Privacy Policy

This Privacy Policy explains how [COMPANY LEGAL NAME], a company registered in Hungary under company registration number [COMPANY REG. NO.], with its registered office at [REGISTERED ADDRESS], Hungary (“Lobby”, “we”, “us”, “our”), collects, uses, shares, and protects your personal data when you use the Lobby mobile application (the “App”).

Lobby is a social discovery app that helps adults meet new people in real life through small group events. We take privacy seriously and we have designed the App to comply with the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and Hungarian Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information.

This Privacy Policy and our Terms and Conditions of Use are the only documents that govern your use of Lobby. By creating an Account, you confirm that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the App.

In a Nutshell

Here is a short summary of the most important points. The rest of this Policy gives you the detail.

• Lobby is operated by a Hungarian company. We act as the data controller for your personal data.
• We store account, profile, event, chat, and notification data on Firebase (Google Cloud) in a European region.
• Profile photos and selfies used for face verification are processed by Amazon Web Services (AWS) in the EU (Frankfurt, eu-central-1).
• Face verification is biometric processing. We only do it with your explicit consent, and you can withdraw that consent at any time.
• We do not sell your personal data. We do not run targeted advertising. We use Firebase Crashlytics to receive anonymous crash reports so we can fix bugs, but we do not use any third-party behavioural analytics or tracking SDKs.
• If you join the website waitlist, we collect your email address so we can send launch updates and the early-member Premium offer.
• You can access, correct, export, delete, restrict, or object to the processing of your personal data at any time, and you can complain to your data protection authority.
• Event chat messages are automatically deleted approximately 35 days after the Event’s scheduled date — chat is for coordination, not a long-term archive.
• You can delete your Account at any time from inside the App. We will remove your personal data within a reasonable period, subject to legal retention obligations.

1. Who We Are and How to Contact Us

The data controller for personal data processed through Lobby is [COMPANY LEGAL NAME], with its registered office at [REGISTERED ADDRESS], Hungary, company registration number [COMPANY REG. NO.].

• General/legal contact: legal@lobbyapp.eu
• Privacy and data protection contact: privacy@lobbyapp.eu
• Postal address: [REGISTERED ADDRESS], Hungary

We are not currently required to appoint a Data Protection Officer (DPO) under Article 37 GDPR. If that changes, we will publish the DPO's contact details in this Policy.

2. Personal Data We Collect

Below is the full list of personal data Lobby collects, organised by feature. We only collect what we need to operate the App, keep our users safe, and meet our legal obligations.

2.1 Account and authentication data

What we collect

• Your unique user ID (UID) assigned by Firebase Authentication.
• The sign-in method you used (for example, Apple ID for Sign in with Apple).
• An email address where one is provided by the sign-in method.
• Timestamps relating to your account (creation, last sign-in, last activity).

Where it lives

Stored in Firebase Authentication and in the private users/{uid} document in Firestore, in a European region.

2.2 Profile information

What we collect

• First name (or chosen display name).
• Age and date of birth.
• Gender, where you choose to disclose it.
• Your selected city and approximate location.
• Spoken languages and preferred language for the App.
• Short biography and answers to prompts.
• Interests / subcategory tags.
• Education and workplace, where you choose to disclose them.
• Drinking and smoking habits, where you choose to disclose them.
• Favourite places, where you choose to disclose them.
• Public photo keys pointing to your approved profile photos hosted on AWS S3.
• Status flags such as 'face verified' and aggregated counts such as the number of endorsements received.

Where it lives

Stored in the public profiles_public/{uid} document in Firestore (visible to other Users of the App) and, where private, in the private users/{uid} document. Both are in a European region.

2.3 Photo information

What we collect

• The images you upload as profile photos.
• Metadata associated with the upload (file type, size, upload timestamp).
• Automated moderation status (uploading, pending review, approved, rejected) and the moderation reason, if any.

Where it lives

Pending photos are uploaded directly from your device to AWS S3 in eu-central-1 (Frankfurt) via a signed URL. Approved photos are moved to a public S3 location and the storage keys are written to Firestore. Rejected photos may be retained for a limited period for abuse prevention.

