Privacy Policy

I. General information

A. Who we are and how you can contact us

We are ELLU S.R.L., a limited liability company having its registered office in Bucharest, 10-12 Belgrad Street, Attic, District 1, Romania, registered with the Trade Registry under no. J2025070231006 (the "Company"). For the purposes of data protection legislation, we act as a data controller whenever we process your personal data.

The confidentiality of your personal data is one of the Company's main concerns. As we are always open to hearing your views and to providing any additional information you may require regarding the processing of your data, we encourage you to contact us at office@appme.app or by telephone at +40 774 048 038.

B. Applicability

This document explains how we collect, use and otherwise process your personal data when you use our AppMe platform (the "Platform" / "AppMe").

The AppMe Platform is a digital platform available both through a mobile application and through a web interface, which enables connections between Clients and Professionals. "Clients" are individuals seeking short-term services, while "Professionals" are legal entities or individuals acting as independent professionals who promote and/or display their commercial service offers to Clients.

This Privacy Policy applies to, and is addressed to, the following categories of persons:

Clients;
Professionals;
Visitors to the Platform.

II. If you are, or wish to become, a Client of the Platform

In order to create an account and sign in, the user must provide contact details consisting of first name, last name, telephone number and e-mail address, or may opt, where applicable, to authenticate through an external identity provider (i.e., Google). In the latter case, that provider will only transmit to us certain basic identification data (such as first name, last name, e-mail address and profile picture (if any) associated with the account), to the extent you have authorised this through the provider's interface. At no time does the Company have access to your Google or Apple account password.

If you choose to create an AppMe account directly on the Platform (without using a Google account), you will set the credentials relating to your account yourself. The Company does not have access to your password in readable form and cannot view it at any time.

A. What data do we process about you?

The categories of personal data we process include:

Profile data provided directly by you: first name, last name, telephone number and contact e-mail address, home/residential address or workplace address (as applicable), the location where the requested service is to be performed, as well as other details such as a description of the requested service and your interests and needs, insofar as these are necessary to enable the Professional to provide customised and tailored services to each Client.
Except for certain data expressly marked as mandatory by a specific sign (an asterisk (*) placed next to the relevant fields within the Platform), the provision of the other personal information is optional. Please note, however, that you may be unable to access certain functionalities of our Platform, or to use the Platform effectively, if such information is incomplete or inaccurate.
If you use an e-mail address to create an account on the Platform and subsequently choose to authenticate through an external identity provider, our system may automatically associate your existing account with the external provider account, to the extent they use the same e-mail address. As a result of such association, certain basic information supplied by the external provider (such as first name, last name or profile image) may be imported and used to complete or update your Platform profile. If you do not wish such account linking or automatic profile updating to occur, we recommend that you use separate sign-in methods or contact us for assistance.
Data regarding your interaction with the Platform: details relating to the services requested through the Platform, any other content and information posted, uploaded, transmitted or otherwise made available on the Platform and/or sent by you to other Professionals, including service requests, reviews and ratings, chat messages, videos, photographs and any other materials, regardless of whether these are transmitted publicly or privately.
Technical data generated by the Platform:
When you use the Platform, we receive information about the type of device you use to access the Platform, the device identifier, information relating to the mobile network used, the device operating system, your IP address, location inferred from the IP address, the web browser used and information relating to device settings (for example, date and time, preferred language, etc.). With your consent, your device may also transmit location data based on GPS or other tools used to identify your location. We use such location data only in order to connect you with Professionals located in your area and to optimise the services based on location. You may refuse or withdraw GPS access permission at any time from your device settings; in such case, we will only use approximate location data (for example, based on the IP address or address information provided by you).

