TOGERE Privacy Policy

Version: 1.1.0
Effective date: [[S4]] June 14, 2026 June 14, 2026
Last update: [[S6]] July 14, 2026 July 14, 2026

Version control

1. Who we are

Togere is a social platform that allows people to share visual content, experiences, recommendations and links related to products, services, places or resources of interest.

The person responsible for the treatment is:

Digital Resource Association
CIF: G93670362

Website: https://www.togere.com

Privacy Email: rgpd@togere.com

2. Our privacy philosophy

Privacy is part of Togere's design.

Our philosophy is based on the following principles:

• Collect only the data necessary to provide the service.
• Do not sell personal data.
• Do not rent personal data.
• Do not create commercial profiles of users.
• Do not use the data for external behavioral studies.
• Do not share personal information with third parties for advertising purposes.
• Maintain transparency about the use of information.
• Allow the user to control their own data.
• Apply the privacy principle by design and by default.

Togere has been created to operate with the minimum amount of personal information possible.

3. Data we collect

We only collect the data strictly necessary for the operation of the platform.

Account details

We can store:

• Internal user identifier.
• Display name or alias.
• Email address.
• Optional profile image.
• Account settings and preferences.

User Generated Content

We can store:

• Covers and user-created visual content.
• Comments.
• Reactions.
• Links associated with covers.
• Information that the user decides to include in their profile.

Minimum technical data

To guarantee the security and correct functioning of the service we may register:

• Date and time of access.
• Session identifiers.
• Operating system.
• Application language.
• Device type.
• Approximate country of connection.
• Technical security records.

This data is used exclusively to operate and protect the platform.

4. Data we do not collect

Unless a specific functionality requires it and the user expressly authorizes it, Togere does not collect:

• Device contacts.
• Call history.
• External private messages.
• Financial information.
• Identity documents.
• Biometric data.
• Fingerprints.
• Facial recognition.
• Voice recordings.
• Health data.
• Information from other applications.
• Continuous real-time location.

5. Images and geolocation

Image privacy is a priority for Togere.

Metadata removal

Before storing or distributing an image, Togere may remove unnecessary technical metadata included in the original file, including:

• GPS coordinates.
• Device model.
• Device serial number.
• Original capture date.
• Technical information not necessary for the operation of the platform.

Location of the covers

The location of a cover is optional.

The user can:

• Do not add location.
• Add an approximate location.
• Add a specific location when the functionality is available.

The location will only be shown when the user voluntarily decides to associate it with a cover.

Togere does not automatically publish the location obtained from image metadata.

The application does not continuously track the user's location.

6. Purpose of the treatment

The data collected is used exclusively for:

• Create and manage accounts.
• Publish content.
• Show covers.
• Manage comments and interactions.
• Detect fraud or abuse.
• Maintain the security of the service.
• Resolve technical incidents.
• Comply with legal obligations.

We do not use the data to:

• Create commercial profiles.
• Sell personal information.
• Carry out external behavioral studies.
• Make automated decisions with legal effects on people.

7. Cache System

Togere uses an internal system called “Cache”.

Cache is a metric used exclusively to manage the visibility and distribution of content within the platform.

The system:

• Does not evaluate sensitive personal aspects.
• Does not determine economic solvency.
• Does not generate commercial profiles.
• Does not make automated decisions with legal effects.

Its sole purpose is the internal functioning of the platform.

8. External links

The covers may contain links to external websites.

When a user accesses a link:

• You will be informed that you are leaving Togere.
• The link may be automatically verified to check its availability and security.
• Togere does not control and is not responsible for the privacy policies of external sites.

We recommend reviewing the conditions and policies of each site visited.

9. Advertising

Togere may display advertising to finance the operation of the service.

Advertising will preferably be displayed using contextual information from the application and not by creating detailed personal profiles.

Togere does not sell personal data to advertisers.

To serve ads we use Google AdMob, operated by Google Ireland Limited in the European Economic Area. The SDK may process device or advertising identifiers, IP address, technical information, ad interactions, and diagnostics, subject to applicable privacy settings.

Where required by regulation, we seek consent through Google's User Messaging Platform before requesting personalized ads. The user can review their advertising privacy options from their account. If there is no consent for personalization, limited or non-personalized ads may be displayed depending on availability and Google rules.

More information in the Google Privacy Policy and in how Google processes advertising data.

10. Data sharing

We do not sell personal data.

We do not rent personal data.

We do not exchange personal data with third parties for commercial purposes.

We can only share information when:

• It is necessary to provide the service.
• There is a legal obligation.
• Is required by a competent authority.
• It is necessary to prevent fraudulent, abusive or illicit activities.

11. Service providers

We may use technology providers for functions such as:

• Accommodation.
• Security.
• Content distribution.
• Automatic moderation.
• Authentication.
• Basic technical analysis.
• Advertising and management of advertising consent.

These providers will act exclusively on our instructions and may not use the data for their own purposes.

12. Data retention

The data will be kept only for the time necessary to:

• Keep the account active.
• Provide the requested service.
• Comply with legal obligations.
• Resolve possible complaints or security incidents.

When the data is no longer necessary, it will be deleted or anonymized.

13. Security

We apply reasonable technical and organizational measures to protect information against:

• Unauthorized access.
• Improper modifications.
• Accidental losses.
• Unauthorized disclosures.

14. User rights

Users may request:

• Access to your data.
• Rectification of incorrect data.
• Data deletion.
• Limitation of treatment.
• Opposition to treatment.
• Portability when applicable.
• Withdrawal of consent.

Requests may be directed to: rgpd@togere.com

15. International users

Togere is available for users in different countries.

Where local law grants additional privacy rights, Togere will endeavor to respect them to the extent compatible with the operation of the service and applicable regulations.

16. Minors

Togere is not intended for children under the minimum age required by applicable legislation in each jurisdiction.

If we reasonably detect that an account violates this requirement, we may restrict, suspend or delete it.

17. Account deletion

The user may request the deletion of their account at any time from the application or by contacting rgpd@togere.com.

After elimination:

• Personal data will be deleted or anonymized when possible.
• Certain minimum records may be retained where there is a legal obligation or legitimate need for security.

18. Changes to this policy

We may update this Privacy Policy to adapt it to legal, technical or functional changes.

Relevant modifications will be communicated through the application or website.

Your continued use of Togere following the posting of changes will constitute acceptance of the updated version of this policy.

Document: Togere Privacy Policy
Version: 1.1.0
Owner: Digital Resource Association (CIF G93670362)
Privacy email: rgpd@togere.com
Website: https://www.togere.com