2.4 Face verification data (biometric)

What we collect

• A live selfie you capture inside the App for the purpose of face verification. Face verification is performed both when you complete onboarding and each time you replace your main profile photo.
• The similarity score returned by AWS Rekognition (or a comparable face-comparison service) when comparing the selfie to your approved profile photo.
• Verification status (verified, rejected, needs retry) and the technical reason code.
• Verification attempt timestamps used to enforce rate limits (currently 5 attempts per hour and 10 per day per User).

Where it lives

Selfies are transmitted to an AWS endpoint in eu-central-1 (Frankfurt) and compared against your approved profile photo by AWS Rekognition. Selfie bytes are processed in memory only and are not persisted to any AWS storage. Only the similarity score and verification status are retained, in Firestore (in a European region).

Face verification involves the processing of biometric data, which is a special category of personal data under Article 9 GDPR. We process this data exclusively on the basis of your explicit consent (Article 9(2)(a) GDPR), which you provide when you start the verification flow. You can withdraw your consent at any time by removing your verification from your profile settings or by deleting your Account. Withdrawing consent does not affect processing already carried out on the basis of the prior consent.

2.5 Event (Room) information

What we collect

• Event title, description, date and time, vibe/category, free-text location, place name, and capacity.
• The selected city and a derived geohash used for efficient nearby-event discovery.
• Hero image associated with the event.
• The UID of the event creator, the UIDs of participants, invited users, kicked users, and users with pending join requests.
• Mappings of invited users to inviters.
• Lifecycle fields such as creation and update timestamps, cancellation status, and participant counts.

Where it lives

Stored in the events collection in Firestore in a European region.

2.6 Chat and messaging data

What we collect

• Messages you send within an Event chat room (text messages).
• Image messages you choose to share.
• Location messages you choose to share.
• Date proposal messages.
• Automatic system messages generated by the App (for example, when someone joins or is removed).
• Sender ID, timestamp, message type, and metadata.
• Per-chat-room aggregates such as last message, last message timestamp, message count, and per-user unread counts.

Where it lives

Stored in Firestore in a European region. Chat content is visible only to participants of the Event. Each message is stamped at creation with an expiry timestamp; Google Cloud Firestore’s built-in TTL service automatically and permanently deletes each message approximately 35 days after the associated Event’s scheduled date (see Section 7 for the precise rule). Per-message data is transmitted over TLS and encrypted at rest by Google Cloud using AES-256 (Google manages the keys). Messages are not end-to-end encrypted, which means that while they exist they are technically readable on our servers; this lets us investigate reports and comply with legal obligations.

2.7 Friend connections

What we collect

• The list of users you have added as friends.
• Incoming and outgoing friend requests.
• Acceptance, decline, cancellation, and removal events.

Where it lives

Stored in your private users/{uid} document in Firestore in a European region.

2.8 Endorsements

What we collect

• A record that you endorsed another user after an Event you both attended.
• The event ID, the rater UID, the endorsed user UID, and the timestamp.
• An aggregated endorsement count shown on your public profile, computed server-side.

Where it lives

Stored in the endorsements collection in Firestore in a European region. We never display a negative or low score: the absence of an endorsement carries no meaning and is not visible.

2.9 Reports and safety data

What we collect

• When you submit a report against another user or an Event: your UID as the reporter, the UID or ID of the reported item, the report type and category, your optional written description, and timestamps.
• Internal moderation notes, decisions, and any restrictions applied to an account or Event as a result.

Where it lives

Stored in the reports collection in Firestore in a European region. Access is restricted to authorised moderation personnel.

2.10 Device and technical information

What we collect

• Firebase Cloud Messaging (FCM) push notification tokens for each device you use.
• Your preferred notification locale (currently 'en' or 'hu').
• Whether you granted the OS-level location permission to the App.
• Your chosen search radius (in kilometres, clamped between 1 and 500).
• Server-side timestamps of significant account events (last update, last activity).
• Operating-system level information that is necessarily exposed by the Firebase SDK (such as platform and SDK version) for the purpose of delivering notifications and securing the service.

