türkiye, see the Türkiye section. For other countries, see the regional sections.

If you do not want a transfer. These providers are needed to run the Service. You can avoid a particular transfer by not using the related feature (for example AI features, which you can also switch off in Settings → AI features, place search or live location), or by deleting your account. Some features will then not be available.

15. How Long We Keep Data

Data	How long we keep it
Account and profile	While your account exists. If you delete your account: hidden at once, permanently deleted after 30 days (Section 16)
Accounts whose e-mail address is never verified	Deleted 7 days after sign-up
Plans, stops, places, place and plan photos, comments, likes and place views	While your account exists, or until you delete them. When your account is permanently deleted, we delete them (Section 16). Stops you added to other people’s plans stay in those plans, without any information about who added them
Chat messages and the photos and other media you sent in chats	While your account exists, so that the people in the chat keep their conversation history (also after you leave a chat). A message you delete is hidden for everyone, but its text stays on our servers for safety and abuse investigations. When your account is permanently deleted, we delete all your messages and media
Text of your AI requests	Up to 30 days, with your credit history. After that, only the feature used and the number of credits stay
Your choice about AI features (the current choice and the last 20 choices)	While your account exists. Deleted when your account is permanently deleted. Without an account, the choice is stored only on your device until you sign in
Your choice about reminders and offers (the current choice and the last 20 choices, each with its date, platform, app version, language and text version)	While your account exists. Deleted when your account is permanently deleted
Record that you turned off e-mail reminders (a one-way code of the e-mail address, the choice, its date and how you made it)	While an account with this e-mail address exists. Deleted when that account is permanently deleted, also when an account whose e-mail address was never verified is deleted. If the secret key of these one-way codes changes, a record we can no longer match is deleted within 30 days
What our e-mail providers report about your e-mail address (bounced, blocked, reported as spam or unsubscribed; provider, reason and date)	While your account exists; it can be removed earlier (Section 11). Deleted when your account is permanently deleted. Oracle and MailerSend keep their own suppression lists (Section 12)
Credit and purchase history, subscription records and store transaction identifiers	While your account exists. Deleted when your account is permanently deleted
Store notifications about purchases	120 days (from the server update that comes with app version 1.5.0). Notifications linked to your account are deleted when your account is permanently deleted
Usage analytics (app version 1.5.0 and later)	180 days. When your account is permanently deleted, we delete the usage events linked to it. Events recorded before you signed in, which are linked only to an install identifier, are deleted within 180 days
Notifications in the app	Read notifications: 180 days. Unread notifications: until your account is permanently deleted. Notifications that other people received about you are also deleted when your account is permanently deleted
Sign-in sessions	Up to 2 years, or until you sign out or delete your account
Verification codes	Until they expire
Device records (device identifier, model, push token, IP address, approximate country) and the history of IP addresses used to sign in	While linked to your account. Deleted when your account is permanently deleted. Device records that were never linked to an account currently have no fixed deletion period
One-way codes (hashes) of the device identifier and e-mail address of a deleted account	12 months after the account is permanently deleted, then deleted (Section 16)
Purchase record of an App Store or Google Play subscription (one-way codes of the purchase and of its paid billing periods, which credits were added or will not be added, whether the yearly bonus was added, whether a period was refunded)	30 days after the end of the paid billing period it describes, and at the latest 13 months after it was last updated. If we do not know when the period ended (for example for a refund that arrives after the account was deleted), 13 months after it was last updated. It is not deleted with your account (Section 16)
Live location	Only the latest position, no history: about 2 minutes after the last update for sharing on the map, up to 10 minutes for sharing inside a plan. Map areas viewed: up to 6 hours
Which accounts we showed you as people suggestions, and on which days	30 days after we last showed you an account; for an account shown on several days without you adding it, longer, but at most 90 days (Section 7)
Note that a connection request came from a suggestion	Until the request is accepted, declined or withdrawn
Reports you file, reports about you (with a copy of the reported content), warnings, suspensions and other safety records	While your account exists, as long as needed to keep Plan Roam safe and to deal with disputes. Deleted when your account is permanently deleted
Feedback you send in the app, and e-mails you send us	As long as needed to answer you and to improve the Service, and at the latest until your account is permanently deleted
Records of administrator actions (security log, from the server update that comes with app version 1.5.0)	2 years. Entries that identify a deleted account are deleted when the account is permanently deleted
Server logs	Short rolling logs that are overwritten automatically as they fill
Backup copies of the database	The backups are encrypted. Deleted data can remain in them until they expire
Copies kept by AI providers	Anthropic: up to 30 days (longer if flagged for misuse). Google Gemini API: for a limited time, only to detect misuse and to meet legal requirements (Google’s terms do not set a fixed period)
Google Analytics for Firebase data (older Android versions)	According to Google’s settings and terms
Data on our previous hosting provider (Hetzner)	That server may still hold server logs and temporary data (cache) from before 11 October 2026, until the server is deleted (it is no longer used to run the Service)
Website	Cloudflare logs according to Cloudflare’s terms. Theme choice: in your browser until you clear it. Language cookie: up to 1 year (Section 20)

How we delete. Automatic deletion jobs run every day. When we delete electronic records, they cannot be restored in normal operation. Deleted data can remain in our database provider’s encrypted backups until they expire (see the table). We do not keep paper records.

When the law requires us to keep data. If the law requires us to keep specific data (for example because of an order of a court or an authority), or we need it for a legal claim that has already been made, we keep only that data, only for that purpose and only for as long as necessary. We then delete it.

16. Deleting Your Plan Roam Account

This section explains how to delete your account in the Plan Roam app (iOS and Android) or without the app.

In the app.

