Cleangor

Privacy policy

This is an English translation of the Croatian original.

1. Introduction

1.1 We are committed to protecting the privacy of users of the Cleangor app and website and to applying this Privacy Policy together with the related rules (where applicable and published), including:

  • App permissions
  • Cookie policy
  • SMS/notification rules (if used)

1.2 This policy applies where we act as data controller with regard to the personal data of visitors to our website and users of our services; in other words, where we determine the purposes and means of processing that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for providing the website and services, we will ask for your consent to use cookies on your first visit.

1.4 Our website and/or mobile app may contain privacy controls that affect how we process your personal data. By using those controls (e.g. notification settings, location permissions, profile visibility settings where available) you can limit certain types of processing.

1.5 In this policy, "we", "us" and "our" refer to Cleangor, operated by the data controller named in point 3.

2. How we use your personal data

2.1 In Sections 2.a to 2.d we set out:

(a) the general categories of personal data we may process; (b) for personal data we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.

2.2 Usage data

We may process data about your use of our website and services ("usage data"). Usage data may include your IP address, geographical location (approximate, derived from the IP address), browser type and version, operating system, referral source, length of visit, pages viewed and navigation paths on the website, and information about the timing, frequency and patterns of your use of the service. For the mobile app, it may also include technical device identifiers (where applicable) and diagnostic data.

The source of usage data is our technical logs and, where implemented, analytics and diagnostics systems. This data may be processed to analyse use of the website and services, improve stability, ensure security and prevent abuse.

The legal basis for this processing is our legitimate interests, in particular ensuring security, preventing abuse and improving the Service. Where applicable (e.g. analytics cookies that are not necessary), the legal basis may be your consent.

2.3 Account and profile data

We may process data about your account ("account and profile data"). This may include your first and last name, address (e.g. the address of the premises or the service location the user enters), phone number, email address, profile photos and other information the user voluntarily enters in the profile (e.g. area of work, availability, description of experience).

Account data may be processed to manage the account, provide the functionality of the Service, ensure security, back up the database and communicate with users.

The legal basis for this processing is the performance of a contract (use of the Service). For certain optional elements (depending on settings and features) the legal basis may be consent.

2.4 Publication data

We may process information you publish for display to other users through the Service ("publication data"), for example profile information intended to be visible (e.g. display name, profile picture if you set one, description, area of work).

Publication data may be processed to enable publication and to administer the Service.

The legal basis for this processing is the performance of a contract and/or consent (depending on the feature and visibility settings).

2.5 Enquiry and job data

We may process information contained in an enquiry, request or arrangement relating to a cleaning service ("enquiry and job data"). This data may include the address of the premises, job description, special instructions, times, logistical details and photos users voluntarily upload (e.g. to clarify the scope of work).

Enquiry and job data may be processed to enable users to be matched and to organise the provision of the service.

The legal basis for this processing is the performance of a contract.

2.6 Notification data

We may process data we use to send notifications, including notifications about job status or chat messages ("notification data"), for example the device identifier for push notifications (token), notification settings and information needed to deliver notifications.

Notification data may be processed to send notifications and ensure the functionality of the Service.

The legal basis for the processing is the performance of a contract for essential notifications and, where applicable, consent for optional notifications.

2.7 Correspondence data

We may process information contained in communications you send us ("correspondence data"), including the content of the communication and metadata (e.g. time sent, sender address). Our website and/or app may generate metadata associated with communications through contact forms or support.

This data may be processed to communicate with users, provide customer support and keep records.

The legal basis for this processing is our legitimate interests, in particular the proper administration of our business and communication with users.

2.8 Legal claims

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in administrative or out-of-court procedures.

The legal basis for this processing is our legitimate interests, in particular the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.9 Insurance, risk management, professional advice

We may process any of your personal data identified in this policy where necessary for obtaining or maintaining insurance cover, managing risks or obtaining professional advice.

The legal basis for this processing is our legitimate interests, in particular the protection of our business against risks.

