Privacy Policy

01Who We Are

1.1. txtme.social is a European social media platform created to help people build authentic connections through real-life, offline interactions. Our goal is to provide a digital social media hub where users can connect, communicate, share memories, join communities, follow approved B2B channels, and use privacy-focused social networking features.

1.2. The txtme.social services may be operated by one or more of the following entities:

• txtme.social B.V., which operates the native iOS and Android social media application
• txtme.social apparel B.V., which may operate the website, homepage, future e-commerce shop, clothing brand, B2C products, and B2B clothing-related services
• txtme.social marketing B.V., which may operate B2B client services, marketing services, B2B channels, and related products such as NFC table stands and other non-food marketing products

Together, these are referred to in this Privacy Policy as “txtme.social”, “we”, “us”, or “our”.

1.3. Our business is registered in Amsterdam, the Netherlands.

1.4. For privacy-related questions, you can contact us at:

Email:

Address:

02Services Covered by this Privacy Policy

2.1. This Privacy Policy applies to your use of all txtme.social services, including:

• the txtme.social mobile application for iOS and Android
• user profiles
• QR-code-based connection features
• location-based or offline connection features
• the ‘Live Pulse’ feature
• newsfeed and memory features
• photos, videos, posts, comments, captions, and similar content features
• direct messaging
• communities, groups, and channels
• B2B channels
• creator and brand ambassador features
• premium features and subscriptions
• the txtme.social website or homepage
• any future e-commerce shop operated under the txtme.social brand
• any other products, services, software, features, or tools we make available

2.2. We refer to all of these together as the “Platform” or the “Services”.

03Our Privacy Commitments

3.1. txtme.social is built around privacy, safety, and user control. Based on the current design of the Platform:

• We do not sell personal data.
• We do not use targeted advertising.
• We do not use behavioural advertising.
• We do not use user data to train AI models.
• We do not use recommendation algorithms for content ranking.
• We do not use automated moderation tools to make enforcement decisions.
• We do not intend to transfer personal data internationally.
• We store personal data in Europe.
• We may use anonymised or aggregated information for B2B analytics dashboards where users follow a B2B channel.
• Payment data is handled by third-party payment providers and is not intended to be permanently stored by us.

3.2. If any of these commitments change in the future, we will update this Privacy Policy and, where required, inform users or request consent.

04Minimum Age

4.1. You must be at least 16 years old to create an account and use txtme.social.

4.2. We do not specifically target or appeal to children under 13.

4.3. If we become aware that a person below the minimum age has created an account or provided personal data, we may delete the account and related personal data, unless we are legally required or permitted to keep limited information.

4.4. If you are under 18, you should make sure that your parent or legal guardian is aware that you are using txtme.social, as authorisation for paid features, subscriptions, or purchases, additional confirmation or consent may be required where required by law, app store rules or payment provider rules.

05Personal Data We Collect

5.1. We collect different types of personal data depending on how you use the Platform.

5.2. When you create an account, we may collect:

• full name
• email address
• username
• phone number
• verification information
• login details
• Apple or Google login information, if you choose to use social login

We use this information to create your account, verify your identity, provide access to the Platform, keep your account secure and communicate with you.

5.3. When you use txtme.social, you may choose to upload, create, send, post, display, or share content that may contain personal data, including:

• profile photos
• photos and videos
• posts
• captions
• comments
• replies
• direct messages
• stories
• memories
• community content
• B2B channel interactions
• other information you choose to provide

You remain responsible for the personal data you choose to include in your content that is voluntarily disclosed by you. You should not share personal data about other people unless you have permission or another valid legal basis to do so.