Where it lives

FCM tokens, locale, location permission flag, and search radius are stored in the private users/{uid} document in Firestore in a European region.

2.11 Location information

What we collect

• Your selected city (which you choose during onboarding).
• A geohash computed from your selected city, used to find events near you efficiently.
• When you grant device location permission, an approximate device location is used in-memory by the App to compute distance to events. We do not store your precise device coordinates on our servers.

Where it lives

City and geohash are stored in Firestore (in a European region). Device-level coordinates remain on your device.

2.12 Push notifications

What we collect

• FCM tokens (one per device) used to send you push notifications about chat messages, friend requests, join requests, event updates, and safety notices.
• Your preferred locale for those notifications.

Where it lives

Stored as part of your private users/{uid} document in Firestore. Notifications are delivered via Firebase Cloud Messaging.

2.13 Customer support correspondence

What we collect

• When you contact us at legal@lobbyapp.eu or privacy@lobbyapp.eu: your email address, your message, any information you choose to include (for example, screenshots), and our response.

Where it lives

Stored in our internal support inbox for as long as needed to handle your request and to keep a record of the interaction (see Section 7 on retention).

2.14 Information about future paid features (placeholder)

What we collect

• At the date of this Policy, Lobby is free to use and we do not process payment information.
• If we introduce paid features in the future, purchases will be handled through the Apple App Store or Google Play, and we will receive only the limited transaction information made available to us by those stores (for example, a purchase token, a subscription status, and the product ID — but not your full payment card details).

Where it lives

Until paid features are launched, we hold no purchase or payment data. If that changes, we will update this Policy.

2.15 Information we do not collect

What we collect

• We do not currently integrate Firebase Analytics or any third-party behavioural analytics SDK (such as Amplitude, Mixpanel, AppsFlyer, Sentry, or PostHog). We do use Firebase Crashlytics for crash diagnostics — see Section 2.16.
• We do not use advertising identifiers (IDFA, GAID) and we do not show advertising inside the App.
• We do not knowingly collect personal data from children under 18 (see Section 11).

Where it lives

If we ever start using behavioural analytics or advertising-related processing, we will update this Policy before that processing begins, and where required, ask for your consent.

2.16 Crash and diagnostic data

What we collect

• Crash reports automatically generated when the App hits an unhandled error. Each report contains the stack trace, exception type, iOS or Android version, device model, App version, memory state at the time of the crash, and recent debug logs / breadcrumbs.
• A pseudonymous device-level Firebase Installations ID that lets Crashlytics deduplicate reports from the same device. This ID is not your Account ID and is not linked to your name, email, or any other identifying information held by us.
• We do NOT send your Account ID, name, email, messages, location, photos, or other personal data with crash reports.
• Crash reporting is disabled in development builds; it only operates on App Store and Google Play release builds.

Where it lives

Stored by Google in the Firebase Crashlytics service, in the same European Firebase region as our other data. Crashes are retained for the standard Firebase Crashlytics retention period (currently up to 90 days for unresolved crashes), after which they are deleted by Google. We use crash data exclusively to diagnose and fix bugs.

2.17 Website waitlist

What we collect

• If you join the waitlist on our website: your email address.
• The timestamp of your signup and the page section where the signup was submitted, so we can keep an audit trail of the consent you gave.

Where it lives

Stored in a server-side waitlist file on our Tárhely.eu cPanel hosting account, outside the public website document root. We use it only to send launch updates and the early-member Premium offer, unless you separately become an App user and provide data through the App.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

3.1 Operating Lobby

• Creating and authenticating your Account.
• Displaying your profile to other Users.
• Letting you create, edit, find, join, and leave Events.
• Powering Event discovery (including geohash-based proximity search and ranking).
• Powering chat between Event participants.
• Letting you send and accept friend requests.
• Letting you endorse other Users you have actually met.
• Delivering relevant push notifications.

