Draft: not yet reviewed by our lawyer. Items in [square brackets] are still to be filled in.
Privacy policy
Last updated [date]
Who we are
trowd. is run by [Company name], [registered address], company number [number]. We are the data controller for the personal data described here. ICO registration number: [number]. Contact us at privacy@trowd.uk.
The short version
- Your reviews are seen only by people who already know you, and only the people you choose for each review.
- Your phone contacts are scrambled on your phone. We never see them in readable form, and we keep nothing about people who don’t use trowd.
- We store your phone numbers and emails only in scrambled (hashed) form.
- We don’t sell your data, show adverts, or let anyone pay to change what you see.
- You can download everything we hold about you, or delete your account, at any time in Account.
What we collect and why
| What | Why |
|---|---|
| Your phone number(s) and email, stored scrambled (hashed), with a masked hint like “+44 •••• ••0417” | To sign you in with one-time codes, and so friends who have you in their contacts can find you. |
| Scrambled versions of the numbers and emails in your phone contacts | To find which of your contacts use trowd. Scrambling happens on your phone. We compare the scrambled values with our members and keep only the matches; everything else is thrown away straight away. |
| Your reviews: score, words, photos, who can see each one | To show them to the people you choose. Photos have their location and camera details removed. |
| Loyalty: your till code, visits businesses log for you, points, rewards used, schemes you joined | To give you rewards. Businesses see that someone with your code visited, never your friends or who you know. |
| An optional name to show friends on our website | So friends know who you are on the website (the app uses the names in their own contacts). |
| Optional: a scrambled Facebook account id, if you link Facebook | To confirm which of your Facebook friends also use trowd. and linked Facebook. We never receive or keep your friend list. |
| Reports you make about reviews or photos | To keep trowd. safe. The person you report is never told who reported them. |
| Technical: sign-in sessions and basic server logs | To keep your account secure and the service working. Logs are kept for [30 days]. |
Voice notes are turned into text on your phone. The recording is never sent to us. Your location is used on your phone to centre the map and find places near you. We don’t store it.
What businesses see
When you review a business, the business sees your review too: your score, words and photos, with your display name if you’ve set one (otherwise “A trowd. customer”). This includes reviews you keep private from your friends: those are your private feedback to the business. Businesses can reply to reviews and ask us to look at a review they believe breaks our rules. Logging a visit at the till never tells a business whether someone is a member, and businesses must not contact you about your review outside trowd.
Featured reviews: only if you switch on “Let businesses feature my reviews”, a business may pay to quote one of your reviews in its marketing. It’s always labelled as featured with your permission, shown next to the business’s overall trowd. score, credited as you chose (your display name or “A trowd. customer”), and you receive bonus trowd. points. Private reviews are never featured.
Who helps us run trowd.
We use these services, only for the purposes shown:
- Railway, to run our servers and database, which are in the Netherlands (EU). UK data protection law treats the EU as giving the same protection as the UK.
- Google: to search for businesses when you type a name (the words you type), and to check photos for unsuitable content before anyone sees them. Google doesn’t keep the photos.
- Open Food Facts and Open Products Facts, to look up products by barcode (the barcode only).
- Resend, to email your sign-in codes (your email address and the code only).
- Stripe, only for businesses buying trowd. points.
- Facebook, only if you choose to link it.
We never sell personal data, and we don’t use it for advertising.
Our legal reasons
[To be confirmed by our lawyer.] We use your data to provide the service you signed up for (contract); with your consent for who can see your reviews, contact matching and linking Facebook; and in our legitimate interests to keep the service safe and prevent fraud.
How long we keep it
- Your account, reviews and points: until you delete them or your account.
- Contact matches: replaced every time your phone checks your contacts; removed if you stop using contacts.
- Sign-in codes: until they’re used or expire (minutes).
- Backups: up to [35 days] after deletion.
Your rights
You can:
- download everything we hold about you: Account → Download my data;
- delete your account and everything linked to it: Account → Delete my account;
- correct your details, change who sees each review, or switch off contacts or Facebook at any time;
- object to how we use your data, or ask us anything, at privacy@trowd.uk.
If you’re unhappy with how we’ve handled your data, you can complain to the Information Commissioner’s Office (ico.org.uk).
Children
trowd. is for people aged [16] and over.
Changes
If we change this policy in a way that matters, we’ll tell you in the app first. See also our terms of use.