Privacy Policy

1. Introduction

Welcome to Havado. We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how Havado ("we", "us", "our") collects, uses, stores, and protects your personal information when you use our platform at havado.net.

This policy is written in accordance with the General Data Protection Regulation (GDPR) and Dutch privacy law (Uitvoeringswet AVG).

By using Havado, you agree to the collection and use of your information as described in this policy.

2. Who We Are

Platform name: Havado Website: havado.net Email: hello@havado.nl Location: Netherlands

Havado is the data controller responsible for your personal data.

3. What Data We Collect

3.1 Data You Provide Directly

When you register or use Havado, we may collect:

Full name
Email address
Password (encrypted — we never see your actual password)
Profile photo (optional)
Location (city/region)
Phone number (optional)
Payment information (processed securely via Stripe — we do not store card details)
Listing content (photos, descriptions, prices)
Messages sent through our platform

3.2 Data We Collect Automatically

When you use Havado, we automatically collect:

IP address
Browser type and version
Device type (desktop, mobile, tablet)
Pages visited and time spent
Search queries on the platform
Cookies and similar tracking technologies

3.3 Data From Third Parties

We may receive data from:

Stripe — payment status and transaction confirmation (not card details)
Google Analytics — anonymous usage statistics
Social media platforms if you connect your account

4. Why We Collect Your Data (Legal Basis)

We process your data for the following reasons:

| Purpose | Legal Basis | |---|---| | Creating and managing your account | Contract performance | | Processing transactions | Contract performance | | Sending order confirmations and updates | Contract performance | | Buyer and seller communication | Contract performance | | Preventing fraud and abuse | Legitimate interest | | Improving our platform | Legitimate interest | | Sending marketing emails (with consent) | Consent | | Complying with legal obligations | Legal obligation | | Resolving disputes | Legitimate interest |

5. How We Use Your Data

We use your personal data to:

Create and manage your Havado account
Enable you to post listings and complete transactions
Process payments securely via Stripe
Send transaction confirmation emails
Facilitate communication between buyers and sellers
Provide customer support
Detect and prevent fraud, abuse, or illegal activity
Improve and develop our platform
Send you important service updates
Send marketing communications (only with your consent)
Comply with legal obligations

6. Who We Share Your Data With

We do not sell your personal data. We only share data with trusted third parties where necessary:

6.1 Service Providers

Stripe — payment processing (stripe.com/privacy)
Sharetribe — marketplace platform infrastructure
Google Analytics — anonymous website analytics
Email service provider — for transactional and marketing emails
Cloud hosting provider — secure data storage

6.2 Other Users

When you post a listing or complete a transaction:

Your username and profile information is visible to other users
Your general location (city/region) may be shown on listings
Your exact address is never shared publicly

6.3 Legal Requirements

We may disclose your data if required by law, court order, or to protect the rights and safety of Havado and its users.

7. Cookies

Havado uses cookies to improve your experience. Cookies are small text files stored on your device.

We use the following types of cookies:

| Cookie Type | Purpose | |---|---| | Essential cookies | Required for the platform to function | | Analytics cookies | Help us understand how users use the platform | | Preference cookies | Remember your settings and preferences | | Marketing cookies | Used for relevant advertising (only with consent) |

You can manage your cookie preferences at any time through your browser settings. Note that disabling essential cookies may affect platform functionality.

8. Data Retention

We keep your personal data for as long as necessary:

| Data Type | Retention Period | |---|---| | Account data | Until account deletion + 1 year | | Transaction records | 7 years (Dutch tax law requirement) | | Messages | 2 years after last activity | | Marketing data | Until you withdraw consent | | Analytics data | 26 months (anonymised) |

When data is no longer needed, we securely delete or anonymise it.

9. Your Rights Under GDPR

As a user in the EU, you have the following rights:

9.1 Right of Access

You can request a copy of all personal data we hold about you.

9.2 Right to Rectification

You can request correction of any inaccurate or incomplete data.

9.3 Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal data, subject to legal retention requirements.

9.4 Right to Restrict Processing

You can request that we limit how we use your data in certain circumstances.

9.5 Right to Data Portability

You can request your data in a structured, machine-readable format.

9.6 Right to Object

You can object to processing based on legitimate interest, including direct marketing.

9.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens Website: autoriteitpersoonsgegevens.nl Phone: +31 (0)70 888 85 00

10. How to Exercise Your Rights

To exercise any of your rights, contact us at:

Email: hello@havado.nl Subject line: "Privacy Request — [Your Request Type]"

We will respond within 30 days. We may need to verify your identity before processing your request.

11. Data Security

We take data security seriously. Our security measures include:

All data transmitted via SSL/TLS encryption (https)
Passwords are encrypted and never stored in plain text
Payment data processed exclusively by Stripe — PCI DSS compliant
Regular security reviews of our platform
Access to personal data limited to authorised personnel only
Regular backups of all data

Despite our best efforts, no internet transmission is 100% secure. We cannot guarantee absolute security but we take all reasonable measures to protect your data.

12. International Data Transfers

Havado is based in the Netherlands. If we transfer your data outside the EU/EEA, we ensure appropriate safeguards are in place in accordance with GDPR requirements, including Standard Contractual Clauses where applicable.

13. Children's Privacy

Havado accounts must be registered by users aged 18 or over. Users under 18 may use the platform under parental supervision, with a parent or guardian registering and managing the account.

We do not knowingly collect personal data from children under 16 without verifiable parental consent. If you believe we have inadvertently collected such data, please contact us immediately at hello@havado.nl and we will delete it promptly.

14. Third Party Links

Havado may contain links to third party websites. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

Email notification to your registered address
A prominent notice on our platform

The date at the top of this policy indicates when it was last updated. Continued use of Havado after changes constitutes acceptance of the updated policy.

16. Contact Us

For any privacy-related questions or requests:

Email: hello@havado.nl Website: havado.net Address: Netherlands

We aim to respond to all privacy enquiries within 5 business days.

This Privacy Policy was last updated in June 2025. It is intended as a starting point and should be reviewed by a qualified legal professional before publication to ensure full compliance with GDPR and Dutch privacy law.