Discoverly

Privacy Policy

DISCOVERLY P.C. (DISCOVERLY I.K.E.)

Effective Date: October 19, 2026 Version: 2.5 Last Updated: October 19, 2026


1. Data Controller

The data controller responsible for the processing of your personal data is:

DISCOVERLY P.C. (in Greek: DISCOVERLY I.K.E.)

  • Full legal name: DISCOVERLY ΙΔΙΩΤΙΚΗ ΚΕΦΑΛΑΙΟΥΧΙΚΗ ΕΤΑΙΡΕΙΑ
  • General Commercial Registry (GEMI): 190845701000
  • Tax Identification Number (AFM): 803154309
  • Registered seat: Kariou 6, 113 63 Athens, Greece
  • Email: privacy@discoverly.gr
  • Website: https://discoverly.gr

For any question or concern regarding how we process your personal data, contact privacy@discoverly.gr.

Data Protection Officer: We have not appointed a Data Protection Officer. For any data protection matter, contact us at privacy@discoverly.gr.


2. Scope of This Policy

This Privacy Policy explains how DISCOVERLY P.C. ("Discoverly", "we", "us", or "our") collects, uses, stores, shares, and protects your personal data when you use the Discoverly platform, including our website at discoverly.gr, our mobile applications, the DiscoverPass membership, the partner and organizer areas, and the DiscoverPass for Business area (collectively, the "Service").

This Policy applies to everyone who uses the Service: visitors who browse without an account, registered members, employees who hold a sponsored membership seat, venue partners, experience organizers, and the people who manage a corporate account.

It has been drafted in accordance with Regulation (EU) 2016/679 (GDPR), Greek Law 4624/2019, Greek Law 3471/2006 on electronic communications, and other applicable data protection legislation.

This version replaces the version of October 16, 2026.


3. Categories of Personal Data We Collect

3.1 Account and Profile Data

  • Name and, where you provide one, display name
  • Email address
  • Password, stored only as a secure hash. We never store your password in readable form
  • Phone number (optional). If you add one, we confirm it by sending a one-time code by SMS (Section 5). A verified number is also used to make sure a free trial is used only once (Section 16)
  • Profile photograph (optional)
  • Preferred language
  • Date of birth and gender (optional, blank by default). We use them to personalise recommendations and, only if you have given marketing consent (Section 15), to send you personalised offers, for example around your birthday
  • Preferences and interests selected during onboarding

3.2 Social Login Data

If you register or sign in with Google, we receive your name, email address and profile picture from Google, according to the permissions you grant.

If you register or sign in with Apple, we receive your name and email address from Apple. If you choose Apple's Hide My Email option, we receive a private relay address created by Apple instead of your real email address, and Apple forwards the email we send to that address to you. Apple shares your name with us only the first time you sign in with Apple.

We do not receive or store your Google or Apple password, and we do not share your Discoverly activity with Google or Apple.

3.3 Membership, Deal and Experience Data

  • Your DiscoverPass tier, its source (for example a paid subscription, a gift or a corporate seat) and its period
  • If you buy a membership: your plan (monthly or yearly), subscription status, free-trial end, current period end, cancellation, the date of your first payment, and the identifiers Stripe assigns to you as a customer and to your subscription. See Section 16
  • If you buy a gift: the recipient's email address, your optional message, the gift code, amount and currency, its status and expiry, and who redeemed it and when. See Section 16
  • Deal claims: which deal, which venue, the day and time window reserved, the redemption code, its state (active, used, expired) and the counters we need in order to apply monthly limits, daily limits and cooldowns
  • Favourites and saved venues, deals and experiences
  • Interest in, and attendance at, experiences where you record it through the Service

3.4 Location Data

  • Your device's approximate location, used only with your permission and only when you ask for it, for example to see results near you, to sort or filter by distance, or to show your position on the map. Your coordinates are used on your device to calculate distances, sort and filter results and centre the map. They are not sent to our servers and we do not store them. We do not track your location in the background.
  • When the map is centred on your position, the map provider (Google Maps) loads the map for that area, as it does for any area you view.