B. For what purposes do we process your data?

We will use your personal data for the following purposes:

Onboarding to the Platform - if you wish to use the Company's services and identify Professionals for specific services, you must go through the onboarding process.
Legal basis: conclusion and performance of the service agreement with you.
Use of the Platform - the services available through the Platform involve connecting Clients and Professionals.
The information made available by you helps us contact you or put you in contact with Professionals who provide Services in your area of interest, and helps ensure smooth cooperation between you and the Professionals. At the same time, the Professionals' selection of your service requests may depend on the information you provide, and the way in which you use the Platform and your preferences in selecting services is necessary for us to understand your experience in relation to the Platform.
Legal bases:
1. performance of the contract concluded with you;
2. our legitimate interest: (i) to ensure the quality of the services provided through the Platform and efficient communication between Client and Professional, and (ii) to prevent abusive or improper use of the Platform.
Use and payment of Services
If the Client wishes to pay online for services contracted through our Platform, we will process the following data: the client's first name and last name / business name, address, e-mail address, telephone number, the issuing bank of the payment card, a partially anonymised card number, and the card type.
Please note that this information is used exclusively for the secure processing of the payment through our secure payment service providers. The Company does not store the full number of your card in its own systems, but only a transaction identifier and, where appropriate, the last digits of the card for reference purposes. In this case, the personal data will be processed in order to complete the online payment transaction requested by you, on the basis of the performance of the contract concluded with you.
Legal basis: performance of the contract concluded with you.
Managing our relationship with you (Client)
We process your personal data when you request support from us in connection with the use and/or operation of the Platform (for example, when you send us requests regarding the Platform's functionalities or malfunctions).
We may send you communications in order to keep you informed about the functioning of the Platform (for example, when we carry out maintenance operations or when we have updated the Platform). In addition, to ensure that you remain informed about the Service you have chosen, we may send such communications through the Platform or by other means of distance communication.
Legal basis: our legitimate interest in providing quality services suited to your needs.
Sending commercial communications
The Company processes the e-mail address you provide when you choose, through the Platform, to receive communications regarding the products and services offered via the Platform.
Legal basis: your consent.
You may express your consent for the processing of data for this purpose by ticking the relevant box at the time your Client account is created or, after account creation, in the settings section associated with your account. To unsubscribe from such commercial communications, you may use the option available at the end of each e-mail containing commercial communications, or untick the relevant box in your account settings.
Protection of our rights and interests
We may process your personal data in order to protect ourselves against fraud and to defend our rights and interests in the context of potential or existing disputes or litigation in which we may be involved, regardless of their nature and of the authority before which they are conducted.
In this context, we may receive or disclose your personal data to third parties (for example, courts or public authorities), or it may be necessary to disclose your information in order to comply with our legal obligations to respond to requests from authorities.
We wish to assure you that we will disclose your personal data only where, following an internal assessment or consultation with our external advisers, we conclude that we are under a legal obligation to do so.
Legal bases:
1. a legal obligation, where disclosure is required by law;
2. a legitimate interest, where disclosure is based on a sound justification and there are no overriding fundamental rights of the data subjects;
3. in addition, we may disclose your personal data on the basis of our legitimate interest in properly handling disputes and litigation, and in defending our rights and interests in such proceedings.
Improvement of the services and the Platform
We analyse the services and the Platform, as well as your interaction with and experience of them, because we aim to continuously improve our services and products. We also seek to understand and assess the Platform's performance so that we can develop and offer you new services and functionalities tailored to your needs.
For the purposes set out above, we will, as a rule, process anonymous or aggregated data. By way of exception, we may also process data that could ultimately lead to your identification, if such processing is strictly necessary for the achievement of the purposes described above.
Legal basis: our legitimate interest in measuring the performance and functionality of the Platform and in understanding how we can develop/improve the Platform and our services.

III. If you are, or wish to register as, a Professional on the Platform

A. What data do we process about you?

The categories of personal data we process in relation to you include:

