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Privacy Policy

Effective Date: April 2026  |  Share Your Plans SRL · BCE No. BE1034.288.729  |  UU PDP No. 27/2022 Compliant

1. Identity of the Data Controller

The entity responsible for processing your personal data in connection with the SYP application is:

Share Your Plans SRL
Incorporated under Belgian law  |  BCE No. BE1034.288.729

Share Your Plans SRL acts as the sole data controller for all personal data collected through the Platform. There is no subsidiary or local entity involved in data processing at this stage of operations.

Data Protection Contact: SYP has designated a contact responsible for handling personal data inquiries and requests. This function can be reached at privacy@syp-app.com.

2. Scope of This Policy

This Privacy Policy applies to all Users who access or use the SYP mobile application within the territory of Indonesia. It describes how we collect, use, store, share, and protect your personal data, and how you may exercise your rights under applicable Indonesian law.

This Policy is governed by the Indonesian Personal Data Protection Law (UU PDP No. 27/2022), the Electronic Information and Transactions Law (UU ITE No. 11/2008 as amended), and Government Regulation No. 71/2019 on Electronic System and Transaction Operations (GR 71).

This Policy applies primarily to users accessing the Platform from Indonesia. Users accessing the Platform from other jurisdictions may have additional rights under their local applicable law. SYP will endeavour to respect such rights to the extent reasonably practicable. A jurisdiction-specific policy will be made available as SYP expands to additional markets.

3. Personal Data We Collect

We collect only the personal data necessary to operate and deliver the Platform's features.

3.1 Account and Profile Data

When you register for a SYP account, we collect the following:

  • First name and last name (mandatory — only your first name is displayed to other users, and only after acceptance of a Match or a request to join)
  • Email address (mandatory)
  • Date of birth (mandatory — used solely to verify the minimum age requirement of 18 years)
  • City of residence (mandatory — for internal statistical analysis; displayed on the user profile after acceptance of a Match or a request to join)
  • Preferred match distance and time margin (mandatory — used exclusively by the matching algorithm; never triggers device location permissions)
  • Language(s) spoken (mandatory — used to determine your app interface language)
  • Profile photo (mandatory — displayed to other users after acceptance of a Match or a request to join)
  • Brief bio (optional — displayed on your profile after acceptance of a Match or a request to join)
  • Password (stored in hashed, non-reversible form — never accessible in plain text)

Profile information is visible to other users only after acceptance of a Match or a request to join, except for first name and Plan details which are visible in Explorer Mode to Gold subscribers.

3.2 Plan Data

When you create or publish a Plan on the Platform, we collect: title of the activity, category (one of five fixed options: Sport, Culture, Food, Travel, Social), specific address of the planned activity as entered by you via Google Maps, date and time, and an optional description.

The activity address is a fixed, user-entered property of the Plan. It is never derived from your device location, and its collection does not constitute user geolocation in any form.

3.3 Location Data — Permanent Policy

SYP does not collect, and will never collect, any GPS coordinates or real-time device location data. This is a permanent architectural and product commitment. The application does not request, access, or process device location permissions at any point.

Location information in SYP is limited exclusively to two manually entered data points: the city you provide at registration, and the specific Google Maps address you enter when creating a Plan. No location data is ever automatically derived from your device.

3.4 Usage and Technical Data

We automatically collect: device type and operating system version, app version, session timestamps and duration, log data (errors, crash reports), and IP address (used for security and fraud prevention only — not used for location tracking).

This data may be collected in part through third-party analytics and crash reporting SDKs integrated in the app. These tools collect device identifiers and usage data solely for the purpose of monitoring app stability and performance. This data is not used for advertising or cross-application tracking.

3.5 Communication Data

Once a Match or a request to join is accepted, Users may exchange messages through the Platform's in-app Chat Thread. Messages are stored to ensure service continuity and enable moderation where required. Messages are not monitored proactively — access is restricted to authorised personnel for safety, legal compliance, and moderation purposes only.

Users may also exchange messages in group chats available within confirmed Activities. Users may delete conversations from their interface. However, copies of messages may be retained for a limited period where necessary for safety, moderation, fraud prevention, or compliance with legal obligations.

3.6 Payment Data

If you subscribe to a payment plan:

  • On Android devices, payments are processed via Google Play Billing
  • On iOS devices, payments are processed via Apple StoreKit

SYP does not store full payment card numbers or sensitive financial credentials. We retain only the data necessary to manage your subscription (subscription tier, billing status, transaction reference).