2.10 Legal obligations and vital interests

In addition to the specific purposes set out in this Section 2, we may process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

2.11 Personal data of others

Please do not supply us with the personal data of other people unless we expressly ask you to or it is necessary for using the Service (e.g. a contact person for handing over keys, where relevant).

2.a.i Collection and use of information (mobile app)

For a better experience while using the Service, we may ask you to provide certain personal data, including but not limited to: email address, first and last name, phone number, device identifier (where applicable), address of the premises or service, city and photos (e.g. a profile photo or photos uploaded through the Service).

The data we request will be retained and used as described in this Privacy Policy.

The app also uses certain third-party services that may collect information used to identify you.

Third-party services (examples)

  • Google Play Services (Android)
  • Google Sign-In (Google Login)
  • Google Maps Platform (Google Maps API)

2.a.ii Usage data (mobile devices)

We may also collect data your device sends when you use the Service through a mobile device ("Usage Data"). This may include your device's IP address, device type, unique device ID (where applicable), mobile operating system and other diagnostic data.

2.a.iii Location data

We may use and store information about your location if you give us permission to do so. We use this data for the functionality of the Service, for example to show service providers near you, and for more efficient matching and logistics.

You can turn location services on or off in your device settings at any time.

2.a.iv Tracking and cookies (web)

We use cookies and similar tracking technologies to track activity on the website and store certain information. Cookies are files with a small amount of data that may include a unique anonymous identifier. Cookies are sent to your browser from a website and stored on your device.

We may also use other technologies such as tags and scripts to collect and track information and to improve and analyse the Service.

You can instruct your browser to refuse all cookies or to tell you when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of the website.

Examples of cookies we may use:

  • Session cookies (to run the website)
  • Preference cookies (to remember settings)
  • Security cookies (for security)

2.a.v Use of data

We use the data collected for various purposes, including:

  • providing and maintaining the Service
  • notifying you about changes to the Service
  • enabling interactive features (including chat)
  • providing customer support
  • gathering analytics to improve the Service
  • monitoring use of the Service
  • detecting, preventing and resolving technical issues
  • preventing abuse, fraud and breaches of the Terms of Use

2.a.vi A note on chat (Chat Data)

The Service includes a chat feature that lets users communicate to arrange and organise work. We may process:

  • message content,
  • attachments (e.g. photos),
  • metadata (time sent, sender/recipient identifiers).

We do not actively monitor chat communication in real time. However, we may review chat communication where necessary to investigate a report of abuse, enforce the Terms of Use, fulfil legal obligations or protect users and our legal rights.

2.b Legal basis for processing under the GDPR

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal data described in this Policy depends on the data we collect and the context. We may process personal data because:

  • we need to perform a contract with you (provide the Service),
  • you have given us consent,
  • the processing is in our legitimate interests and is not overridden by your rights,
  • we need to comply with the law.

A note on payments: Cleangor does not process payments within the app and does not collect card or bank account data. Payments take place directly between users.

2.b.i Retention of data

We will retain your personal data only for as long as necessary for the purposes set out in this Policy. We will retain and use personal data to the extent necessary to comply with legal obligations, resolve disputes and enforce our agreements and policies.

We usually retain usage data for a shorter period, except where it is used to strengthen security or improve the functionality of the Service, or where we are legally required to retain it longer.

Chat communication may be retained for a reasonable time where necessary for security, dispute resolution and the protection of legal rights.

2.b.ii Transfer of data

Your data, including personal data, is hosted and processed within the European Union.

If it becomes necessary in the future to transfer personal data outside the EEA, we will ensure appropriate safeguards, such as standard contractual clauses or other lawful mechanisms under the GDPR.

2.c Disclosure of data

2.c.i Business transactions

If we are involved in a merger, acquisition, reorganisation or sale of assets, your personal data may be transferred. We will notify you before your personal data becomes subject to a different privacy policy, where applicable.