3.5 Interaction and Behavioural Data

  • The preferences you select and the taste words you type into the welcome prompt or your profile, which are stored in your profile
  • The text of your searches, including dish and theme searches, which is used at the time of the search to return results. We keep it afterwards only as part of in-app activity, if you allow Personalisation, as described below
  • Your favourites and saved items, your reviews and ratings, the "helpful" votes you give to reviews, and your deal claims
  • In-app activity, only if you allow Personalisation, described below

In-app activity. If you allow Personalisation in Cookie settings on the website or in Profile > Privacy settings in the app, we record what you do on the website and in the app: the venues, deals and lists you see and open, what you search for (with email addresses and phone numbers removed), what you save, share and book, how far you are from a venue as a rough band (under 1 km, 1 to 3 km, 3 to 10 km or over 10 km, never your exact position), and your device type and app version. It also includes the steps of joining DiscoverPass or buying a gift (the plan you chose, its price, and whether the payment page was completed or cancelled) and changes to your membership that our payment provider reports to us, such as a trial starting or ending, a renewal, a cancellation or a failed payment. It never includes card or other payment details. We use it to personalise recommendations, to train and evaluate our recommendation model, and to understand how the website and app are used so that we can improve them. It is stored by us, in our own database in the European Union, linked to a random device identifier and, when you are signed in, to your account. We do not store your IP address or your location with it, and we do not share it with Google or any advertiser. We keep it for up to 25 months and then delete it, keeping only monthly counts that identify no one. The text of your searches goes sooner: once the month of a search is more than 90 days in the past, we delete the text and keep only how often each term was searched that month, and only for terms searched from at least five devices. Without Personalisation consent no in-app activity is recorded; only your consent choice itself is recorded. You can withdraw at any time in Cookie settings on the website or in Profile > Privacy settings in the app. Withdrawing consent stops collection. If you withdraw while signed in, we delete the activity linked to your account on all your devices; if you withdraw while signed out, we delete the activity of that device. If you never allowed Personalisation, there is nothing to delete. Deleting your account deletes this data too.

Statistics. Separately, if you allow Statistics, the website uses Google Analytics 4 to count visits and pages (Section 3.8). The mobile application uses no third-party analytics; usage in the app is measured only through our own in-app activity records above.

3.6 Social and Community Data

Posts, comments, reviews and ratings you create, and connections with other users, where those features are available to you.

3.7 Technical and Device Data

  • Device type and model, operating system and version, browser type and version
  • IP address, and unique device or installation identifiers
  • Error and crash reports and stack traces from the website and the mobile application, described in Section 3.7.1
  • If you use the partner app and allow notifications: a push token for your device, described in Section 3.7.2

3.7.1 Error Monitoring

We use Sentry (Functional Software, Inc.) to find and fix faults on the website and in the mobile application. When an error or a crash happens, Sentry receives the error message and stack trace, your device, browser and operating system information, the page or screen where the error happened, and a pseudonymous account identifier tied to your account, but never your name, email address or phone number.

Before an error report leaves our servers or your browser, we remove email addresses and phone numbers from the error message and its context. Sentry receives error and crash diagnostics only: neither the website nor the mobile application uses session replay or performance tracing. We do not store your IP address as part of this processing.

Error reports for the website and the mobile application are processed in Sentry's EU data region (Germany), and this processing does not involve a transfer outside the EU or EEA. Sentry acts as our processor under a data processing agreement. The legal basis for this processing is our legitimate interest, Art. 6(1)(f) GDPR, in finding and fixing faults. Error reports are retained according to our Sentry account settings, within the diagnostic-log retention period in Section 8.

3.7.2 Partner App Notifications

If you use the Discoverly partner app, for venue owners and managers, and allow notifications on your device, we store a push token for that device. A push token is an identifier, issued through Expo, that lets us send notifications to that device. We store it linked to your account, together with the app it belongs to (the partner app), the platform (iOS or Android), your app language, and when it was registered and last seen. The member app does not register push tokens today.

We use the token to send you service notifications about your venue: a new booking, a redeemed code and a new review. A notification shows the guest's first name, the time and the deal title. These notifications are part of the partner service and are not promotional. The legal basis is the performance of our contract with you, Art. 6(1)(b) GDPR. They are separate from the promotional push notifications in Section 15, which need your consent. You can switch off each type (bookings, redemptions, reviews) in the app's notification settings, and all notifications in your device settings.