3.7 Inferences and Matching Logic

The Platform operates two distinct connection mechanisms, each generating different types of data:

  • Algorithmic Matching: The Platform automatically identifies compatible Plans based on user-defined criteria (category, title, location, distance preference, date and time margin). Limited inferences about activity preferences and patterns may be generated to improve future match relevance.
  • Request to Join (Explorer Mode): Gold subscribers may browse existing Plans and send a request to join. The Plan owner independently decides to accept or decline each request. No algorithmic inference is involved in this mechanism — it is driven entirely by user initiative.

Important: In both mechanisms, SYP does not actively select, recommend, or promote specific users to one another. All connections result solely from user-defined criteria and independent user decisions.

Inferred data is used solely to improve the relevance of future algorithmically generated Match suggestions. It is not shared with third parties, not used for advertising purposes, and is permanently deleted upon account closure.

4. Legal Basis for Processing

Under UU PDP No. 27/2022, we process your personal data on the following legal bases:

  • Consent — for optional profile data (bio only). You may withdraw consent at any time by removing this information from your profile settings.
  • Performance of a Contract — for account data, Plan data, and communication data necessary to provide the service.
  • Legitimate Interest (where permitted under applicable Indonesian law) — for technical and usage data to maintain security, stability, and performance.
  • Legal Obligation — where required by Indonesian law, including UU ITE and GR 71.

Where processing is based on consent, such consent is collected explicitly at the relevant point in the registration or profile completion process, before any data is collected for that purpose. You will be clearly informed of what you are consenting to and may withdraw your consent at any time without affecting the lawfulness of prior processing.

5. Purposes of Processing

We use your personal data strictly for the following purposes: creating and managing your user account and profile; operating the Plan publication and Matching features; delivering Match notifications and enabling in-app messaging after acceptance of a Match or a request to join; generating inferences to improve Match relevance; managing subscription status and billing records; ensuring platform security and preventing fraud; responding to user support requests; complying with legal obligations; and improving Platform performance through aggregated, anonymised analytics.

SYP does not use personal data for targeted advertising or cross-application tracking. We do not sell personal data to advertisers.

For information regarding user interactions, safety, and liability, please refer to our Terms of Service.

6. Data Storage and Infrastructure

6.1 Storage Location

All personal data is stored on secure cloud infrastructure and database hosting services operated by third-party providers acting as data processors under our instruction. These providers implement appropriate technical and organisational measures to ensure the security and integrity of personal data in accordance with industry standards and do not use your data for their own purposes.

Certain real-time and messaging functionalities rely on secure third-party infrastructure under strict access control and security standards. Third-party providers include analytics and crash reporting tools, push notification services, and payment providers (the latter acting as independent data controllers).

In addition, we use the following named providers whose processing is directly relevant to the services you receive:

  • Google Play Billing — subscription management and in-app purchases (Android). Acts as an independent data controller for payment data.
  • Apple StoreKit — subscription management and in-app purchases (iOS). Acts as an independent data controller for payment data.

A full list of our infrastructure and sub-processors is available upon request at privacy@syp-app.com.

6.2 Security Measures

We implement appropriate technical and organisational measures to protect your personal data, including: encryption of data in transit (TLS 1.2 or higher), encryption of data at rest on our database infrastructure, access controls and role-based permissions, token-based authentication and session management, and rate limiting to mitigate abuse.

6.3 Data Retention

  • Account and profile data: retained for the duration of the account and deleted within 15 days of a valid deletion request
  • Plan data and Match history: retained for the duration of the account
  • In-app messages (Chat Thread and group chat): retained for the duration of the account; copies may be retained for a limited additional period for safety, moderation, or legal compliance purposes
  • Inferred data: deleted upon account closure
  • Technical logs: retained for a maximum of 90 days
  • Billing records: retained for 5 years in accordance with Indonesian accounting and tax obligations

If you have an active subscription at the time of your account deletion request, you will be reminded to cancel any active subscription before your account is deleted. You may delete your account even if a subscription remains active, but we recommend cancelling it first to avoid further charges. Deleting your account does not automatically cancel an active subscription.

6.4 Inactive Accounts

If your account has been inactive for a continuous period of 2 years (no login or activity), we reserve the right to close it automatically. You will be notified by email at least 30 days before any automatic closure.

6.5 Post-Closure Safety Retention Window

Following account closure, we retain a limited subset of your data for 3 months as a safety retention window (extended to 1 year in the event of an account ban). The purpose is to enable investigation of any unlawful conduct or violations that may come to our attention after closure.