3.2 Safety, trust, and moderation

• Screening profile photos through automated moderation before they are made public.
• Comparing your selfie with your profile photo, with your explicit consent, in order to verify that you are the person shown in your profile photo.
• Reviewing reports submitted by other Users and taking action against accounts, Events, or content that breach our Terms or the law.
• Preventing fraud, spam, harassment, impersonation, scraping, and other abuse.
• Rate-limiting features (such as face verification) to prevent abuse.

3.3 Communicating with you

• Sending service-related notifications (for example, an event reminder, a friend request, or a chat message).
• Sending launch updates and the early-member Premium offer if you join the website waitlist.
• Responding to your enquiries when you contact our privacy or legal addresses.
• Notifying you about material changes to these documents or the App.

3.4 Improving the App

• Diagnosing problems and improving reliability, including by receiving anonymous crash reports through Firebase Crashlytics (see Section 2.16).
• Improving recommendation and ranking quality. We do not currently feed personal data into any third-party analytics service; if we begin to do so, we will update this Policy first.

3.5 Legal and compliance

• Meeting our legal obligations under EU and Hungarian law.
• Establishing, exercising, and defending legal claims.
• Responding to valid requests from public authorities.

4. Lawful Bases for Processing

Under the GDPR we may only process your personal data where we have a lawful basis to do so. The table below lists the lawful basis we rely on for each main category of processing.

Where we rely on legitimate interests, we have carried out a balancing test to ensure that our interests are not overridden by your rights and freedoms. You can ask us for more information about that balancing test by contacting privacy@lobbyapp.eu.

5. Who We Share Your Personal Data With

We share personal data only where it is necessary to operate the App, to comply with our legal obligations, or to protect the safety of our Users. We do not sell your personal data.

5.1 Other Users

Information you put on your public profile (your first name, age, photos, city, prompts, interests, education, workplace, languages, drinking and smoking habits, favourite places, verified badge, endorsement count) is visible to other Users of Lobby. Information you provide in Events you host or join (event details, your participation, chat messages) is visible to other participants of those Events.

5.2 Our processors and service providers

We rely on a small number of trusted vendors who process personal data on our behalf and only on our instructions:

We have written data processing agreements in place with these vendors, in accordance with Article 28 GDPR.

5.3 Authorities and legal recipients

We may share personal data with courts, law-enforcement bodies, regulatory authorities, or other public bodies where we are legally required to do so, where we have a court order, or where we believe in good faith that disclosure is necessary to prevent imminent harm to a person.

5.4 Buyers, successors, and professional advisers

If we are involved in a merger, acquisition, restructuring, sale of assets, or insolvency, your personal data may be transferred to the buyer or successor in interest, subject to the same protections that apply under this Policy. We may also share personal data with our professional advisers (lawyers, auditors, insurers), in each case bound by confidentiality.

5.5 What we do NOT do

• We do not sell your personal data.
• We do not share personal data with third parties for their own marketing or advertising purposes.
• We do not run targeted advertising inside the App.
• We do not knowingly share personal data with data brokers.

6. International Data Transfers

We aim to keep all personal data processed through Lobby within the European Economic Area (EEA). Firebase services are configured for a European region, and AWS resources used by Lobby are located in eu-central-1 (Frankfurt, Germany).

However, some of our processors are members of corporate groups headquartered outside the EEA, and limited operational support (for example, security investigations, billing operations) may take place from outside the EEA. Where personal data is transferred outside the EEA or the United Kingdom, we rely on one or more of the following safeguards required by Articles 44–49 GDPR:

• an adequacy decision from the European Commission (for example, for transfers to organisations participating in the EU–US Data Privacy Framework);
• the European Commission's Standard Contractual Clauses (SCCs), supplemented by additional measures where necessary as a result of a transfer impact assessment;
• binding corporate rules approved by a competent supervisory authority; or
• an explicit derogation under Article 49 GDPR (for example, your explicit consent for a specific transfer).

You can request a copy of the safeguards we rely on by contacting privacy@lobbyapp.eu.