Profile data provided directly by you: first name, last name, telephone number and contact e-mail address, the location where the service is to be provided, and other details such as your professional experience, applicable rates and working schedule, statements and certifications. These are necessary in order for the Client to make a preliminary assessment of your suitability and qualifications to provide the services for which the Client has submitted a request through the Platform and to request that such services be performed by you.
Except for certain data expressly identified as such, the provision of the other personal information is optional. Please note, however, that you may be unable to access certain functionalities of our Platform, or to use the Platform effectively, if such information is incomplete or inaccurate. In addition, Clients may avoid interacting with you through the Platform to the extent that the data supplied by you does not provide sufficient credibility or clarity.
You may amend the information you provide at any time and add further information to your profile for as long as your profile remains active.
Your profile is, in principle, public. This means that it may be viewed by any Client or Visitor.
Data regarding your interaction with the Platform: your preferences regarding commercial communications, details relating to services requested through the Platform (for example, offers submitted or services performed), any other content and information posted, uploaded, transmitted or otherwise made available on the Platform and/or sent by you to other Clients, including service requests, reviews and comments, chat messages, videos, photographs and other materials, regardless of whether these are transmitted publicly or privately.
Data collected from other sources: legal or economic details relating to your business activity (for example, information obtained from public registers, such as data from the Trade Registry, for the purpose of verifying your status and information relating to your business).
Technical data generated by the Platform:
When you use the Platform, we receive information about the type of device you use to access the Platform, the device identifier, information relating to the mobile network used, the device operating system, your IP address, location inferred from the IP address, the web browser used and information relating to device settings (for example, date and time, preferred language, etc.). With your consent, your device may also transmit location data based on GPS or other tools used to identify your location. We use such location data only to optimise connections with Clients located in your vicinity, and GPS access permission may be withdrawn at any time from your device settings.

B. Why do we process your data?

The personal data of Professionals will be processed on the legal basis of entering into and performing a contract, namely the agreement governing the provision of services offered through the Platform, combined with the legal bases of consent and the Company's legitimate interest in ensuring the proper functioning of the Platform and in delivering the services it offers under the best possible conditions.

We will use the data for the following purposes:

Onboarding to the Platform and validation of your identity or of the entity you represent - in order for you to submit commercial offers relating to the services provided by the Professional or accept Client requests, it is necessary (i) to register on the Platform, (ii) to complete the validation steps in accordance with the conditions set out on the Platform, and (iii) to complete your Professional profile with information relevant to Clients.
Legal bases:
1. the conclusion and performance of the contract with you; and
2. our legitimate interest in confirming your eligibility as a Professional and in managing the activity carried out with Clients.
Use of the Platform - in order for us to provide and maintain a safe marketplace and a high level of transparency in relation to the services offered through the Platform, your Professional profile is essential both to us and to Clients.
The accuracy and truthfulness of the information in your profile help us maintain contact with you and connect you with Clients requesting Services in your area of interest. Please note that Clients' preferences and requests may be influenced by their own assessment of your profile, as well as by the associated reviews and recommendations, and the way in which you use the Platform is necessary for us to understand your experience in relation to the activity carried out through the Platform.
Legal bases:
1. performance of the contract concluded with you;
2. our legitimate interest: (i) to ensure the quality of the services provided through the Platform and efficient communication between Client and Professional, and (ii) to prevent abusive or improper use of the services and/or the Platform.
Use and payment of Services
With your consent, we use your payment details to enable you to purchase additional services within the Platform.
Legal basis: performance of the contract concluded with you.
Managing our relationship with you (Professional)
We process your personal data when you request support from us in connection with the use and/or operation of the Platform (for example, when you send us requests regarding the Platform's functionalities or malfunctions).
We may send you communications in order to keep you informed about the functioning of the Platform (for example, when we carry out maintenance operations or when we have updated the Platform). In addition, to ensure that you remain informed about the service you have chosen, we may send such communications through the Platform.
Legal basis: our legitimate interest in providing quality services suited to your needs.
Sending commercial communications
The Company processes the contact details you provide (i.e., e-mail address or telephone number) when you choose, through the Platform, to receive communications regarding the products and services offered.
Legal basis: your consent.
You may express your consent for the processing of data for this purpose by ticking the relevant box at the time your Professional account is created or, after account creation, in the notifications section associated with your account. To unsubscribe from such commercial communications, you may use the option available at the end of each e-mail containing commercial communications.
Protection of our rights and interests
We may process your personal data in order to protect ourselves against fraud and to defend our rights and interests in the context of potential or existing disputes or litigation in which we may be involved, regardless of their nature and of the authority before which they are conducted.
In this context, we may receive or disclose your personal data to third parties (for example, courts or public authorities), or it may be necessary to disclose your information in order to comply with our legal obligations to respond to requests from authorities.
We wish to assure you that we will disclose your personal data only where, following an internal assessment or consultation with our external advisers, we conclude that we are under a legal obligation to do so.
Legal bases:
1. a legal obligation, where disclosure is required by law;
2. a legitimate interest, where disclosure is based on a sound justification and there are no overriding fundamental rights of the data subjects;
3. in addition, we may disclose your personal data on the basis of our legitimate interest in properly handling disputes and litigation, and in defending our rights and interests in such proceedings.
Improvement of the services and the Platform
We analyse the Services and the Platform, as well as your interaction with and experience of them, because we aim to continuously improve our services and products. We also seek to understand and assess the Platform's performance so that we can develop and offer you new services and functionalities tailored to your needs. For the purposes set out above, we will, as a rule, process anonymous or aggregated data. By way of exception, we may also process data that could ultimately lead to your identification, if such processing is strictly necessary for the achievement of the purposes described above.
Legal basis: our legitimate interest in measuring the performance and functionality of the Platform and in understanding how we can develop/improve the Platform and our services.

