PRIVACY POLICY

Privacy Policy – Socra

Effective Date: September 30, 2025

Last Updated: September 30, 2025

Socra (“we,” “our,” or “us”) is operated by Socra App, Immerseelstraat 25, 5175CH Loon op Zand, The

Netherlands. We are committed to protecting your privacy and safeguarding your personal data. This

Privacy Policy explains comprehensively what data we collect, why we collect it, how it is processed, the

safeguards in place, and the rights you have. We want to ensure that our users worldwide understand their

rights and our responsibilities under applicable law.

1. Who We Are and Contact Information

Socra App acts as the Data Controller responsible for the processing of your personal data. Our company

address is Immerseelstraat 25, 5175CH Loon op Zand, The Netherlands. For privacy-related matters,

please contact us at contact@socra-app.com. We currently do not appoint a Data Protection Officer

(DPO), as our activities do not require it under GDPR rules, but we ensure a direct contact point for all

privacy matters.

2. Scope

This Privacy Policy applies to all users worldwide. As a company established in the European Union, we

primarily comply with the General Data Protection Regulation (GDPR). We also respect other applicable

laws such as the California Online Privacy Protection Act (CalOPPA) and the California Consumer Privacy

Act (CCPA/CPRA). If a user’s local law provides stronger protection, those protections shall prevail.

3. Eligibility & Children’s Privacy

The App is not intended for children under 13 years of age. In the European Union, depending on the

country, parental or guardian consent may be required if the user is between 13 and 16 years of age. To

remain fully compliant, Socra requires users under 16 in the EU to have verified parental consent unless

their national law permits a lower age. If we discover that we have collected data from a child without

appropriate consent, we will delete that information without delay.

4. Information We Collect

We collect:

• Account information: email address, username, and password.

• User activity data: posts, comments, messages, photos, videos, friend lists, and other social interactions.

• Technical and analytical information: IP addresses, device type, operating system, and app usage

patterns. We use Google Analytics and App Store Connect for insights and improvement.5. How We Use Your Information

Data is processed for the following purposes, under GDPR lawful bases:

• Account creation and management (performance of a contract).

• Communication and customer support (performance of a contract / legitimate interest).

• Content moderation, enforcement of community standards, and safety (legitimate interest / legal

obligation).

• Personalization and recommendations (legitimate interest).

• Statistics and analytics to improve our services (legitimate interest).

• Advertising and marketing in the future, with prior opt-in consent where required (consent).

• Legal compliance, enforcement, and fraud prevention (legal obligation).

6. Sharing of Data

We only share data with trusted third parties: hosting providers, analytics providers (Google, Apple), and

advertising partners (future use). Where these providers process data outside the EU, we implement

Standard Contractual Clauses (SCCs) or equivalent safeguards. For transparency, Google LLC and Apple

Inc. may process data in the United States.

7. Retention of Data

We retain data only as long as necessary for our services or legal obligations:

• Account data: retained while the account is active.

• Upon account deletion: personal data will be deleted or anonymized within 30 days; backups are cleared

within 90 days.

• Analytics data: retained for up to 24 months, justified by the need for trend analysis and product

improvement.

• Legal or regulatory data: retained longer if required for compliance, fraud prevention, or dispute

resolution.

8. User Rights

You have the following rights under GDPR and equivalent laws: access, rectification, erasure, restriction,

portability, objection, and withdrawal of consent. Requests will be handled without undue delay and withinone month, extendable to two months for complex cases. To exercise these rights, contact:

contact@socra-app.com. You may also lodge complaints with your local supervisory authority. In the

Netherlands, this is the Autoriteit Persoonsgegevens.

9. Security Measures

We implement industry-standard measures to secure your data, including encryption in transit, restricted

access, staff training, monitoring, vulnerability management, and periodic audits. While no system is

completely secure, we are committed to responding promptly to incidents. In the event of a data breach,

we will notify affected users and authorities in compliance with GDPR timelines.

10. Cookies & Tracking

The App may use cookies, SDKs, and similar tracking technologies for essential functionality, analytics,

and (in the future) advertising. We will always request explicit consent for non-essential cookies or

targeted advertising through in-app consent mechanisms. Users can change preferences at any time in

device or app settings.

11. International Users

• EU/EEA Users: GDPR applies fully.

• California Users: You have rights under CCPA/CPRA, including the right to know, delete, and opt out of

data sharing. We do not sell your personal data. If this changes, you will be notified and given the right to

opt out before any sale occurs.

• Other regions: Your local laws may grant additional rights, which we will respect. This Privacy Policy is

not intended to override mandatory protections.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, or practices. Updates will be

posted in the App and on our website, with the 'Last Updated' date amended. For significant changes, we

will notify users directly and, if required, request renewed consent. Continued use of the App after updates

constitutes acceptance.

13. Governing Law

This Privacy Policy is governed by the laws of The Netherlands. Any disputes arising from or related to this

Policy shall be submitted to the competent court in Amsterdam, unless mandatory consumer laws in your

country of residence require otherwise.

14. ContactFor privacy inquiries or to exercise your rights, please contact:

Email: contact@socra-app.com

Address: Immerseelstraat 25, 5175CH Loon op Zand, The Netherlands

We will respond to all legitimate requests within statutory deadlines.