To deliver a notification, we send the token and the notification text to Expo (650 Industries, Inc., United States), which passes it to Apple Push Notification service (APNs, Apple Inc.) for iPhone or to Firebase Cloud Messaging (FCM, Google) for Android, which deliver it to your device. See Sections 5 and 7.

We delete a token when you sign out of the partner app on that device, when Expo reports that it is no longer valid, for example because the app was removed, and when you delete your account. We keep at most 20 tokens per account for the app and delete the oldest beyond that. Notifications pass through a delivery queue that holds only identifiers, the notification type and the delivery status, never the notification text, and its entries are deleted after 30 days.

3.8 Cookie and Analytics Data

  • Strictly necessary cookies and browser storage required for the Service to work
  • Google Analytics 4 measurement data on the website, only with your Statistics consent: page views by page type, sign-ups, bookings by venue category, interest in the membership, and the start of a membership checkout, a purchase or a free trial with the plan and its price (never payment details). Google receives a random analytics identifier stored in a cookie, never your name, email address, account identifier or what you search for. Google signals and advertising personalisation are switched off

See our Cookie Policy for the full list.

3.9 Partner and Organizer Data

If you list a venue or run experiences, we also process:

  • The account and contact details of the person managing the listing, and their role
  • Listing content: descriptions, photographs, menus, opening hours, deals, experience schedules and capacity
  • Company verification data: legal and trade name, legal form, Greek VAT number (AFM) and tax office, business registry (GEMI) number and status, registered seat, activity codes, legal representatives with their contact details, billing email and address, and optionally an IBAN for future payouts. For non-Greek companies, the country, national registration number and VAT or EORI number
  • The raw response and the date of the lookup we make against the Greek business registry, so that what the registry stated on the day of signing can be evidenced
  • Documents you upload for verification, such as a business licence, utility bill or tax registration, held in private storage
  • Venue verification data: the telephone number the mapping provider holds for the venue, the one-time code we send to it, the time and outcome of each verification attempt, and, for the voice path, the fact that an automated call was placed
  • The record of acceptance of the Partner Terms or Organizer Terms, including version, language, date, the signer's role and the company's legal name at the time of signing
  • The activity log: which partner account (account identifier, email address and role) made which change to a venue or experience, and when. Changes our support staff make to a venue are logged too

3.10 Corporate Membership Data

If your employer or another organisation sponsors your membership:

  • The work email address the organisation provides to us, or the fact that you opened a single-use claim link
  • Your seat status, the date it was claimed, and the date it was revoked or expired
  • Aggregated usage counts derived from your activity, as described in Section 6

If you manage a corporate account, we process your name, work email, role in that account, and your actions in the business area, such as invitations sent and seats revoked.

3.11 Support and Communications

Messages you send us, the email address or phone number you send them from, and our replies.