5.4. If you use direct messaging, we process information needed to send, receive, display, store, secure and manage your messages. This may include:

• sender and recipient information
• timestamps
• delivery information
• reports or safety-related information connected to direct messages

5.5. txtme.social is designed to support real-life connections. Depending on the features available, users may connect through:

• scanning another user’s QR code from their profile
• location-based connection features where users are in the same real-life location
• phone-number-based discovery for premium users
• other connection tools we may introduce

We may process information needed to enable these features, such as QR-code activity, connection status, limited location-related information, phone-number matching information, or discoverability settings. Our location-based features are designed to support real-life matching without collecting or displaying precise location data. Instead, txtme.social may use temporary token-based verification for location-based matching. This may include a temporary platform-generated token embedded in or connected to a QR code.

The token is designed to calculate distance or proximity between users, rather than to identify, display, or store a user’s specific location. We aim to process location-related data in a limited, privacy-protective, and proportionate way.

5.6. When you use the Platform, we may collect limited technical information, including:

• device type
• operating system
• app version
• browser type
• session data
• log data
• crash reports
• error reports
• security-related information

We use this information to make the Platform work properly, adjust the Platform to your device, improve reliability, prevent misuse, and protect the security of the Platform.

5.7. If you use the txtme.social website, homepage, or future e-commerce shop, or if you purchase physical products, we may additionally collect:

• shipping address
• billing details
• order details
• delivery information
• payment-related information
• customer support communications

We use this information to process orders, arrange delivery, provide customer support, handle returns or refunds, prevent fraud, and comply with tax, accounting, consumer protection, or other legal obligations.

5.8. Payments for premium features, in-app purchases, subscriptions, webshop purchases, or other paid services may be processed by third-party providers, including app stores, payment processors, or other payment partners. We do not permanently store your full payment details. We may store limited transaction information, such as:

• product or subscription purchased
• amount paid
• payment status
• transaction date
• order number
• invoice or receipt information
• refund or cancellation status

5.9. If you choose to follow a B2B channel, you may see posts, stories, brand content, community updates, or other approved content from that channel. When you follow a B2B channel, your interaction with that channel may be included in anonymised or aggregated analytics shown to the relevant B2B client. These analytics may include, for example:

• age ranges
• country-level information
• general engagement statistics
• follower numbers
• channel interaction statistics

We do not provide B2B clients with your directly identifiable personal data for any purposes. If any analytics information could reasonably identify you, we will treat it as personal data and protect it under this Privacy Policy.

5.10. If you submit a report, appeal, reinstatement request, safety complaint, or other moderation-related communication, we may process:

• the contents of your report
• the reported content, account, message, profile, channel, or activity
• your username or account information
• the reported user’s account information
• any supporting information you provide
• internal review notes
• enforcement actions taken
• appeal or reinstatement outcomes

We use this information to review reports, enforce our Terms of Service and Community Guidelines and Content Policy, protect users, prevent misuse, and comply with legal obligations.

5.11. If you contact us for customer support purposes, we may process:

• your name
• email address
• username
• account details
• message content
• attachments or screenshots you provide
• support history

We use this information to respond to your request, provide support, investigate issues, and improve our Services.

06Personal Data We Do Not Collect

6.1. We do not buy or collect personal data from data brokers or other third parties.

6.2. We do not collect personal data about users from public databases, marketing partners, data providers or other social media platforms for tracking, advertising or profiling purposes.

6.3. Apart from the personal data provided directly by you or generated by you when you use the Platform, in limited cases, we may also receive personal data about you from Apple or Google login services, payment providers, app stores, delivery providers, other users who interact with or report content on the Platform, B2B applicants or partners and competent authorities where legally permitted or required.

07Why We Use Personal Data

We use personal data for the following purposes:

7.1. To Provide the Platform: This includes creating accounts, enabling login, displaying profiles, allowing users to connect, supporting QR-code connections, providing direct messaging, showing posts, maintaining memories, operating communities, and enabling B2B channels.

7.2. To Improve Reliability and Security: This includes debugging, crash analysis, technical maintenance, security audits, abuse prevention, and service improvement.

7.3. To Verify and Secure Accounts: This includes account verification, phone or email confirmation, login protection, optional two-factor authentication, fraud prevention, and protection against unauthorised access.