PRIVACY POLICY

Privacy Policy – Socra

Effective Date: September 30, 2025

Last Updated: September 30, 2025

Socra (“we,” “our,” or “us”) is operated by Socra App, Immerseelstraat 25, 5175CH Loon op Zand, The

Netherlands. We are committed to protecting your privacy and safeguarding your personal data. This

Privacy Policy explains comprehensively what data we collect, why we collect it, how it is processed, the

safeguards in place, and the rights you have. We want to ensure that our users worldwide understand their

rights and our responsibilities under applicable law.

1. Who We Are and Contact Information

Socra App acts as the Data Controller responsible for the processing of your personal data. Our company

address is Immerseelstraat 25, 5175CH Loon op Zand, The Netherlands. For privacy-related matters,

please contact us at contact@socra-app.com. We currently do not appoint a Data Protection Officer

(DPO), as our activities do not require it under GDPR rules, but we ensure a direct contact point for all

privacy matters.

2. Scope

This Privacy Policy applies to all users worldwide. As a company established in the European Union, we

primarily comply with the General Data Protection Regulation (GDPR). We also respect other applicable

laws such as the California Online Privacy Protection Act (CalOPPA) and the California Consumer Privacy

Act (CCPA/CPRA). If a user’s local law provides stronger protection, those protections shall prevail.

3. Eligibility & Children’s Privacy

The App is not intended for children under 13 years of age. In the European Union, depending on the

country, parental or guardian consent may be required if the user is between 13 and 16 years of age. To

remain fully compliant, Socra requires users under 16 in the EU to have verified parental consent unless

their national law permits a lower age. If we discover that we have collected data from a child without

appropriate consent, we will delete that information without delay.

4. Information We Collect

We collect:

• Account information: email address, username, and password.

• User activity data: posts, comments, messages, photos, videos, friend lists, and other social interactions.

• Technical and analytical information: IP addresses, device type, operating system, and app usage

patterns. We use Google Analytics and App Store Connect for insights and improvement.5. How We Use Your Information

Data is processed for the following purposes, under GDPR lawful bases:

• Account creation and management (performance of a contract).

• Communication and customer support (performance of a contract / legitimate interest).

• Content moderation, enforcement of community standards, and safety (legitimate interest / legal

obligation).

• Personalization and recommendations (legitimate interest).

• Statistics and analytics to improve our services (legitimate interest).

• Advertising and marketing in the future, with prior opt-in consent where required (consent).

• Legal compliance, enforcement, and fraud prevention (legal obligation).

6. Sharing of Data

We only share data with trusted third parties: hosting providers, analytics providers (Google, Apple), and

advertising partners (future use). Where these providers process data outside the EU, we implement

Standard Contractual Clauses (SCCs) or equivalent safeguards. For transparency, Google LLC and Apple

Inc. may process data in the United States.

7. Retention of Data

We retain data only as long as necessary for our services or legal obligations:

• Account data: retained while the account is active.

• Upon account deletion: personal data will be deleted or anonymized within 30 days; backups are cleared

within 90 days.

• Analytics data: retained for up to 24 months, justified by the need for trend analysis and product

improvement.

• Legal or regulatory data: retained longer if required for compliance, fraud prevention, or dispute

resolution.

8. User Rights

You have the following rights under GDPR and equivalent laws: access, rectification, erasure, restriction,

portability, objection, and withdrawal of consent. Requests will be handled without undue delay and withinone month, extendable to two months for complex cases. To exercise these rights, contact:

contact@socra-app.com. You may also lodge complaints with your local supervisory authority. In the

Netherlands, this is the Autoriteit Persoonsgegevens.

9. Security Measures

We implement industry-standard measures to secure your data, including encryption in transit, restricted

access, staff training, monitoring, vulnerability management, and periodic audits. While no system is

completely secure, we are committed to responding promptly to incidents. In the event of a data breach,

we will notify affected users and authorities in compliance with GDPR timelines.

10. Cookies & Tracking

The App may use cookies, SDKs, and similar tracking technologies for essential functionality, analytics,

and (in the future) advertising. We will always request explicit consent for non-essential cookies or

targeted advertising through in-app consent mechanisms. Users can change preferences at any time in

device or app settings.

11. International Users

• EU/EEA Users: GDPR applies fully.

• California Users: You have rights under CCPA/CPRA, including the right to know, delete, and opt out of

data sharing. We do not sell your personal data. If this changes, you will be notified and given the right to

opt out before any sale occurs.

• Other regions: Your local laws may grant additional rights, which we will respect. This Privacy Policy is

not intended to override mandatory protections.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, or practices. Updates will be

posted in the App and on our website, with the 'Last Updated' date amended. For significant changes, we

will notify users directly and, if required, request renewed consent. Continued use of the App after updates

constitutes acceptance.

13. Governing Law

This Privacy Policy is governed by the laws of The Netherlands. Any disputes arising from or related to this

Policy shall be submitted to the competent court in Amsterdam, unless mandatory consumer laws in your

country of residence require otherwise.

14. ContactFor privacy inquiries or to exercise your rights, please contact:

Email: contact@socra-app.com

Address: Immerseelstraat 25, 5175CH Loon op Zand, The Netherlands

We will respond to all legitimate requests within statutory deadlines.

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