App version 1.5.0 and later: open your Profile, tap the gear icon, then Account → Delete account.
Older app versions: open your Profile, tap the gear icon (Settings), then Account Settings → Delete Account.

Without the app. Send an e-mail to support@planroam.com from the e-mail address of your Plan Roam account, with the subject “Delete my account”. You do not need to reinstall the app. If you cannot use that e-mail address, tell us your username; we will check that the account is yours.

Before you delete your account. You can ask us for a copy of your data (Section 17). If other people use plans you created, let them know: those plans are deleted for them too.

What happens.

Your profile is hidden at once and you are signed out on all devices.
Your account is permanently deleted 30 days later. If you sign in during those 30 days, the deletion is cancelled and your account is restored.
This also applies to older app versions, although their screen says that your data is deleted permanently.

What we delete after 30 days. When the 30 days end, we delete all the data we hold about you, including:

your profile and profile photo, sign-in details, devices and push tokens, sessions, and the history of sign-ins and IP addresses;
your choice about e-mail reminders and what our e-mail providers reported about your e-mail address;
your connections, blocks and plan memberships;
the plans you created, with their stops, routes and cover images, also for the other members of those plans;
the places you created, with their photos; they are also removed from the public map;
your comments and likes, the places you viewed, and the records of who viewed your places;
your chat messages and the photos and other media you sent in chats; in those chats, the other people see “Deleted account”;
notifications to you and notifications about you;
reports you filed and reports about you, and other safety records about you;
feedback you sent, and your live location;
the usage analytics linked to your account;
your credit and purchase history, including the text of AI requests, records of offers shown to you and records of automated reviews of your places;
the other data about you in our database, in our temporary storage (cache) and in our file storage.

Stops you added to other people’s plans stay in those plans, without any information about who added them.

The only things we keep. When your account is deleted, we keep two one-way codes (cryptographic hashes made with a secret key): one of your device identifier and one of your e-mail address in a standard form (for example in lower case). We cannot turn these codes back into your e-mail address or device identifier. They are not linked to your old account or to any other data about you. We use them only to prevent abuse: to stop welcome credits from being claimed again, to stop people from getting around a suspension or closure by creating a new account, and to apply the limit on accounts per device. When a device or an e-mail address is used to create an account, we compare its code with the stored codes, only for these purposes. The legal basis is our legitimate interest in preventing abuse (GDPR Article 6(1)(f); in Türkiye, KVKK Article 5(2)(f)). We delete the codes 12 months after your account is permanently deleted. You can object (Section 5).

Purchase record of a subscription. For each App Store or Google Play subscription, we also keep a purchase record, separately from your account. It is not deleted with your account. It contains only: one-way codes (cryptographic hashes made with a secret key) of the store’s identifiers of the purchase and of each paid billing period; which credits of the paid billing period were already added to an account or will not be added under our rules (on the yearly plan, which months); whether the yearly bonus was added, and the day on which the subscription year it belongs to ends; and whether the store refunded the period. It contains no account, name, e-mail address, device identifier or payment amount. We cannot turn the codes back into the store’s identifiers, and the record is not linked to your old account or to any other data about you. Deleting your account does not cancel the subscription. If the subscription is later restored on a Plan Roam account, we compute the code of the restored purchase and compare it with the stored codes, only to add the subscription’s credits correctly: credits that were already added to any account for a paid billing period are not added again. For the current paid billing period, the credits that no account received are added if the period began after we started keeping these records; if it began earlier, the monthly credits that fell due before the restore are not added. Credits of an earlier paid billing period that ended before the restore are not added. The legal basis is our legitimate interest in preventing abuse and in providing the paid subscription correctly (GDPR Article 6(1)(f); in Türkiye, KVKK Article 5(2)(f)). We delete each record 30 days after the end of the paid billing period it describes, and at the latest 13 months after it was last updated. If we do not know when the period ended, we delete the record 13 months after it was last updated. You can object (Section 5).

What can remain for a limited time.

Copies in our database provider’s encrypted backups, until the backups expire (Section 15).
Short rolling server logs, until they are overwritten.
Copies held by providers under their own retention rules: AI providers (Anthropic up to 30 days; Google according to its terms), Cloudflare’s logs and, for older Android versions, Google Analytics for Firebase (Section 15).
Your e-mail address on the suppression list of Oracle or MailerSend, if an e-mail to it bounced or was reported as spam, until we remove it (Section 12).
Server logs and temporary data (cache) from before 11 October 2026 on our previous hosting server (Hetzner), until that server is deleted.
Data the law requires us to keep, as described in Section 15.

We cannot delete copies that other people made themselves, for example screenshots.

When these rules apply. These deletion rules apply from the server update that comes with app version 1.5.0, for all app versions. Accounts whose deletion was completed before that update may have left content behind (for example public places, plans or messages); we are removing it with a one-time clean-up.

Subscriptions. Deleting your account, or deleting the app, does not cancel an App Store or Google Play subscription. Cancel it in your App Store or Google Play account settings. Unused credits are lost when your account is permanently deleted.

Sign in with Apple. If you used Sign in with Apple, you can also remove Plan Roam in your Apple account settings, under Sign in with Apple.

17. Your Rights and How to Use Them

Your rights. Depending on where you live, you can ask us to:

tell you whether we process your data, and give you access to it and a copy;
correct data that is wrong or incomplete;
delete your data;
restrict how we use your data;
give you your data in a common electronic format, or send it to another company (portability);
stop processing based on legitimate interests (objection, Section 5);
review a decision made only by automated means, with a person, and hear your point of view (Section 9); and
withdraw a consent you have given.

Things you can do yourself in the app.