7. How Long We Keep Your Personal Data

We keep personal data only for as long as we need it for the purposes set out in this Policy, and then we delete or anonymise it. The retention periods below are general guidelines; specific data may be kept for shorter or, in limited cases, longer periods where required by law.

At the end of the relevant retention period, we permanently delete the personal data or anonymise it so that you can no longer be identified from it.

8. Your Rights

Subject to the conditions set out in the GDPR, you have the following rights in relation to your personal data:

8.1 Right of access (Art. 15 GDPR)

You can ask us to confirm whether we are processing personal data about you and to provide you with a copy of that data and information about how we process it.

8.2 Right to rectification (Art. 16 GDPR)

You can ask us to correct inaccurate personal data or to complete incomplete personal data. You can do this directly inside the App for most fields (by editing your profile).

8.3 Right to erasure / right to be forgotten (Art. 17 GDPR)

You can ask us to delete personal data we hold about you. The fastest way is to delete your Account from Settings → Delete account. We may keep limited information after deletion to comply with our legal obligations, defend legal claims, or prevent abuse (see Section 7).

8.4 Right to restriction of processing (Art. 18 GDPR)

You can ask us to suspend processing of your personal data, for example while we check the accuracy of disputed data.

8.5 Right to data portability (Art. 20 GDPR)

Where processing is based on your consent or on a contract with you, you can ask us to provide your personal data in a structured, commonly used, and machine-readable format, or to transmit it directly to another controller where technically feasible.

8.6 Right to object (Art. 21 GDPR)

You can object at any time to processing carried out on the basis of our legitimate interests. We will stop processing unless we can show compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is necessary for legal claims.

8.7 Right to withdraw consent (Art. 7(3) GDPR)

Where we process your personal data on the basis of consent — most importantly for face verification and the website waitlist — you can withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

8.8 Right not to be subject to automated decision-making (Art. 22 GDPR)

See Section 12 below for information on automated decisions, including photo moderation and face verification.

8.9 How to exercise your rights

To exercise any of these rights, contact us at privacy@lobbyapp.eu. We will respond within one month, although we may extend this period by up to two further months for complex requests, in which case we will let you know within the first month. We do not charge a fee unless your request is manifestly unfounded or excessive.

8.10 Right to lodge a complaint

If you believe that we have not handled your personal data lawfully, you have the right to lodge a complaint with a data protection supervisory authority, including the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH), Falk Miksa utca 9-11, 1055 Budapest, Hungary, https://naih.hu. You may also lodge a complaint with the supervisory authority in the EU/EEA Member State where you live or work.

9. Cookies and Similar Technologies

Lobby is delivered as a mobile application (iOS and Android) and also operates this public website. The App does not use HTTP cookies. The website waitlist form does not use HTTP cookies and does not run third-party behavioural analytics or tracking pixels.

However, the App and the SDKs it depends on (Firebase, AWS, Apple, Google) read and write information on your device. This is necessary for the App to work and includes:

• authentication tokens stored locally by Firebase Authentication so you do not have to sign in every time;
• cached profile, event, and city data stored locally on your device for performance (we use an on-device cache and an embedded SQLite database for the city list);
• FCM tokens registered with the operating system for push notifications;
• standard application caches managed by the operating system.

None of this storage is used for advertising or cross-app tracking. If we introduce website cookies, advertising, or analytics SDKs that require consent, we will publish a cookie banner and update this Policy.

10. How We Protect Your Personal Data

We use a combination of technical and organisational measures to protect your personal data, including:

• encryption in transit (HTTPS / TLS) between the App, Firebase, AWS, and our Cloud Functions;
• encryption at rest in Firestore, AWS S3, and Firebase Authentication, using keys managed by the cloud provider;
• Firestore security rules and AWS IAM policies that restrict access to authorised personnel and authorised application code only;
• signed URLs for direct S3 uploads, so that profile photos never pass through an intermediate server;
• storing website waitlist submissions outside the public website document root;
• shared-secret authentication and rate-limiting on Cloud Functions that communicate with AWS;
• rate limits on sensitive operations such as face verification, to prevent automated abuse;
• regular review of access permissions and dependency security.