4. Purposes and Legal Basis for Processing

PurposeData usedLegal basis
Create and manage your account, authenticate you, and keep you signed inAccount, social login, technical dataContract, Art. 6(1)(b)
Provide the core Service: discovery, search, favourites, listingsAccount, interaction dataContract, Art. 6(1)(b)
Operate DiscoverPass: check eligibility, issue and validate redemption codes, apply monthly limits, daily limits, capacity and cooldownsMembership, claim and venue dataContract, Art. 6(1)(b)
Sell and manage paid DiscoverPass memberships and free trials, and take payments through StripeAccount email and identifier, Stripe customer and subscription identifiers, subscription status and periodContract, Art. 6(1)(b)
Make sure a free trial is used only onceKeyed hash of your verified phone number and of the card fingerprint Stripe providesLegitimate interest, Art. 6(1)(f), in preventing trial abuse
Sell, deliver and redeem gift memberships, including sending the gift email to the recipientPurchaser account, recipient email address, optional message, gift code, payment dataContract, Art. 6(1)(b), with the purchaser; legitimate interest, Art. 6(1)(f), of the purchaser and the recipient in the gift reaching the recipient
Verify your phone number, where you choose to add onePhone number, verification attemptsContract, Art. 6(1)(b); legitimate interest, Art. 6(1)(f), in preventing abuse
Operate sponsored corporate seats: match an invitation or claim link to your account, apply the one-seat rule, end a seat on revocation or expiryCorporate membership dataContract, Art. 6(1)(b); legitimate interest in preventing seat abuse, Art. 6(1)(f)
Provide aggregated usage statistics to a sponsoring organisation, never below five active employees and never showing individual visitsAggregated counts derived from claim dataLegitimate interest, Art. 6(1)(f), of the sponsoring organisation and of Discoverly in demonstrating the value of a seat, balanced by suppression and aggregation
Personalise recommendations and search results, including dish and theme searchPreferences, taste words, favourites, reviews and claims, in-app activity (Section 3.5) where you allow it, location on your device where granted, and optional date of birth and genderConsent, Art. 6(1)(a), for in-app activity, for optional date of birth and gender and for location; legitimate interest, Art. 6(1)(f), for personalisation from your profile preferences, favourites, reviews and claims
Train and evaluate our recommendation model, and understand how the website and app are used so that we can improve themIn-app activity (Section 3.5)Consent, Art. 6(1)(a)
Show results near you and display mapsLocation, used on your device only; IP address for map displayConsent, Art. 6(1)(a), for device location; contract for map display of a place you opened
Verify that a venue or experience genuinely belongs to the person listing it, and verify the company behind a partner accountPartner and organizer data, verification codes, registry lookups, uploaded documentsContract, Art. 6(1)(b); legal obligation, Art. 6(1)(c); legitimate interest, Art. 6(1)(f), in protecting members from fraudulent listings
Keep an activity log of the changes partner accounts make, for security, accountability and support (Section 3.9)Account identifier, email address and role of the partner account, the change and its timeLegitimate interest, Art. 6(1)(f), in keeping partner accounts secure, knowing who changed what, and resolving support requests
Send service messages: confirmations, verification codes, booking and redemption messages, membership, payment and gift messages, security and terms noticesName, email, phone, claim, membership and gift dataContract, Art. 6(1)(b)
Send partner app notifications about a venue's new bookings, redeemed codes and new reviews (Section 3.7.2)Push token, platform and app language of the partner's device; the guest's first name, the time and the deal titleContract, Art. 6(1)(b)
Send promotional messages about venues, deals and experiences by email, SMS or push notification, including personalised offers such as offers around your birthday (Section 15)Name, email, phone, preferences, and date of birth where you provided itConsent, Art. 6(1)(a), given separately and never pre-ticked. We do not send such messages today
Review listings and content, by automated checks and by our staff, for accuracy and policy complianceListing content, partner dataLegitimate interest, Art. 6(1)(f); legal obligation, Art. 6(1)(c), where applicable under Regulation (EU) 2022/2065
Measure how the website is usedGoogle Analytics 4 data (Section 3.8)Consent, Art. 6(1)(a)
Find and fix faults on the website and in the mobile applicationError and crash reports, device dataLegitimate interest, Art. 6(1)(f)
Keep the Service secure, prevent fraud and abuse, and investigate incidentsTechnical data, IP addresses, logs, claim patternsLegitimate interest, Art. 6(1)(f); legal obligation, Art. 6(1)(c)
Maintain backups and restore the Service after a failureAll stored data, in encrypted formLegitimate interest, Art. 6(1)(f); legal obligation, Art. 6(1)(c), for the security of processing under Art. 32
Meet accounting, tax and other legal obligations, including keeping payment and invoice records, and establish, exercise or defend legal claimsAccount, partner, payment and transaction dataLegal obligation, Art. 6(1)(c); legitimate interest, Art. 6(1)(f)

Where we rely on legitimate interests, we have carried out a balancing assessment and you may obtain a summary of it by writing to privacy@discoverly.gr. You may object to processing based on legitimate interests at any time (Section 9.6).


5. Processors and Recipients

We do not sell your personal data. We use the following service providers, each of which acts as a processor on our instructions under a data processing agreement, unless stated otherwise.