IV. If you are a Visitor

We will process your personal data only to the extent that you choose to contact us using the contact details available on the website (for example, by e-mail or telephone). In such case, we may process the data you provide directly to us (such as your name, e-mail address, telephone number and the content of your message). The purpose of the processing is to handle the requests received, communicate with you and provide information upon request.

Legal basis: our legitimate interest in responding to the requests received and communicating with the persons who contact us.

V. How long do we process your data for?

As a matter of principle, the Company will process your personal data for as long as necessary to achieve the processing purposes mentioned above.

Client and Professional data are retained for as long as they maintain an active account on the Platform. If the Client or the Professional requests that we deactivate and delete the account, the data associated with that account will be deleted or anonymised, as applicable, without undue delay.

However, certain data may be retained even after account deletion, to the extent such retention is necessary for autonomous and legitimate purposes, such as maintaining the history of bookings and transactions carried out through the Platform, complying with legal accounting, tax and archiving obligations, handling complaints and disputes, preventing fraud, defending or exercising rights before authorities or courts, and preserving the integrity of the reviews and feedback system.

In such cases, the data will be retained only to the extent necessary for each distinct purpose and, where possible, will be limited, pseudonymised or anonymised.

In the case of reviews and feedback, their content may remain associated with the Platform history; however, the Company will assess, depending on the technical architecture and the specific necessity of the processing, whether the author's identifying elements may be removed, limited or replaced.

The actual retention periods, or the criteria used to determine them, differ depending on the nature of the data and the purpose pursued.

If you withdraw your consent to the processing of data for the purpose of receiving commercial communications, the Company will cease processing your personal data for that purpose, without affecting the processing carried out on the basis of the consent given by you prior to its withdrawal.

VI. Disclosure of personal data

In order to facilitate communication and collaboration between Clients and Professionals, the Company may disclose each party's contact details to the other through the Platform.

For the purposes of the processing activities mentioned above, the Company may disclose your data to third parties or entities that support us in carrying out our activity, or to central/local public authorities, in the following cases:

for the development, administration and maintenance of the Platform and the storage of the data collected through it;
for carrying out data analysis, testing and research, monitoring usage and activity trends, and personalising and improving the Platform;
for sending commercial communications, subject to the conditions and limits laid down by law, and other communications relating to the operation of the Platform;
to payment processors for the purpose of collecting the amounts relating to the subscriptions you have chosen;
in order to obtain advisory services from third parties in specific fields requiring their professional expertise, or where it is necessary to involve them in litigation or disputes relevant to us (e.g., external lawyers, auditors, experts);
in the event of a merger, acquisition, or other type of reorganisation or sale, we may provide your information to the relevant organisation;
where disclosure of personal data is required by law (to competent public authorities and institutions, provided we consider their request to be well-founded and lawful).

VII. Transfer of personal data

As a rule, the personal data collected by us through the Platform will not be transferred outside the European Economic Area (EEA).