7.4. To Enable User Connections and Discoverability: This includes QR-code connections, location-based or offline connection features, phone-number-based discovery for premium users, and related connection tools.

7.5. To Provide Direct Messaging: This includes sending, receiving, storing, displaying, and securing direct messages.

7.6. To Operate the Website, Webshop, and Physical Product Sales: This includes processing purchases, arranging delivery, handling returns, providing customer support, managing refunds, and keeping legally required transaction records.

7.7. To Process Payments and Subscriptions: This includes facilitating in-app purchases, premium features, subscription payments, payment confirmations, cancellations, refunds, and customer support.

7.8. To Provide B2B Channel Analytics: This includes showing B2B clients anonymised or aggregated insights about users who follow their channels.

7.9. To Maintain Safety and Enforce Platform Rules: This includes reviewing reports, removing prohibited content, issuing warnings, restricting features, suspending or banning accounts, protecting users, and preventing illegal or harmful conduct.

7.10. To Comply with Applicable Laws: This includes responding to valid legal requests, cooperating with competent authorities, preserving records where required, meeting tax and accounting obligations, and complying with applicable laws.

08Special Category Data

8.1. We do not intentionally ask you to provide special category data, such as information about your health, religion, political opinions, sexual orientation, biometric data, or similar sensitive information.

8.2. However, because txtme.social allows users to upload photos, posts, profile information, messages, and other content, your content may reveal sensitive information about you or others.

8.3. Where special category data is included in user-generated content, we process it only where necessary to provide the Platform, enforce our rules, protect users, comply with legal obligations or where another valid legal basis applies or where it is based on your explicit consent.

09Cookies, Tracking, and Session Data

9.1. The txtme.social mobile application does not use cookies. However, our website or webshop may use similar limited technical tools that are necessary to operate the website, maintain sessions, secure the service, process purchases or remember your choices.

9.2. If we introduce non-essential cookies or similar tools in the future, we will provide appropriate notice and ask for consent where required.

10Advertising, Marketing, and B2B Content

10.1. txtme.social does not display third-party targeted advertising.

10.2. We do not use behavioural monitoring or direct marketing based on hidden tracking.

10.3. If you choose to follow a B2B channel, you may see posts, stories, brand content or community updates from that B2B channel in your feed or other relevant areas of the Platform. This content is shown because you actively follow the B2B channel, not because we track you across services.

10.4. We may send you service-related communications, such as account verification messages, security notices, order updates, subscription updates, policy updates, or important Platform notices.

10.5. We will only send optional marketing communications if you have explicitly consented to it or where we have a valid legal basis to do so. You can opt out of optional marketing communications at any time.

11AI, Algorithms, and Automated Decision-Making

11.1. txtme.social does not currently use content recommendation algorithms for content ranking.

11.2. txtme.social does not currently use targeted advertising tools, behavioural monitoring, AI-generated content services, or user data to train AI models.

11.3. txtme.social does not currently use automated decision-making or moderation tools that produces legal effects, moderation or enforcement decisions concerning you or significantly affecting you.

11.4. If we introduce AI systems, recommendation systems, automated moderation tools, or automated decision-making in the future, we will update this Privacy Policy and provide additional information where required.

12Who We Share Personal Data With

12.1. We do not sell your personal data.

12.2. We may share limited personal data with trusted service providers who help us operate the Platform. These may include:

• cloud hosting providers
• payment processors
• app store providers
• Apple or Google login providers
• delivery and shipping providers
• customer support providers
• security providers
• analytics or technical service providers used for non-tracking operational purposes
• auditors
• professional advisers
• legal, regulatory, or law enforcement authorities where legally permitted or required

12.3. These service providers may only process personal data for the purposes we allow and must protect it appropriately.

12.4. We do not share directly identifiable personal data with B2B clients for targeted advertising, behavioural monitoring, or individual user profiling.