Correct your profile in the app.
Delete content and your account (Section 16).
Withdraw device permissions (location, camera, notifications) in your device settings.
Stop live location by choosing Private.
Switch off usage analytics in Settings → “Share usage data” (app version 1.5.0 and later).
Allow AI features, or withdraw your permission, in Settings → AI features (app version 1.5.0 and later).
Choose notification categories, and agree to or withdraw from reminders and offers, in Settings → Notifications (app version 1.5.0 and later).
Block other users, and unblock them (app version 1.5.0 and later: Settings → Account → Blocked accounts).

Withdrawing a consent or permission does not affect what we did before.

How to make a request. Write to support@planroam.com from the e-mail address of your Plan Roam account. If you write from another address, we may ask you for information to confirm that the account is yours. Requests are free of charge. To get a copy of your data, write to us: we send it to you by e-mail in a common electronic format. You may also ask someone to make a request for you (an authorised agent); we may ask for proof that they are allowed to act for you.

How quickly we answer.

Where you live	Main rights	How quickly we answer	Where you can complain
EU/EEA	All the rights above	Within 1 month (can be extended by 2 months for complex requests; we tell you if so)	The data protection authority where you live, work or where you think the infringement happened
United Kingdom	All the rights above	Within 1 month (same extension). Complaints: we acknowledge them within 30 days	The Information Commissioner’s Office (ico.org.uk)
Türkiye	The rights in Article 11 KVKK	Within 30 days, free of charge	The Personal Data Protection Board (Kişisel Verileri Koruma Kurulu)
United States	Confirm, access, correct, delete, portable copy, opt out of significant profiling	Within 45 days (can be extended by 45 days). You can appeal	Your state Attorney General, if your appeal is denied (we tell you how)
Brazil	The rights in Article 18 LGPD, including review of automated decisions	Within 15 days for a full statement	ANPD (www.gov.br/anpd)
Korea	Access, correction, deletion, suspension, objection to and explanation of automated decisions	Within 10 days	See the Korea section
Japan	Disclosure, correction, suspension of use, deletion	Without delay, free of charge	The Personal Information Protection Commission (www.ppc.go.jp)
Canada and Québec	Access and correction; withdraw consent	Within 30 days	Office of the Privacy Commissioner of Canada; in Québec, the Commission d’accès à l’information
Taiwan, Hong Kong, Australia	See the regional sections	Within the time the local law sets	See the regional sections
Elsewhere	Your rights under local law	Within the time the local law sets	Your local authority

The regional sections give more detail for each region.

18. Security

We protect personal data with:

encryption of data in transit (HTTPS/TLS);
passwords and sign-in session tokens stored only in protected (hashed) form on our servers;
secure storage of sign-in tokens on your device (Section 10; for older Android versions, see the note below);
restricted access to our servers and database: only the people who run Plan Roam have access, using key-based sign-in, and our servers accept connections only through Cloudflare. From the server update that comes with app version 1.5.0, our administration tools are also protected by Cloudflare access control, most administrator roles see personal data such as e-mail addresses masked, and administrator actions are logged; and
servers and database in data centres in Germany and Belgium.

No system is completely secure. We cannot guarantee that data will never be accessed without permission.

Older Android versions (1.4.x) allowed Android’s backup feature to copy some app settings and sign-in data to your Google account backup and to a new phone. App version 1.5.0 and later exclude this data from backups. To remove these copies from future backups, update the app and sign out of devices you no longer use.

If a data breach affects you, we will inform you and the authorities as the law requires.

19. Age Requirement (18+)

You must be at least 18 years old to create an account or use Plan Roam. This also applies to browsing without an account. Plan Roam is not directed at children, and we do not knowingly collect personal data from anyone under 18. If we learn that a person under 18 has an account, we close the account and delete their personal data as described in Section 16. If the person is under 13, we also do not keep the one-way codes or the purchase record described in Section 16, unless the law requires us to keep them. If you think a person under 18 is using Plan Roam, please tell us at support@planroam.com.

20. Website (planroam.com), Cookies and Local Storage

Hosting. The website is hosted by Cloudflare. To deliver the site and protect it from attacks, Cloudflare processes your IP address, browser information and the pages you request.
Website analytics. We may use Cloudflare Web Analytics on our general pages (for example the home, download and contact pages). It counts page views and measures loading speed. It does not use cookies or store anything on your device. It sends the page address (without the part after ”?”), the referring page and timing data to Cloudflare. It is not used on the e-mail verification page or on the pages that show a shared plan or profile.
Error reports. Your browser may send reports about network errors (for example a page that failed to load) to Cloudflare.
Theme. If you choose a light or dark theme, your choice is stored in your browser’s local storage. It is not sent to us.
Language. If you choose a language in the website’s language menu, the site may store this choice in a cookie called astro-locale for up to one year. Otherwise, the site may choose a language from your browser settings and your approximate country, which we do not store.
E-mail verification page. When you open the link in a verification e-mail, the page sends the one-time code in the link to our servers to confirm your e-mail address.
Shared plans and profiles. If someone shares a plan or a profile with you, the link opens in the Plan Roam app if you have it, and otherwise on a page of our website (planroam.com/plan/… or planroam.com/profile/…). To build that page, the website asks our servers for a short summary. For a public plan, the page shows its name, the town and country of its places, the number of days and stops, and its cover image. For a profile, it shows the username, the name, the profile photo and the number of public plans the person created. If the plan is not public, or if the plan or profile was reported and is being reviewed, or was hidden, removed or deleted, the page shows only a general invitation, without any of its details. If you asked us to stop suggesting your account (Section 7), your profile page also shows only the general invitation. Profile pages are marked so that search engines do not list them. To keep the site fast, Cloudflare and your browser can keep these pages for a few minutes, so a change can take up to 10 minutes to appear.
Download links with campaign information. Links in our social media posts and profiles can carry campaign information (for example “instagram” and the name of a series of posts). When our download page takes you to the App Store or Google Play, it can pass this campaign information on to the store. The store buttons on the pages of shared plans and profiles can pass on a fixed note that you came from a shared link. Apple and Google show us only total numbers of visits and downloads per campaign. The campaign information does not identify you, and the website does not store it. Apple and Google process your visit under their own privacy policies (Section 12).
No advertising cookies. The website does not use advertising or cross-site tracking cookies, and does not let third parties collect information about your activity across other websites.
In the apps, device storage is described in Section 10.