If the Company transfers your personal data to a country outside the EEA, or to a country in respect of which the European Commission has not issued a decision confirming that adequate safeguards for the protection of personal data are in place, we will ensure that your data is adequately protected. As a rule, we will ensure that there is an appropriate data transfer agreement in place, in accordance with the standard contractual clauses approved by the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

If the transfer cannot be based on the standard contractual clauses, we will take the steps necessary to ensure that the transfer is based on another mechanism provided by law in order to safeguard your personal data, including, where applicable, requesting your consent for such transfer.

VIII. Keeping personal data secure

If you have chosen a password that enables you to access the Platform, you are responsible for keeping that password confidential. Please do not disclose your password to anyone.

Please note that the transmission of information over the internet is not completely secure. We will do our utmost to protect your information, but we cannot guarantee the security of your data transmitted to the Platform or when using our services. Any disclosure is made at your own risk. Once we have received your information, we will use strict procedures and security features in an attempt to prevent unauthorised access.

IX. Your rights

Under the conditions laid down by personal data protection legislation, as data subjects, you benefit from the following rights:

the right of access to data, namely the right to obtain confirmation from the Company as to whether personal data relating to you is being processed, as well as details regarding the processing activities, such as the manner in which the data is processed, the purpose of the processing, the recipients or categories of recipients of the data, etc.;
the right to rectification of inaccurate personal data, as well as the completion of incomplete data. The rectification/completion will be communicated to each recipient to whom the data was disclosed, unless this proves impossible or involves disproportionate effort. In addition, the Company allows Clients and/or Professionals to rectify/update their data at any time from the "My Account" section of the Platform, for as long as the account remains active;
the right to erasure of your processed personal data. Your personal data will be erased or anonymised without undue delay. This does not apply to personal data necessary for the fulfilment of our legal obligations and therefore subject to retention under the applicable legislation (e.g., handling an order placed), or for the protection of our legitimate interests. Your personal data will also be erased where such data is no longer necessary for the relevant purpose or where storage of such personal data is impossible due to other reasons established by law. The erasure of your personal data may be requested from the authorised person ("right to be forgotten") if any of the following circumstances applies:
1. the data is no longer necessary for the purposes for which it was collected or processed;
2. you withdraw your consent and there is no other legal basis for the processing;
3. you object to the processing under Article 21(1) GDPR and there are no overriding legitimate grounds, or you object to the processing under Article 21(2) GDPR;
4. the personal data has been unlawfully processed;
5. the personal data must be erased in order to comply with a legal obligation;
The Company has also implemented deletion functionalities for Clients and/or Professionals who voluntarily wish to close their Platform account.
the right to restriction of processing, to the extent that:
1. you contest the accuracy of the data, for a period enabling us to verify the accuracy of the data;
2. the processing is unlawful and you oppose the erasure of the personal data, requesting instead the restriction of its use;
3. the data is no longer necessary for processing, but you require it for the establishment, exercise or defence of legal claims; or
4. you have objected to processing (other than for direct marketing purposes), for the period during which it is verified whether the controller's legitimate rights override those of the data subject;
the right to data portability, namely (i) the right to receive personal data in a structured, commonly used and easily readable format, as well as (ii) the right to have such data transmitted by the Company to another controller, insofar as the legal conditions are met;
the right to object to processing activities, which may be exercised by submitting a request as indicated below:
1. at any time, on grounds relating to your particular situation, where data relating to you is processed on the basis of the Company's legitimate interest, except where we can demonstrate compelling legitimate grounds justifying the processing that override your interests, rights and freedoms, or where the purpose is the establishment, exercise or defence of legal claims;
2. at any time, free of charge and without any justification, where data relating to you is processed for direct marketing purposes;
the right not to be subject to an automated individual decision, namely the right not to be subject to a decision based solely on automated processing activities, including profiling, which produces legal effects concerning you or similarly significantly affects you;
the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) or with the competent courts, to the extent you consider it necessary.

If you wish to exercise any of the rights above, please contact us at office@appme.app or by telephone at +40 774 048 038. Requests to the ANSPDCP may also be submitted via its website at www.dataprotection.ro.

X. Changes to our policy

Any changes we may make in the future to this policy will be posted on this page. If the changes concern essential aspects of the services or the Platform, we may notify you of such changes by e-mail or by another appropriate means, such as when you next access the Platform.