2.c.ii Disclosure to authorities / legal requirements

We may disclose personal data in good faith where we believe it is necessary to:

  • comply with a legal obligation
  • protect and defend our rights or property
  • prevent or investigate possible abuse in connection with the Service
  • protect the personal safety of users or the public
  • protect against legal liability

2.c.iii Security of data

The security of your data is important to us, but no method of transmission over the internet and no method of electronic storage is 100% secure. Although we strive to use commercially acceptable means of protection, we cannot guarantee absolute security.

2.c.iv "Do Not Track" (DNT)

We do not guarantee support for "Do Not Track" signals. You can enable or disable DNT in your browser settings. You can manage cookies as described in points 13–15.

2.d Your rights under the GDPR

If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the processing of your personal data.

If you want to know what personal data we hold about you or want it removed from our systems, contact us at: support@cleangor.com.

In certain circumstances you have the following rights:

2.d.i The right to access, update or delete

2.d.ii The right to rectification

2.d.iii The right to object

2.d.iv The right to restriction of processing

2.d.v The right to data portability

2.d.vi The right to withdraw consent

You also have the right to lodge a complaint with a supervisory authority. In Croatia, this is AZOP (the Croatian Personal Data Protection Agency).

We may ask you to verify your identity before acting on a request.

3. Our details

3.1 This mobile app and the Cleangor website are owned and operated by:

CALIPTO, OBRT ZA USLUGE, VL. IVAN PUŠKAR A. G. Matoša 8, 10450 Jastrebarsko, Croatia OIB: 76350619295

3.2 You can contact us: (a) by post at the address given above; or (b) by email: support@cleangor.com

4. Providing your personal data to others

4.1 We may disclose your personal data to our service providers insofar as reasonably necessary for the purposes and on the legal bases set out in this Policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for obtaining insurance, managing risks, obtaining professional advice or the establishment, exercise or defence of legal claims.

4.3 In addition, we may disclose your personal data where such disclosure is necessary to comply with a legal obligation or to protect vital interests.

5. International transfers of your personal data

5.1 Data is hosted and processed within the European Union. When third-party services (e.g. Google) are used, certain processing may take place under their terms; where relevant, we ensure lawful safeguards.

5.2 Personal data you publish (e.g. profile data visible to other users) may be available to other users of the Service. Choose carefully what you publish. We cannot prevent misuse by other users beyond our control.

6. Retaining and deleting personal data

6.1 This section sets out the rules for retaining and deleting data.

6.2 Personal data will not be kept for longer than necessary for the purposes of processing.

6.3 Notwithstanding the other provisions, we may retain personal data where necessary to comply with the law or to protect our legal rights or vital interests.

6.4 Data deletion

You can request deletion of your account and personal data by sending a request to support@cleangor.com. We will act on the request in accordance with the GDPR and applicable law, subject to possible lawful retention (e.g. security, disputes).

7. Changes

7.1 We may update this policy from time to time by publishing a new version on the website.

7.2 We recommend that you check this page from time to time.

7.3 We may notify you of significant changes by email, in the app or by posting a notice within the Service.

8. Your rights

8.1 In this section we summarise the rights you have under data protection law.

8.2 Your principal rights are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restriction of processing; (e) the right to object; (f) the right to data portability; (g) the right to complain to a supervisory authority; (h) the right to withdraw consent.

8.3 The rights apply as described in section 2.d and under applicable law.

8.4 You can exercise your rights in writing at: support@cleangor.com

9. Third-party websites and services

9.1 Within the Service we use certain third-party services. Those third parties may process personal data under their own privacy rules.

Examples include: a) Google (Google Sign-In; Google Maps Platform; Google Play Services)

We may update this list from time to time.

9.2 Service providers

We may engage third parties ("Service Providers") to provide the Service, perform related services or help analyse how the Service is used. These third parties have access to personal data only to perform tasks on our behalf and are obliged not to disclose or use it for any other purpose.

9.3 Payments (important note)

Cleangor does not provide in-app payment services and does not process payments. All payments take place directly between the person requesting the service and the service provider.