21. App Store and Google Play Privacy Labels

The App Store “App Privacy” section and the Google Play “Data safety” section summarise the data the apps collect. They use the stores’ own categories, so they are shorter than this policy. This policy is the full description. If you think a store summary does not match this policy, please tell us at support@planroam.com and we will correct it.

In short, the apps collect: contact information (name, e-mail address); location (precise and approximate); user content (photos, messages, plans, places, comments, support messages and feedback); search terms; identifiers (account ID, device identifier and, in current versions, install identifier; in older Android versions also the advertising ID, through Google Analytics for Firebase); purchase history; usage data (app version 1.5.0 and later; Google Analytics for Firebase in older Android versions); and diagnostic and technical information (device model, system and app version, and basic diagnostics that Google’s map and ML Kit software in the Android app sends to Google). When you sign in with Google, Google’s sign-in software may also collect information under the Google Privacy Policy (Section 12). We do not sell data or share it for advertising. Current app versions do not track you across other companies’ apps or websites. For older Android versions, see Section 10.

22. Changes to This Policy

We may update this policy, for example when we change a feature or when the law changes. We will post the new version here with a new date. If a change is important, we will tell you in the app or by e-mail before it applies. You can ask us for a copy of an earlier version at support@planroam.com.

23. Contact Us

For any question about this policy or your personal data: support@planroam.com (please write “Privacy” in the subject line).

Regional Sections: Extra Information for Your Country

Each section below adds information for users in a particular country or region. It applies together with the rest of this policy.

Türkiye (KVKK) — notice for users in Türkiye

This section is the information notice required by Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. It is not a consent form. Where we rely on your explicit consent (for reminders and offers, Section 11), we ask for it separately in the app. The Turkish version of this policy is on planroam.com/tr/legal/privacy-policy; for users resident in Türkiye, the Turkish text governs.

A. Data controller. Plan Roam, operated by an independent developer based in Türkiye. Contact: support@planroam.com.

B. How we collect personal data. Through the Plan Roam mobile apps (iOS and Android), the website planroam.com and our servers at api.planroam.com: from the information you enter, automatically from your device, and from Apple’s and Google’s sign-in and app-store services. Collection is electronic, by fully or partly automated means.

C. Data, purposes and legal reasons.

Data category	Examples	Purpose	Legal reason (KVKK Art. 5(2))
Identity and contact	Name, username, e-mail address, Apple or Google account ID, phone number if you gave one	Creating and managing your account, signing in, verification and security e-mails, the welcome e-mail after your e-mail address is verified	(c) establishment and performance of a contract; (f) legitimate interest (account security; helping new users get started)
Profile and content	Profile photo, bio, plans, stops and notes, places and their photos, comments, likes, connections	Providing the Service; sharing content with the people you choose or publicly; automatic translation into other languages (with AI only if you allowed AI features)	(c); (f)
Messages	Chat messages, reactions, message previews in notifications	Delivering and storing messages, sending notifications, automated safety checks; we do not use the content of your messages for any other purpose	(c); (f) (community safety)
Location	Device location if you allow it; live location if you turn it on; coordinates of places; the map area you view; the location in a photo you share (read only on your device; it becomes the place’s location if you save the place). If you choose “Public”, your live position is shown to all Plan Roam users viewing the map, except people you blocked	Map, routes, nearby places and live location sharing	(c). You can turn off the location permission in your device settings and live location in the app at any time
Place views	That you opened a place created by someone else, and when	Showing the place’s creator who viewed it; preventing abuse	(f) legitimate interest
People suggestions	Your connections and their connections, shared plans, profile, e-mail address and whether it is verified (only to recognise Plan Roam’s own accounts and real accounts), language, when you last used the app, connection requests, blocks, reports and other safety records; the accounts we showed you and when (at most 90 days); the note that a connection request came from a suggestion (until the request is answered or withdrawn)	Suggesting people you may know to you, and your account to other users; suggesting real and relevant accounts	(f) legitimate interest
Device and transaction security	Device identifier, install identifier, device model, system and app version, language, time zone, push token, IP address and its approximate country, sign-in times and IP history	Session management, notifications, new-device notices and other security e-mails, preventing fake accounts and abuse, meeting legal obligations	(c); (ç) legal obligation; (f)
E-mail choices and delivery	A one-way code (hash) of your e-mail address with your choice to turn off e-mail reminders, its date and how you made it; what our e-mail providers report about your address (bounced, blocked or reported as spam)	Following your choice; delivering account and security e-mails reliably	(f) legitimate interest
Guest and first-launch data	Device identifier, model, system and app version, language, push token, IP address, recorded when the app first starts, also without an account; public content you view as a guest (app version 1.5.0 and later)	Running the app before sign-up, delivering notifications, preventing abuse	(c); (f)
Usage (analytics)	In-app events (for example screens opened, features used) and session information, linked to your account and install identifier; for the app’s first start and a completed sign-up, the approximate country	Improving the app and finding errors; counting installs and sign-ups per country	(f). You can switch this off in Settings → “Share usage data” (app version 1.5.0 and later)
App tests (app version 1.5.0 and later)	Which version of a screen your installation sees	Testing which version of a screen works better	(f). Switched off with “Share usage data”
Terms acceptance (app version 1.5.0 and later)	Version of the Terms of Use in force when you signed up, and when	Proving the contract and its terms	(c); (e)
Purchases	Product bought, transaction and order identifiers, subscription status and dates, credit balance and history	Verifying purchases, granting Pro and credits, refunds and fraud checks	(c); (e) establishing, exercising or protecting a right; (f)
AI requests	The text you write when you create a plan or stops with AI (kept for up to 30 days), your time zone and language; your choice about AI features	Sending your request to the AI provider and creating the result; credit records and abuse checks; following your choice about AI features	(c); (f)
Abuse prevention after account deletion	One-way codes (hashes) of the device identifier and of the e-mail address of a deleted account, kept for 12 months and not linked to the account or to any other data	Preventing welcome credits from being claimed again, getting around a suspension or closure, and getting around the limit on accounts per device	(f) legitimate interest
Credits of a restored subscription	Purchase record of an App Store or Google Play subscription: one-way codes (hashes) of the purchase and of its paid billing periods, which credits were added or will not be added, whether the yearly bonus was added and whether a period was refunded; kept until 30 days after the end of the paid billing period, at most 13 months, and not linked to an account or to any other data	Adding a subscription’s credits only once per paid billing period, and, for a paid billing period that began after we started keeping these records, adding the credits of that period that no account received, when the subscription is restored on another account	(f) legitimate interest
Safety and moderation records	Results of automated checks, reports you file and reports about you (including a copy of the reported content), blocks, warnings and suspensions	Community safety, acting on illegal content, handling objections	(f); (e); (ç)
Notifications	Your notification choices, push token	Notifications about messages, invitations, plan changes, connection requests, account and purchases; service announcements	(c); (f)
Reminders and offers (commercial electronic messages)	Push token, the record of your approval, language, time zone, platform and app version, sign-up date, offer status, credit balance and recent credit use, whether you have a Pro subscription, which first steps you have taken and when you last used the app	Sending the reminders and offers you approved	Your explicit consent (Article 5(1) KVKK) and your prior approval (onay) under Law No. 6563
Support and feedback	Your e-mails, in-app feedback, device and version information	Answering your requests	(c); (f)
Website visitors	IP address, browser information, pages visited (through Cloudflare), cookieless Cloudflare Web Analytics measurements, theme choice (stored only in your browser)	Providing and securing the website, overall visit statistics	(f)