ProviderRoleWhere the data is processed
SupabaseApplication hosting, PostgreSQL database, authentication, server-side functions and private file storage for the ServiceEuropean Union (Ireland)
HetznerApplication hosting for the previous API at api.discoverly.gr, which still serves a test version of the previous mobile app (not publicly released) until the new mobile app replaces it. Redis (caching) and Elasticsearch (search) run on the same server, for that API only. This hosting will be retired once the new mobile app replaces the old oneGermany
Lovable, on CloudflareHosting of the website at discoverly.grGlobal infrastructure; see Section 7
Amazon Web Services (AWS)Object storage in Amazon S3 for photographs, menus and uploaded verification documents. Review photos, profile photos and verification documents are kept private and delivered only through time-limited signed links, including where they are shown to other users. Public venue photographs and stock images are delivered through ImageKit (see below). Storage of encrypted database backupsEuropean Union (Frankfurt, eu-central-1) for media; European Union for backups
ImageKit (ImageKit Inc., United States)Image optimisation and delivery network for public venue photographs and stock images. It fetches the image from our Amazon S3 storage, resizes and caches it, and delivers it to your device, which involves receiving your IP address and browser details. It does not handle review photos, profile photos or verification documentsProcessing region Germany (Frankfurt), with delivery from a global network of edge locations and possible access from India and the United States; see Section 7
MuxHosting and playback of partner-uploaded venue videosGlobal infrastructure (United States); see Section 7
Bird (MessageBird)Delivery of transactional and account email, including verification, redemption, security, membership, payment and gift messages, and the gift email to a gift's recipient. Open tracking and click tracking are switched off for account emailEuropean Union, with possible support access from outside the EEA under the safeguards in Section 7
TwilioDelivery of one-time verification codes by SMS through Twilio Verify to a member's phone number, when a member chooses to verify it, and to a venue's telephone number by SMS and by automated voice callUnited States (Twilio Verify), under Standard Contractual Clauses
Expo (650 Industries, Inc., United States)Delivery of partner app push notifications (Section 3.7.2). Expo receives the device's push token and the notification text (the guest's first name, the time and the deal title) and passes them to Apple Push Notification service or Firebase Cloud MessagingUnited States, under Standard Contractual Clauses; see Section 7
Apple (Push Notification service, APNs)Delivery of partner app notifications to iPhonesGlobal infrastructure; see Section 7
Google (Firebase Cloud Messaging, FCM)Delivery of partner app notifications to Android devicesGlobal infrastructure; see Section 7
Google (Maps Platform and Places)Map display, place search, place details and place photographs used to build venue listingsGlobal infrastructure; see Section 7
Google (Sign-In)Authentication when you choose to sign in with GoogleGlobal infrastructure; see Section 7
Apple (Sign in with Apple)Authentication when you choose to sign in with Apple and, where you use Hide My Email, forwarding of our email to your real address through Apple's private relayGlobal infrastructure; see Section 7
Google (Analytics 4)Website usage statistics, only with your Statistics consent. Google acts as our processor; Google signals and advertising personalisation are off and no account identifier is sent. Not used in the mobile applicationGlobal infrastructure; see Section 7
AI gateway (Lovable), with Google Gemini embedding modelsConverting dish, venue and experience text and your search text into numerical representations so that semantic search works and so that we can personalise suggestions from your profile preferences, and, where enabled, assisting with listing drafts, translations and automated listing reviewProcessed by the gateway provider and the underlying model provider; see Section 7
Google Gemini, OpenAI and TypeSafe (Jev)Automated moderation of review text and photos and of venue description edits, and generation of review topicsGlobal infrastructure; see Section 7
SentryError and crash monitoring for the website and the mobile application, described in Section 3.7.1. No session replay and no performance tracingSentry's EU data region (Germany)
Stripe (Stripe Payments Europe, Limited)Payments for DiscoverPass memberships and gifts through Stripe Checkout, a payment page hosted by Stripe. Your card details are entered on Stripe's page and never reach our servers. Stripe acts as our processor for the payments it processes on our instructions, and as an independent controller for its own purposes, such as fraud prevention and its legal and regulatory obligations. See Section 16European Union (Ireland), with transfers to Stripe, Inc. in the United States; see Section 7
Greek business registry (GEMI) and public tax registry servicesLookup of a partner company's VAT number and registry details during company verificationGreece. These are independent public bodies and are not our processors

We may also disclose personal data to:

  • Partners and Organizers, limited to what they need in order to honour a claim or run an experience. A venue sees your first name, that a redemption code is valid, the deal it relates to and the time window, and marks it used. The venue's owners and managers may also receive this in a notification in the partner app (Section 3.7.2). A venue is not given your full identity, your contact details or your history at other venues
  • Other users, for information you choose to make public, such as your display name, profile photo, posts and reviews
  • Sponsoring organisations, only in the aggregated form described in Section 6
  • Professional advisers, auditors and insurers, under a duty of confidentiality
  • Law enforcement, courts, regulators and other public authorities, where required by law or to protect our legal rights
  • An acquirer, in the event of a merger, acquisition, reorganisation or sale of assets, in which case we will notify you

6. Corporate Sponsored Memberships

If an employer or other organisation sponsors your DiscoverPass membership, the following applies.