13B2B Channels, Creators, and Brand Ambassadors

13.1. txtme.social may allow approved B2B channels, creators, brand ambassadors, and business users to use certain Platform features.

13.2. B2B users may need to apply and be approved before appearing on the Platform. We may carry out due diligence before approving B2B users.

13.3. B2B channels may receive anonymised or aggregated analytics relating to users who follow their channel.

13.4. B2B channels, creators, and brand ambassadors must not collect, copy, scrape, misuse, or identify users from Platform data or analytics.

13.5. If you intentionally tag, submit content to, or interact with an approved B2B channel, that B2B channel may be able to view or use that content depending on the feature, your permissions, and the applicable Terms of Service.

13.6. Any wider use of your content or personal data by a B2B channel must be based on your permission, a valid legal basis, and any applicable B2B or platform terms.

14Reporting, Safety and Law Enforcement

14.1. Users can report content or conduct through the in-app “Report” function.

14.2. Where we receive a report, we may review the reported content, account, message, profile, channel, or activity to determine whether it violates our Terms of Service, Community Guidelines and Content Policy, this Privacy Policy, or applicable law.

14.3. We may share information with police, courts, regulators, or other competent authorities only where we have a valid legal basis to do so. This may include situations where:

• we are legally required to respond to a valid request
• disclosure is necessary to protect users or others from serious harm
• disclosure is necessary to investigate or prevent illegal conduct
• disclosure is necessary to enforce our rights or comply with legal obligations

14.4. txtme.social exercises discretion in determining what data or information should be shared with law enforcement or other competent authorities. This may include, but not limited to, account information, phone number, email address, content or messages that are referred to in a complaint (subject to encryption limitations), transaction data, log data or location/proximity data.

14.5. Where legally allowed, we may notify affected users about requests for their data or actions taken on their accounts, unless doing so would interfere with an investigation, violate the law, or create a risk of harm.

15Where Personal Data Is Stored

15.1. We aim to store your personal data in Europe.

15.2. We do not transfer personal data internationally.

15.3. If we transfer personal data outside the European Economic Area in the future, we will only do so where appropriate legal safeguards are in place, such as an adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism under data protection law.

16Security

16.1. We use technical and organisational measures to protect personal data.

16.2. These measures may include:

• Signal Protocol (end-to-end encryption) for messaging features
• SSL/TLS encryption
• secure authentication
• optional two-factor authentication
• access controls
• confidentiality measures
• regular third-party security audits
• monitoring for misuse or suspicious activity
• separation of app and webshop address data, where appropriate
• security review of service providers, where appropriate

16.3. You are responsible for keeping your login details, verification codes, QR code and account credentials secure.

16.4. If you believe your account and/or your personal data has been accessed without permission, you should contact us immediately.

17How Long Do We Keep Personal Data

17.1. We keep personal data only for as long as necessary for the purposes described under Section 7 of this Privacy Policy.

17.2. In general:

• account data is kept while your account is active
• content not saved under “memories” may be deleted after 45 days
• content saved under “memories” may be kept while your account remains active, unless you delete it earlier
• webshop order records may be kept as long as required for tax, accounting, consumer protection or legal obligations
• payment transaction records may be kept where needed for accounting, dispute resolution, fraud prevention or legal compliance
• reports, moderation records, and enforcement records may be kept where needed to protect users, enforce our rules, investigate misconduct or comply with law
• security logs may be kept for a limited period to protect the Platform

17.3. When a user account is deleted or suspended, we will delete your personal data from our active systems, unless we are legally required or permitted to keep limited information for legal, accounting, tax, safety, security, dispute resolution, fraud prevention or enforcement purposes.

17.4. When a user account is deleted or suspended, txtme.social reserves the right to retain certain categories of personal data that are not strictly required by law, such as security and fraud prevention logs, moderation and enforcement records, safety complaints, pseudonymised analytics or records needed to prevent repeat abuse. These categories of data may be stored in anonymised or aggregated manner.