Older app versions. Older Android app versions (1.4.x) use Google Analytics for Firebase, which automatically collects data such as an app-instance identifier, the device advertising ID, app events and an approximate location, and sends them to Google in the United States. We use this to count app use and find problems, relying on our legitimate interest (KVKK Art. 5(2)(f)). These versions have no in-app switch. You can reset or delete your advertising ID in your Android settings, and updating the app to version 1.5.0 or later stops this collection. Older iOS versions show Apple’s tracking prompt once; Plan Roam does not read your advertising identifier and does not track you.

Automated checks. Photos and texts you upload or send (including chat messages) are checked for inappropriate content by automated models running on our own servers. Content found inappropriate is not posted (a place is shown only to you), and repeated violations can lead to an automatic suspension of the account (Section 9). Automated tools (including AI) and human review may decide how widely your places are shown. An AI provider reviews your places only if you allowed AI features; otherwise a person reviews them. If an automated process has produced a result against you, you can object at support@planroam.com and ask for a person to review the decision.

D. To whom and why we may transfer personal data.

Other users and the public: as described in Section 7 (profile, public content, content for connections and plan members, messages, live location according to your setting, place viewers).
Our suppliers (service providers), to host, deliver and run the Service: server hosting: Oracle Cloud Infrastructure (Frankfurt, Germany); database: MongoDB Atlas (Google Cloud, Belgium); file storage, content delivery and network security: Cloudflare (files stored in the EU; traffic passes through Cloudflare’s global network); e-mail: Oracle Cloud Infrastructure (Frankfurt, Germany) and, as a second provider, MailerSend; push notifications: Apple Push Notification service and, for Android, Google Firebase Cloud Messaging; AI: Anthropic and Google Gemini API (Section 8); previous hosting until 11 October 2026: Hetzner Online GmbH (server in the United States).
Third parties acting for their own purposes: Apple and Google run app-store purchases, Sign in with Apple and Google Sign-In under their own privacy policies; an identifier for your account is added to each purchase. Google Maps features in the app are subject to the Google Privacy Policy. Map and place search, address lookup and route lines also use Apple Maps, OpenStreetMap Nominatim and the OSRM routing service. Until the server update that comes with app version 1.5.0, a short text derived from a plan could be sent to the Pollinations.ai image service when a cover image could not be created.
Authorised public bodies and persons authorised by law: to the extent our legal obligations require, courts, public prosecutors, the Information and Communication Technologies Authority (BTK), the Personal Data Protection Authority and other bodies authorised by law to request information (Section 13).

The full list of recipients is in Section 12.

E. Transfer abroad. All infrastructure that runs our Service is outside Türkiye, so your personal data is transferred abroad: Germany (servers; until 11 October 2026, a server of Hetzner in the United States), Belgium (database), the European Union and Cloudflare’s global network (file storage and content delivery), and the United States and other countries where our providers operate (e-mail, notifications, maps, AI and app stores). We transfer data for the purposes in section C and only as far as each provider needs it. Türkiye has not declared any of these countries adequate. For regular transfers, Article 9 KVKK requires the standard contracts published by the Personal Data Protection Board. We have not yet signed these standard contracts with our providers. We will sign them, notify each signed contract to the Personal Data Protection Authority within five business days, and update this notice. Our providers’ own data processing terms also apply, but they do not replace these contracts. Map, sign-in and app-store providers act under their own terms. Some address lookups and route lines use public map services that do not sign contracts; they receive only coordinates, without your account data. You can ask us which safeguard applies to each provider at support@planroam.com.