What the organisation gives us. The organisation provides the work email addresses of the people it wishes to sponsor, or generates single-use claim links to hand out. The organisation is the controller of the employee list it holds, and it warrants to us in the DiscoverPass for Business Terms that it is entitled to share those addresses with us. We are the controller of the member account that results.

Your account stays yours. A sponsored seat upgrades the account you already have or the account you create. Your favourites, claims and history belong to you and are not transferred to the organisation. You may hold at most one sponsored seat at a time.

What the organisation can see. The organisation sees how many seats it holds, how many are used and how many are free, whether an invitation is outstanding, and aggregated usage statistics for its sponsored population.

What the organisation can never see. It cannot see which venues you visited, which deals you claimed, when you claimed them, what you searched for, your location, or any other individual activity. Any aggregated breakdown is suppressed entirely where fewer than five active sponsored employees are covered by it, so that a figure cannot be traced back to one person. The organisation is contractually prohibited from attempting to re-identify anyone from these statistics and from using them to make decisions about an individual.

When a seat ends. When the organisation revokes your seat, its account is suspended, or its period ends, your membership returns to the free tier and your history remains with you. We keep a record that the seat existed, when it was claimed and when it ended, for the contractual and accounting purposes in Section 8.


7. International Data Transfers

Our primary processing takes place in the European Union. The database, authentication and application run in Ireland; media, documents and backups are stored in the European Union, though cached copies of public venue photographs are served from a global delivery network; error reports for the website and the mobile application are processed in Sentry's German EU region, and this processing does not involve a transfer outside the EU or EEA. The previous API at api.discoverly.gr, which still serves a test version of the previous mobile app, together with Redis and Elasticsearch for that API only, continues to run on a Hetzner server in Germany until the new mobile app replaces the old one, at which point this hosting will be retired.

Some providers may process limited personal data outside the EU or EEA, or may access it from outside the EEA for support purposes. This may apply to Lovable and Cloudflare (website hosting), Mux (partner video hosting), ImageKit (image delivery), Expo (partner app notifications), Google (Maps, Places, Sign-In, Analytics and Firebase Cloud Messaging), Apple (Sign in with Apple and Push Notification service), the AI gateway and the underlying model provider, the direct AI moderation providers (Google Gemini, OpenAI and TypeSafe), and to support access by Bird and Twilio.

Where such transfers occur, we rely on:

  • Standard Contractual Clauses approved by the European Commission under Article 46(2)(c) GDPR, together with supplementary technical and organisational measures where the transfer risk assessment requires them;
  • Adequacy decisions under Article 45 GDPR, including the EU-U.S. Data Privacy Framework for certified recipients in the United States.

For ImageKit, access from India is covered by Standard Contractual Clauses, as India has no adequacy decision.

For Expo, which relays partner app notifications from the United States, we rely on Standard Contractual Clauses.

Payments are handled by Stripe Payments Europe, Limited in Ireland. Stripe may transfer payment data to Stripe, Inc. in the United States, based on an adequacy decision or Standard Contractual Clauses.

You may request a copy of the relevant safeguards by writing to privacy@discoverly.gr.