No system is 100% secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours, and we will notify you without undue delay where the breach is likely to result in a high risk to your rights and freedoms, in accordance with Articles 33 and 34 GDPR.

11. Children

Lobby is intended exclusively for adults aged 18 and over. We do not knowingly process personal data of anyone under 18. If we become aware that a User is under 18, we will close the Account and delete the related personal data, subject to limited retention for safety and legal purposes.

If you are a parent or guardian and you believe that your child has provided personal data to Lobby, please contact us at privacy@lobbyapp.eu and we will take immediate steps to investigate and delete it.

12. Automated Decisions and Profiling

Lobby uses some automated processing to make the platform work and to keep people safe. The decisions described below do not produce legal effects for you in the sense of Article 22 GDPR (for example, they do not deny you a financial product or a contract), but you should be aware of them:

12.1 Profile photo moderation

Profile photos go through automated moderation before they are made public. The system can mark a photo as approved, pending human review, or rejected. You can always try again with a different photo. Onboarding can only be completed once you have at least one approved photo.

12.2 Face verification

Face verification uses face comparison (AWS Rekognition or a comparable service) to decide whether your selfie matches your current main profile photo. It runs both at onboarding and every time you replace your main profile photo. The output is a similarity score and one of three outcomes: verified, needs retry, or rejected. A 'verified' badge does not say anything about your identity, character, or background — only that the face comparison succeeded against the photo currently displayed on your profile. If a main-photo replacement attempt fails or is abandoned before verification succeeds, no change is committed and your previous photo and verified status are automatically restored. You can ask for human review by contacting privacy@lobbyapp.eu.

12.3 Event ranking and discovery

We rank and surface Events based on signals such as your selected city and search radius, your interests, the geohash of the Event, the Event's date, capacity, and engagement. This ranking is purely about which Events to show you; it does not restrict your access to Events. You can override the ranking by browsing or searching manually.

12.4 Your rights

You have the right to obtain human intervention, to express your point of view, and to contest any of these decisions. To do so, contact privacy@lobbyapp.eu.

13. Deleting Your Account

You can delete your Account at any time from inside the App (Settings → Delete account) or by emailing privacy@lobbyapp.eu from the email address linked to your Account.

When you delete your Account, our backend will:

• delete or anonymise your profile in Firestore, including your private and public profile documents;
• delete your profile photos from AWS S3 (pending, public, and rejected buckets);
• revoke your Firebase Authentication account so the credentials can no longer be used;
• remove you from your friends' friend lists and from upcoming Events you joined;
• anonymise endorsements you sent or received so that aggregated counts remain correct;
• delete your FCM tokens so you stop receiving push notifications.

Some content may persist after deletion, including: chat messages you sent to other Users, which remain visible to recipients (with the sender shown as “Unknown”) until the Event-chat retention window elapses (approximately 35 days after the Event’s scheduled date — see Section 7), after which they are deleted along with everyone else’s messages; system messages generated by Lobby; and a hashed identifier kept solely to prevent banned individuals from re-registering. Where the law requires us to keep records (for example, to defend legal claims or to comply with tax obligations if and when paid features are introduced), we will keep only the minimum data necessary.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes in the law, in the App, or in the way we use third-party services. When we make material changes, we will let you know inside the App and update the 'Last updated' date at the top of this document. If a change requires your consent, we will ask for it before the new processing begins. Older versions are available on request from privacy@lobbyapp.eu.

15. How to Contact Us

If you have any questions, requests, or complaints about this Privacy Policy or our handling of your personal data, please contact us first so we can try to help.

• Privacy enquiries and user-rights requests: privacy@lobbyapp.eu
• General/legal contact: legal@lobbyapp.eu
• Postal: [COMPANY LEGAL NAME], [REGISTERED ADDRESS], Hungary

If you are not satisfied with our response, you have the right to complain to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) at https://naih.hu, or to the supervisory authority in the EU/EEA Member State where you live or work.

— End of Privacy Policy —