F. Security. See Section 18.

G. Retention. See Section 15 and Section 16.

H. Your rights (Article 11 KVKK). You have the right to apply to us and:

(a) learn whether your personal data is processed;
(b) request information about it if it has been processed;
(c) learn the purpose of processing and whether the data is used for that purpose;
(ç) know the third parties in Türkiye or abroad to whom it is transferred;
(d) ask for it to be corrected if it is incomplete or wrong;
(e) ask for it to be deleted or destroyed under the conditions in Article 7 KVKK;
(f) ask for the actions under (d) and (e) to be notified to the third parties to whom the data was transferred;
(g) object to a result against you that arises from analysis exclusively by automated systems; and
(ğ) claim compensation if you suffer damage because your data was processed unlawfully.

How to apply. Send your application in Turkish from the e-mail address registered in your Plan Roam account to support@planroam.com, or send it to the same address signed with a secure electronic signature or mobile signature. Your application should include your name and surname; if you are a citizen of Türkiye, your Turkish ID number; if not, your nationality and passport or ID number; your residential or business address for notifications; your e-mail address; and what you are asking for. We will answer free of charge within 30 days at the latest. If the process causes an additional cost, we may charge the fee in the tariff set by the Personal Data Protection Board. If your application is refused, you find our answer insufficient, or we do not answer in time, you may complain to the Personal Data Protection Board within 30 days of learning our answer, and in any case within 60 days of your application.

Notifications and commercial electronic messages. We send notifications about the Service (messages, plan invitations and changes, connection requests, likes and comments on your places, account and purchase information). We send reminders and offers (commercial electronic messages under Law No. 6563 on the Regulation of Electronic Commerce) only with your prior approval (onay), which you give in the app (app version 1.5.0 and later). You can withdraw it at any time, free of charge, in Settings → Notifications → “Reminders & offers”; we keep a record of your approval and of its withdrawal. In app version 1.5.0 and later you can also switch off the other categories in Settings → Notifications, and you can turn off all notifications in your device settings. Notices that are needed for the Service, such as account security and purchase notices, and service announcements cannot be switched off in the app. We do not currently send promotional e-mail or SMS. The welcome e-mail we send once after your e-mail address is verified is informational: it only explains how to start using the Service and contains no offers or advertising, so it is not a commercial electronic message; it has a link to turn off our e-mail reminders (Section 11).

European Union / EEA and United Kingdom

Controller. Plan Roam (Section 1). We are not established in the EU or the UK.

Legal bases. See the table in Section 4. Right to object: see Section 5.

Automated decisions. Account suspensions after repeated blocked content (Section 9) are made automatically. You have the right to obtain human review of such a decision, to express your point of view and to contest it. Write to support@planroam.com.

Transfers. See Section 14. You can ask for a copy of the safeguards at support@planroam.com.

Your rights. You have the rights of access, rectification, erasure, restriction of processing, data portability and objection; rights about decisions based solely on automated processing that significantly affect you (for us, automatic account suspensions, Section 9): we make them only because they are necessary for our contract with you, and you can obtain human review, express your point of view and contest the decision; and the right to withdraw consent at any time. We answer within one month; for complex requests, we may extend this by two more months and will tell you why.

Complaints. You can complain to the data protection authority of the EU/EEA country where you live, where you work or where you think the infringement happened. In the United Kingdom, please contact us first: we acknowledge complaints within 30 days and tell you the outcome. You can also complain to the Information Commissioner’s Office (ico.org.uk).

France. You can give us instructions on how your personal data should be stored, deleted and communicated after your death. Write to support@planroam.com.

United States

What we collect. In the last 12 months we collected these categories of personal information:

identifiers (name, username, e-mail address, account and device identifiers, IP address and the approximate country derived from it; in older Android app versions, the advertising ID);
commercial information (purchases and subscriptions);
internet or other electronic network activity (usage events, searches in the app, server logs);
precise geolocation (only when you use location features or turn on live location);
audio, electronic or visual information (photos);
user content (messages, plans, places, comments); and
inferences limited to safety signals (for example the results of automated content checks).

We use them for the purposes in Section 4 and disclose them to the service providers and other recipients in Section 12. Our retention periods are in Section 15.

No sale, no targeted advertising. We do not sell your personal information, and we do not use it, or share it with others, for targeted (cross-context behavioural) advertising. Older Android app versions (1.4.x) include Google Analytics for Firebase, which sends app-usage events and your device’s advertising ID to Google. Google processes them under its own terms (Section 10). Updating the app stops this. We do not use your personal information to train AI models. Our AI providers, Anthropic and Google (paid Gemini API), may not use it to train their models.

Sensitive information. We process precise geolocation only with your device permission and when you use a location feature. You can withdraw the permission at any time in your device settings, and stop live location in the app.

Your rights. Wherever you live in the United States, you can ask us to confirm whether we process your personal information, to access, correct or delete it, to give you a portable copy, and to let you opt out of profiling that produces legal or similarly significant effects. Send your request from your account e-mail address to support@planroam.com. You may use an authorised agent. We respond within 45 days, and may extend this by 45 days when necessary. We will not discriminate against you for using your rights.

Appeals. If we decline your request, you can appeal by replying to our decision with “Appeal” in the subject line. We decide within 60 days and explain the result in writing. If we deny your appeal, we tell you how to submit a complaint to your state Attorney General. For example, residents of Connecticut can contact the Connecticut Attorney General at portal.ct.gov/ag.