6.6 Suspended vs. Deleted Accounts

If your account is suspended, your profile will no longer be visible to other users on the Platform. However, your data will be retained for the duration of the suspension period, as your account may be reinstated at the end of that period. Deletion of your account and associated data may be requested at any time during suspension by contacting privacy@syp-app.com.

Once your account is closed — including if you do not log back in within 2 years following the end of a suspension period — your data is deleted in accordance with the retention schedule set out above.

6.7 Data Breach Notification

In the event of a personal data breach that is likely to affect your rights or security, we will notify affected users and relevant authorities in accordance with applicable laws, including UU PDP No. 27/2022.

6.8 International Data Transfers

Personal data may be processed and stored outside the territory of Indonesia, including in jurisdictions where our infrastructure and technology providers operate. Where such transfers occur, SYP ensures appropriate safeguards, including contractual protections and adherence to recognised data protection standards, in accordance with applicable Indonesian data protection laws. By using the Platform, you acknowledge and are informed of such cross-border data transfers as necessary for the operation of the service.

7. Sharing of Personal Data

We do not sell, rent, or commercially exploit your personal data. We share personal data only in the following limited circumstances:

  • With Other Users — certain profile information is visible after acceptance of a Match or a request to join. In Explorer Mode, only first name and Plan details are visible.
  • User Reports and Moderation — data may be reviewed internally by authorised personnel to ensure platform safety.
  • Infrastructure and Database Hosting Providers — technical data for application hosting and database storage. These providers act as data processors under our instruction.
  • Analytics and Technology Providers — device and usage data for app functionality, analytics, and crash reporting.
  • Payment Providers (Google Play Billing, Apple StoreKit) — subscription status and billing processing.
  • With Authorities — where required by Indonesian law, court order, or governmental authority.
  • In Corporate Restructuring — in the event of a merger or acquisition, with equivalent privacy protections and prior user notification.

We only share the minimum data necessary for each purpose.

8. Your Rights Under UU PDP

As a data subject under UU PDP No. 27/2022, you have the right to: access your data, correct inaccuracies, request deletion, restrict processing, object to processing based on legitimate interest, withdraw consent, and request data portability.

Account deletion: You may delete your account directly from within the app at any time via the Settings menu. This will initiate the deletion of your account and associated personal data. You may also submit a deletion request by email.

To exercise any of your rights, submit a written request to privacy@syp-app.com. Account deletion requests are processed within 15 days. All other rights requests will be responded to within 14 calendar days. In complex cases, this period may be extended to 30 days, in which case we will notify you of the extension. You also have the right to lodge a complaint with the competent Indonesian supervisory authority responsible for personal data protection, namely the Kementerian Komunikasi dan Digital (Komdigi), or any successor authority designated under UU PDP No. 27/2022.

9. Protection of Minors

The SYP Platform is strictly intended for users aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has registered on the Platform, we will immediately suspend the account and delete the associated personal data.

To report a minor on the Platform, please use the in-app reporting feature available on any user profile, or contact us directly at privacy@syp-app.com.

10. Cookies and Similar Technologies

The SYP mobile application does not use traditional browser cookies. However, we may use the following technologies strictly necessary for the operation of the Platform:

  • Session tokens — to maintain your authenticated session and keep you logged in securely.
  • Local device storage (such as device-native storage mechanisms) — to remember your in-app preferences and settings. This may involve the use of device identifiers as required by the operating system.

None of these technologies are used for advertising, cross-application tracking, or any purpose beyond the operation of the Platform. Device identifiers accessed through local storage are used solely for session management and app functionality, and are not shared with third parties for commercial purposes.

If a web-based version of the Platform is made available in future, a separate cookies notice will be provided at that time.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the Platform's features. In the event of material changes, we will notify you via in-app notification or email at least 14 days before the updated Policy takes effect.

The date of the most recent version is indicated at the top of this document. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

12. Language

This Privacy Policy is drafted in English. In the event of any inconsistency between the English version and any translated version, the English version shall prevail to the extent permitted by applicable Indonesian law. SYP is committed to making a Bahasa Indonesia version available in compliance with applicable local regulatory requirements, including GR 71.

13. Contact — Data Protection

For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data, please contact:

Share Your Plans SRL
BCE No. BE1034.288.729  |  Incorporated under Belgian law
Email: privacy@syp-app.com

We aim to respond to all privacy-related inquiries within 14 calendar days of receipt. In complex cases, this period may be extended to 30 days, and we will notify you of any such extension.

© 2026 Share Your Plans SRL  ·  BCE No. BE1034.288.729
Terms of Service Privacy Policy Contact

Last Updated: April 2026  ·  UU PDP No. 27/2022 Compliant