8. Data Retention

Data categoryRetention
Account and profile dataFor the life of your account. Deleted or irreversibly anonymised within 30 days of a deletion request, unless the law requires retention
Profile photosUntil you replace or remove them. A replaced photo is deleted within one hour
Password hashFor the life of your account
Social login connectionUntil you disconnect it or delete your account
Membership and seat recordsFor the life of your account, and thereafter for as long as needed for accounting and legal claims
Payment, invoice and receipt recordsAs required by Greek tax law, currently up to 10 years. Invoices and receipts are held in our Stripe account
Gift purchases, including the recipient's email address and messageUntil the gift is redeemed or expires (one year after purchase), and then for as long as the payment records above must be kept
Free-trial records (keyed hashes of phone number and card fingerprint)For as long as we offer free trials, so that a trial is used only once. The link to your account is removed when you delete it
Claims and redemption codesFor the life of your account. Expired and used codes are kept while your account exists so that limits and cooldowns can be applied, then deleted or anonymised with the account. Aggregated counts may be retained in anonymised form
Favourites and saved itemsFor the life of your account
Location coordinatesNot sent to our servers and not stored. Used on your device only
Server, edge-function and access logsUp to 90 days, then deleted
Posts, comments and reviewsFor the life of your account. Public content may remain visible in anonymised form after deletion
Technical and device data, IP addressesUp to 12 months, then anonymised or deleted
Sentry error and crash reports and diagnosticsAs configured in our Sentry account, not exceeding 90 days
Partner app push tokens (Section 3.7.2)Until you sign out of the partner app on that device, Expo reports the token as no longer valid, or you delete your account. At most 20 tokens per account for the app; the oldest beyond that are deleted
Partner notification settingsFor the life of your account
Partner notification delivery queue (identifiers, notification type and delivery status, never the notification text)30 days, then deleted
Partner activity log (Section 3.9)24 months, then deleted. This also applies after the partner account is deleted
Google Analytics dataUp to 14 months
In-app activity (Section 3.5) and the record of your consent choicesUp to 25 months, then deleted. Search text is deleted once the month of the search is more than 90 days in the past. Monthly counts that identify no one may be kept. In-app activity is deleted when you withdraw Personalisation or delete your account
Public venue photographsWhile the listing uses them. On deletion they are removed from storage and purged from the delivery network's cache
Partner and organizer company data, registry responses and verification documentsFor the duration of the relationship and 5 years afterwards, as required by Greek commercial and tax law
Venue verification codes and attemptsCodes expire after 10 minutes. Attempt records are kept for up to 12 months for abuse prevention
Member phone verification codes and attemptsCodes expire after 10 minutes. The record of each attempt (number, time and outcome) is kept for the life of your account, for abuse prevention, and deleted with it
Partner Terms and Organizer Terms acceptance recordsFor the duration of the relationship and 5 years afterwards, as evidence of the agreement
Records of marketing consent and its withdrawalFor as long as the consent is active and up to 5 years after you withdraw it, as proof of consent
Support correspondenceUp to 24 months after the matter is closed
Encrypted database backupsNightly backups are retained for 30 days. Monthly backups are retained for 400 days. Data you have deleted persists in these backups until they expire on their normal rotation, after which it is destroyed. Backups are used only to restore the Service
Legal compliance and accounting recordsAs required by law, typically 5 to 10 years under Greek tax and commercial legislation

After the applicable period, personal data is securely deleted or irreversibly anonymised.


9. Your Rights

Under the GDPR and Greek Law 4624/2019 you have the following rights.

9.1 Right of Access (Art. 15)

To confirm whether we process your personal data and to receive a copy of it together with information about the processing.

9.2 Right to Rectification (Art. 16)

To have inaccurate data corrected and incomplete data completed. Most profile data can be corrected directly in the Service.

9.3 Right to Erasure (Art. 17)

To have your personal data deleted where it is no longer necessary, where you withdraw consent and no other basis applies, or where it has been processed unlawfully. You may delete your account in the Service where that feature is available. Deletion does not extend to data we must keep by law, and data in encrypted backups is removed when those backups expire (Section 8).

9.4 Right to Restriction (Art. 18)

To have processing restricted while an issue about accuracy, lawfulness or an objection is resolved.

9.5 Right to Data Portability (Art. 20)

To receive the personal data you provided to us, and data generated by your use of the Service, in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible. You may request an export in the Service where that feature is available, or by email.

9.6 Right to Object (Art. 21)

To object at any time to processing based on legitimate interests, including personalisation and profiling. We will stop unless we demonstrate compelling legitimate grounds that override your interests, or the processing is needed for legal claims. You may object to direct marketing at any time, and we will stop without exception.

9.7 Right to Withdraw Consent (Art. 7(3))

To withdraw consent at any time, for location, for optional profile fields, for Statistics (analytics cookies), for Personalisation (in-app activity) and for promotional messages. Withdrawing Personalisation stops collection and deletes the activity already recorded: on all your devices if you are signed in, or on that device if you are not. For promotional messages you can do this for each channel separately in Profile, under Communication choices, and through the link in every promotional message (Section 15). Withdrawal does not affect the lawfulness of processing before it.