Do Not Track. Our apps and website do not respond to browser “Do Not Track” signals. We do not allow third parties to collect personal information about your online activities across other websites through our website.

Effective date of this notice: 16 October 2026.

Canada and Québec

Consent. For users in Canada, this paragraph replaces the statement in the introduction that using Plan Roam does not mean you consent to anything. In Canada, we rely on your consent. When you create an account and use a feature, you agree to the processing that the feature needs, as described in this policy (implied consent). We ask for express consent where the law requires it, for example through your device’s location permission, when you turn on live location sharing, when you allow AI features and before we send you reminders and offers. Usage analytics are on unless you switch them off in Settings → “Share usage data”. You can withdraw your consent at any time, subject to legal or contractual restrictions. We will tell you what this means for you: for example, some features may stop working, and without the account data we cannot provide an account.

Accountable person. The person accountable for our privacy practices is the Privacy Officer, Plan Roam, reachable at support@planroam.com.

Where your information goes. Your information is stored in Germany and Belgium, is accessed from Türkiye, where Plan Roam is operated, and is processed in the United States and the other countries where our providers operate (Section 12). There, it may be accessible to the courts, law-enforcement and national-security authorities of those countries.

Your rights. You may ask for access to and correction of your personal information. We reply within 30 days. You may withdraw your consent to optional processing (for example location permission, live location sharing, AI features or reminders and offers) at any time, and switch off usage analytics in the app. You can complain to the Office of the Privacy Commissioner of Canada or, in Québec, to the Commission d’accès à l’information.

Québec. Live location sharing is off until you turn it on. When a decision about you is based exclusively on automated processing (Section 9), you may ask us which personal information was used to make it, the reasons and the principal factors and parameters that led to it, and to correct the personal information used. You may submit your observations to a member of our staff who can review the decision. The person in charge of the protection of personal information is the Privacy Officer, Plan Roam (support@planroam.com).

Brazil

Legal bases (LGPD). We process your personal data:

to perform the contract with you: account, plans, places, chat, live location sharing when you turn it on, AI features and purchases (Article 7, V);
on the basis of our legitimate interests: security, moderation, abuse and fraud prevention, automatic translation, people suggestions, e-mail delivery and your e-mail choices, the welcome e-mail, and usage statistics, which you can switch off (Article 7, IX);
with your consent: reminders and offers (Article 7, I), which you can revoke at any time in Settings → Notifications;
to comply with legal or regulatory obligations (Article 7, II), and to exercise our rights in legal proceedings (Article 7, VI).

The device permissions (location, camera, photos, notifications) are your choice. You can refuse or withdraw them in your device settings at any time. If you do, only the related feature will not work.

Your rights (Article 18 LGPD). Confirmation that we process your data; access; correction; anonymisation, blocking or deletion of unnecessary or excessive data; portability; deletion of data processed with your consent, where we rely on consent; information about the public and private entities with which we share data; information about the possibility of refusing consent and its consequences; revocation of consent; and review of decisions taken solely on the basis of automated processing (Article 20). You may also petition the ANPD (www.gov.br/anpd).

Channel for data subjects. support@planroam.com.

Where your data goes. Plan Roam is operated from Türkiye and collects your data directly. Our main servers are in the European Union, which Brazil recognises as providing an adequate level of protection (Resolution CD/ANPD No. 32/2026). We also use providers in the United States and other countries, mainly to provide the features you use. The recipients, countries, data and purposes are listed in Section 12. You can ask us for more information about these transfers and their safeguards at support@planroam.com.

Japan

Business operator. Plan Roam (Section 1). Contact: support@planroam.com.

Purposes of use. See Section 4.

Requests. You can ask us for disclosure (including records of provision to third parties), correction, addition or deletion, suspension of use, deletion, or suspension of provision to third parties, free of charge, at support@planroam.com. Complaints and questions go to the same address.

Security measures. We have rules for handling personal data, restrict access to our servers and database to the people who run Plan Roam (with administrator actions logged and personal data masked for most administrator roles from the server update that comes with app version 1.5.0), and encrypt data in transit.

Understanding of foreign environments. Plan Roam is operated from Türkiye. Your data is stored in Germany and Belgium (EU). It is also processed by providers in the United States, the United Kingdom and other countries (Section 12). Some providers do not tell us in which country a particular request is processed (for example Anthropic and Cloudflare’s global network), so we cannot name every country. We take security measures based on our understanding of the personal-information protection systems of Türkiye, the EU, the United Kingdom and the United States.

Provision to third parties in foreign countries. The EU and the United Kingdom are recognised under the Act on the Protection of Personal Information as having equivalent systems. For service providers in the United States that process data on our behalf under data processing terms (Anthropic, Google for the Gemini API, Cloudflare, MongoDB, MailerSend, the Apple Push Notification service and Firebase Cloud Messaging), we rely on those terms as a system for taking measures equivalent to those required under the Act (Article 28(1)). On request, we provide information about these measures and how we check them.

Messages. Messages you send, including direct messages, are checked automatically on our own servers before delivery to detect abusive, sexual or other harmful content (Section 9). We do not read private messages as a matter of routine; a person may look at a message only in the cases described in Section 9.

Complaints. You can also contact the Personal Information Protection Commission (www.ppc.go.jp).