10. Children's personal data

10.1 Our website and services are intended for people over 18 years of age.

10.2 If we learn that we hold personal data of a person under 18 in our database, we will take steps to delete it.

11. Updating information

11.1 Please let us know if the personal data we hold about you needs to be corrected or updated: support@cleangor.com.

12. App permissions

When you use Cleangor on an iOS/Android device, you will see dialogs asking for certain permissions. Granting permissions improves the experience, but you can refuse each permission individually. You can change permissions in your device settings.

12.1 Location services

If you turn them on, the app may process your location to:

  • show relevant service providers,
  • match more efficiently,
  • show locations on a map (Google Maps).

If you turn them off, you can use the Service by entering a location manually (where available).

12.2 Push notifications

If you turn them on, your device generates a unique token that is stored in order to send notifications (e.g. job status, chat messages). If you turn them off, you will not receive real-time push notifications.

12.3 Camera

Camera access may be requested when you want to take and upload a photo (profile or chat attachment).

12.4 Photos

Access to photos may be requested when you want to select and upload an existing photo (profile or chat attachment).

12.5 Device identifier

We may collect a device identifier for security, diagnostics and abuse prevention.

13. About cookies (web)

13.1 A cookie is a file containing an identifier (a string of letters and numbers) that a web server sends to a web browser and that the browser stores.

13.2 Cookies may be persistent or session cookies.

13.3 Cookies do not usually contain information that directly identifies a user, but personal data we store may be linked to information obtained from cookies.

14. Cookies used by our service providers

14.1 Our service providers may use cookies, and those cookies may be stored on your computer when you visit our website.

14.2 Google Maps API

We use the Google Maps API on the web and/or within the Service to display maps and locations. When you use this feature, data may be processed by Google (e.g. IP address and location data, if enabled), in accordance with their rules.

15. Managing cookies

15.1 Most browsers let you refuse and delete cookies. The methods depend on the browser and its version.

15.2 Blocking all cookies may have a negative effect on the use of many websites.

15.3 If you block cookies, you may not be able to use all the features of our website.

16. A note on payments and limitation of liability

16.1 Cleangor does not process payments and does not store card or bank account data.

16.2 All payments are arranged and made by users directly (the person requesting the service and the service provider).

16.3 To the fullest extent permitted by applicable law, Cleangor is not responsible for disputes relating to payments, non-payment, methods of charging or users' tax obligations, and is not a party to the payment transaction.

This limitation does not exclude liability in cases where exclusion is not permitted by law.

1. Data controller

This Privacy Policy applies to the processing of personal data through the Cleangor mobile app and the associated website (the "Service").

The data controller is:

CALIPTO, OBRT ZA USLUGE, VL. IVAN PUŠKAR A. G. Matoša 8 10450 Jastrebarsko Croatia OIB: 76350619295 Contact email: support@cleangor.com

Hereinafter: "Cleangor", "we", "us".

2. Description of the service

Cleangor is a digital platform that connects:

  • people looking for cleaning services (e.g. owners of holiday apartments, flats and houses)
  • cleaning service providers (cleaners – natural persons, students, trades (obrt) and legal entities)

Cleangor enables:

  • registration and creation of a user account
  • posting and accepting jobs
  • communication through the built-in chat
  • exchange of the information needed to perform the service

Cleangor is not the employer of cleaners nor an employment agency, but solely a technology platform for connecting users.

3. Payments and liability

Cleangor does not process payments or act as an intermediary in financial transactions.

This means:

  • we do not collect credit/debit card data
  • we do not collect bank account data
  • we do not charge payments through the app
  • we do not retain commissions through a payment system
  • we do not make payouts to users

All payments and price arrangements take place exclusively between the person requesting the service and the service provider.

To the fullest extent possible, Cleangor disclaims liability for:

  • the amount and method of charging
  • late payment or non-payment
  • users' tax obligations
  • disputes between users
  • the quality of the service performed

Cleangor is not a contracting party in the relationship between users.

4. What data we collect

4.1 Data users enter

When you register and use the Service, we may collect:

  • first and last name
  • email address
  • phone number
  • address of the premises (people requesting services)
  • area of work (service providers)
  • description of experience and professional information
  • profile photo (if uploaded)

We do not collect sensitive personal data (e.g. health data).