18Your Privacy Rights

18.1. Depending on where you live and the laws that apply, you may have the right to:

• Right of access: you may ask us to confirm whether we process your personal data and request a copy of the personal data we hold about you.
• Right to information: you may ask us for information about how we process your personal data, including the categories of data processed, purposes of processing, legal bases, retention periods, sources of data and recipients of data.
• Right to rectification: you may ask us to correct inaccurate, outdated, or incomplete personal data.
• Right to erasure: you may ask us to delete your personal data where there is no longer a valid reason for us to keep it.
• Right to restriction of processing: you may ask us to temporarily limit how we use your personal data in certain circumstances, for example, while we verify whether the data is accurate or whether we have a valid reason to continue processing it.
• Right to data portability: where legally applicable, you may ask us to provide certain personal data in a structured, commonly used, and machine-readable format, or to transmit it to another service provider where technically feasible.
• Right to object: you may object to certain processing based on legitimate interests, including processing for direct marketing, where applicable.
• Right to withdraw consent: where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal of consent does not affect processing that took place before consent was withdrawn.
• Right not to be subject to certain automated decisions: where applicable, you may have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or significantly affects you.
• Right to complain: you may lodge a complaint with a competent data protection authority.

18.2. These rights may be subject to legal conditions, exceptions, and limitations.

18.3. You can exercise your rights by contacting our Privacy Team at []

18.4. Your request should clearly explain which right you want to exercise and provide enough information for us to identify your account and understand your request.

18.5. We will review your request fairly and respond within the timeframe required by applicable data protection law. Where the GDPR applies, we will usually respond within one month of receiving your request. If your request is complex or if we receive multiple requests from you, we may extend this period where permitted by law. If we need more time, we will inform you.

18.6. If we accept your request, we will take reasonable steps to give effect to it. This may include providing access to your data, correcting inaccurate information, deleting data, restricting processing, exporting data, stopping certain processing, or updating our systems.

18.7. In some cases, we may not be able to fully comply with your request. This may happen where we need to retain or process certain information for legal compliance, tax and accounting obligations, fraud prevention, safety, security, dispute resolution, enforcement of our Terms of Service or Community Guidelines and Content Policy, protection of other users, or the establishment, exercise or defence of legal claims.

18.8. Exercising your privacy rights may affect your ability to use certain features or services of the Platform. For example, if you ask us to delete account data that is necessary to operate your account, you may no longer be able to use the Platform or certain features.

18.9. If your request relates to personal data processed by a third-party provider, such as an app store, payment provider, delivery provider, Apple, Google, or another external service, we may direct you to that provider where they are responsible for handling the request. Where we are responsible for the data, we will handle the request ourselves.

18.10. If you believe that we have not handled your request properly, you may contact us again so that we can review the issue. You also have the right to lodge a complaint with a competent data protection authority, including the Dutch Data Protection Authority, where applicable.

19Contacting the Data Protection Authority

19.1. If you are located in the Netherlands or your complaint relates to our Dutch establishment, you may contact the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens

Website: https://www.autoriteitpersoonsgegevens.nl/en

19.2. You may also have the right to complain to the data protection authority in the EU or EEA country where you live, work, or believe your rights have been infringed.

20Changes to this Privacy Policy

20.1. We may update this Privacy Policy from time to time to reflect changes in the Platform, our services, our data practices, legal requirements, safety practices, or business operations.

20.2. We will alert you about changes by updating the “Updated” date of this Privacy Policy.

20.3. Where appropriate or legally required, we may also notify you through the Platform, by email, or by another appropriate method.

20.4. Continued use of the Platform after changes become effective means that you acknowledge the updated Privacy Policy.

21Contact Us

If you have questions about this Privacy Policy or how we process personal data, you can contact us at:

txtme.social

Email: [Legal POC details]

Address: [insert registered business address]