External transmission of user information. The apps send the following information to third parties:

Sent from	Information sent	Recipient	Purpose
Android app (older versions only)	App-instance identifier, advertising ID, app events, device data	Google LLC (Google Analytics for Firebase)	Usage statistics
Android app	Device and app data, push token, Firebase installation identifier	Google LLC (Firebase Cloud Messaging)	Push notifications
Android app	Map interactions, search text, map area, IP address, software identifiers	Google LLC (Maps SDK and Places SDK)	Maps and place search
Android app	Coordinates for address lookup	Google LLC (Android Geocoder)	Addresses
Android app	Basic device and app data, error reports	Google LLC (ML Kit)	On-device photo check
iOS app	Map requests, search text, map area, coordinates for address lookup and route lines, IP address	Apple Inc. (MapKit)	Maps, place search, addresses and routes
iOS and Android apps	Sign-in information; Google’s sign-in software may also send device identifiers, approximate location and usage data (Section 12)	Apple Inc. (Sign in with Apple, iOS) / Google LLC (Google Sign-In)	Sign-in
iOS app	Push token	Apple Inc. (Apple Push Notification service)	Push notifications
iOS and Android apps	Purchase information with an identifier based on your account ID (in older Android app versions, the account ID itself)	Apple Inc. (App Store) / Google LLC (Google Play)	Purchases
Website	Page address (without the part after ”?”), referring page, timing data	Cloudflare, Inc. (Web Analytics, error reports)	Website performance

Korea

This section applies to users in Korea under the Personal Information Protection Act.

Items and purposes. Required: account data (e-mail address, name, username, password or Apple/Google account ID), and device and connection data. Optional: profile photo, bio, location, photos, messages, AI requests and usage analytics. Purposes: Section 4.
Retention and destruction. Retention periods are in Section 15. Electronic files are deleted with technical methods that prevent their recovery in normal operation. We do not keep paper records.
Entrustment and overseas transfer. Plan Roam itself operates the Service from Türkiye, so your personal information is also accessed from Türkiye. The table in Section 12 lists each recipient, its country, the items transferred, when and how (over encrypted connections, when you use the related feature or continuously), its purpose, how long it keeps the data and where to find its privacy contact. You can refuse an overseas transfer by not using the related feature or by deleting your account; some features will then not be available (Section 14).
Provision to third parties. Content you share is shown to other users according to your settings (Section 7). Google (Maps Platform), Apple (Apple Maps) and Apple and Google (sign-in and app stores) receive data as independent recipients when you use those features.
Your rights. You may ask for access to, correction or deletion of your personal information, or suspension of its processing, withdraw consent, and refuse an automated decision or ask for an explanation of it, directly or through a representative, at support@planroam.com. We respond within 10 days.
Automatic collection. The apps use a device identifier and, in current versions, an install identifier. You can switch off usage analytics in Settings → “Share usage data”.
Advertising notifications. We send reminders and offers (advertising information) only with your prior consent, which you give in the app and can withdraw free of charge at any time in Settings → Notifications → “Reminders & offers”. They start with “(광고)”, name the sender and a contact address, and say how to refuse. We never deliver them between 9 pm and 8 am. When you agree, refuse or withdraw, the app shows the result and the date at once. Every two years after you agree, we tell you in the app that you agreed, when, and how to keep or withdraw your consent.
Safety measures. See Section 18.
Privacy officer. Privacy Team, Plan Roam, support@planroam.com.
Remedies. You can also contact the Personal Information Infringement Report Center (privacy.kisa.or.kr, ☎118), the Personal Information Dispute Mediation Committee (www.kopico.go.kr, ☎1833-6972), the Supreme Prosecutors’ Office (☎1301) or the Korean National Police Agency (ecrm.police.go.kr, ☎182).

Taiwan and Hong Kong

For users in Taiwan (Personal Data Protection Act).

Collector: Plan Roam (support@planroam.com).
Purposes: see Section 4. They include contract and customer management, information and database management, electronic-commerce services and statistics.
Categories: identification data (name, e-mail address, account and device identifiers), location, content, transaction records and usage data.
Period: see Section 15.
Area: Türkiye (from where Plan Roam is operated), Germany and Belgium (our servers and database), the United States and the other countries listed in Section 12.
Recipients: the providers in Section 12, and other users according to your settings.
Method: automated processing, and display in the app and through share links.
Your rights (Article 3): to inquire about and review your data, obtain copies, supplement or correct it, ask us to stop collecting, processing or using it, and ask us to delete it. Write to support@planroam.com.
If you do not provide data: without the required account data we cannot create an account. Some device and technical data is collected automatically (Section 3). Optional data (such as location or photos) affects only the related features.
Reminders and offers: we send them only if you agree, and you can withdraw free of charge at any time (Section 11).

For users in Hong Kong. The purposes, the classes of recipients and your rights to access and correct your data are described in this policy. If you do not provide the required account data, we cannot create an account. Requests: Privacy Officer, Plan Roam, support@planroam.com. We use your personal data in direct marketing (reminders and offers about Plan Roam, chosen using your account activity, credit balance and Pro status) only with your consent, which you can withdraw free of charge at any time (Section 11).

Australia

We handle personal information in line with the Australian Privacy Principles where they apply to us. You may use a username instead of your real name, but an account needs an e-mail address. Your information may be accessed from Türkiye, where Plan Roam is operated, and disclosed to recipients in Germany, Belgium, the United Kingdom, the United States and the other countries listed in Section 12. Some decisions are made automatically using your personal information, for example automated checks of the text and images you post and the automatic suspension of an account after repeated violations. Section 9 explains which information is used and how to ask a person to review a decision. You can complain to us at support@planroam.com. If you are not satisfied with our answer, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au). Nothing in our Terms of Use excludes your rights under the Australian Consumer Law.

Russian-speaking users, Russia and other CIS countries

Plan Roam is operated from Türkiye. We have no office, representative or servers in Russia or in other CIS countries. Your data is stored on servers in the European Union (Germany and Belgium) and processed by the providers listed in Section 12. Paid features are not available in Russia.

China

The Service is not directed at users in mainland China.