4.2 Google Sign-In (Google Login)

If a user signs in with a Google account, we may receive:

  • first and last name
  • email address
  • the unique identifier of the Google account

We do not get access to the password or other data of the Google account.

The processing is based on the performance of a contract and the user's consent.

4.3 Chat communication

Cleangor includes a built-in chat between users.

We may process:

  • message content
  • photos and attachments
  • time sent and received
  • technical metadata

Purpose of processing:

  • organising and performing the service
  • protecting users
  • resolving disputes
  • preventing abuse

Cleangor does not actively monitor communication in real time, but may access communication in the event of a report of abuse, a breach of the Terms of Use or a legal obligation.

4.4 Technical and analytics data

We may automatically collect:

  • IP address
  • device type
  • operating system
  • app version
  • error and crash logs

This data is used solely for the stability, security and improvement of the Service.

4.5 Location data

If the user allows it, the app may use location data to:

  • show service providers nearby
  • connect users more efficiently

Location services can be turned off in the device settings.

4.6 Push notifications

If the user enables push notifications, we may send:

  • notifications about new enquiries
  • job status changes
  • chat messages

Push notifications can be turned off in the device settings.

5. Legal basis for processing

We process data on the basis of:

  • performance of a contract (use of the app)
  • legitimate interest (security and abuse prevention)
  • consent (location and push notifications)
  • legal obligations

6. Hosting and data storage

Data is stored on servers within the European Union.

We apply technical and organisational protection measures, including:

  • encryption of communication (SSL/TLS)
  • access control to data
  • security mechanisms to protect the system

7. Sharing data

Data may be shared:

7.1 Between users

To perform the service, certain data becomes visible to the other party. We make visible to the other party only the data necessary to perform the service (e.g. name, contact, address where the service is performed), depending on the user's role.

7.2 With technical service providers

We may use trusted technical partners (e.g. hosting, authentication, infrastructure). These partners process data solely on our instructions and in accordance with the GDPR.

We will have data processing agreements (DPA) in place with technical providers

7.3 With competent authorities

We provide data on the basis of a valid and binding request.

8. Data retention periods

We retain data as follows:

Account data (name, email, phone, basic profile)

While the account exists: for the whole lifetime of the account

After the account is deleted: 30 days, after which we delete the data

Order/booking data (who arranged a cleaning with whom, place/service, time)

24 months after the service is performed or cancelled (for customer support, complaints, and proving "what happened" on the platform).

Chat communication between users (within the platform)

If the chat is essential to performing the service and to safety: 12 months from the last message

If the chat is linked to a report of abuse or a dispute: until the internal procedure or dispute is concluded, after which the data is deleted.

Location data

If the location is used "in the moment" to show an offer: keep it as briefly as possible, e.g. 30 days (or less if you can) after the service is performed, unless the location is part of the service address from the order (it then falls under "order data" above).

Technical logs (IP, access logs, errors, security records)

6 months (standard for incident detection and system stability); for security incidents: until the investigation and remediation are complete.

Support

24 months from the closing of the enquiry (for support quality and proof of handling).

Data about "other people" entered by the user (e.g. a contact for keys)

Until the retention period for the order expires (e.g. 24 months) or earlier if the need ceases.

9. Deleting your account and data

The user can request deletion of the account:

Once the request is received:

  • the account is deactivated
  • personal data is deleted, except data we are required to keep by law

10. User rights (GDPR)

Users have the right to:

  • access their data
  • rectification
  • erasure
  • restriction of processing
  • data portability
  • lodge a complaint with the Croatian Personal Data Protection Agency (AZOP)

To exercise these rights, contact: support@cleangor.com

11. Minors

Cleangor is not intended for people under 18 years of age.

If we learn that we have processed data of a minor, the data will be deleted.

12. Changes to the policy

We reserve the right to change this Privacy Policy. Users will be notified of significant changes through the app or the website.