9.8 Automated Decision-Making (Art. 22)

Not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects you. See Section 10.

How to exercise your rights

  • Email: privacy@discoverly.gr
  • In the Service: through account settings, where the relevant feature is available

We may ask for information to confirm your identity, and we will use it only for that purpose. We respond within one month of receipt under Article 12(3) GDPR. That period may be extended by two further months where the request is complex, in which case we will tell you within the first month and explain why. Exercising your rights is free, unless a request is manifestly unfounded or excessive.

If you are not satisfied, you may complain to a supervisory authority (Section 12).


10. Automated Decision-Making and Profiling

Personalisation. We analyse your stated preferences, your activity in the Service and, where you allow it, your location, to order and select the venues, deals and experiences we show you. Search by dish and by theme works by converting text into numerical representations through an AI gateway and comparing them. This is profiling under Article 4(4) GDPR. It affects only what is shown first. It never restricts your access to any public listing and it never determines whether you may claim a deal. You may object at any time under Section 9.6, after which you will see non-personalised content. Recommendations only change the order of results and have no legal or similarly significant effect, so Article 22 GDPR does not apply to them.

Eligibility checks. Whether you can claim a deal is decided by fixed rules that you can read in advance: your tier, your claims that month, your claims at that venue that day, the cooldown, and the remaining capacity. The outcome is always explained by naming the rule that applied. These are rule-based checks rather than profiling, they have no legal effect, and you can ask a person to review any outcome you believe is wrong.

Listing review. Listings submitted by partners and organizers may be checked automatically for accuracy, completeness and policy compliance, and are also reviewed by our staff. A partner or organizer affected by an automated outcome may request review by a person.

We do not carry out fully automated decision-making producing legal effects or similarly significant effects on you.


11. Children's Data

The Service is not directed at children. Under Article 8 GDPR and Greek Law 4624/2019, the age of consent for information society services in Greece is fifteen (15) years.

We do not knowingly collect personal data from children under 15. If you are under 15, you may not create an account without the consent of your parent or guardian. If we learn that we hold data of a child under 15 without appropriate consent, we will delete it as soon as reasonably possible. Contact privacy@discoverly.gr if you believe this has happened.


12. Complaints

You may lodge a complaint with the Hellenic Data Protection Authority:

You may also complain to the supervisory authority of the EU or EEA state of your habitual residence, place of work, or place of the alleged infringement, and you have a right to an effective judicial remedy.


13. Security

We apply appropriate technical and organisational measures under Article 32 GDPR, including:

  • Encryption in transit (TLS) and encryption at rest
  • Row-level authorisation rules in the database, so that a request can only reach data the signed-in account is entitled to
  • Private storage for review photos, profile photos and verification documents, reachable only through time-limited signed links
  • Public venue photographs and stock images published at randomly generated addresses through an image delivery network, cached for up to one year and purged from the cache when the image is deleted
  • Encrypted, access-controlled backups
  • Access controls, least privilege and authentication for staff
  • Logging and monitoring, and review of security-relevant events
  • Security assessments and dependency review
  • Staff training on data protection and information security
  • Contracts with every processor, and assessment of each before it is introduced

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Hellenic Data Protection Authority within 72 hours under Article 33 GDPR and, where the risk is high, notify you under Article 34.


14. Cookies and Similar Technologies

Our consent banner offers three categories: Strictly necessary, Statistics and Personalisation. We use strictly necessary cookies and browser storage for sign-in, language and recording your consent choice. Statistics covers Google Analytics 4 on the website; Personalisation covers our own in-app activity records (Section 3.5). We do not use marketing or advertising cookies; whether we may send you offers by email, SMS or push notification is a separate choice in Profile, under Communication choices (Section 15). We ask again every 12 months. Your choice is also recorded on our servers, with a random device identifier and, when you are signed in, your account, as proof of consent. Full details, and the way to change or withdraw your choice at any time, are in our Cookie Policy.


15. Marketing Communications

We do not send promotional messages yet. When we start, we will send promotional messages about venues, deals and experiences, by email, SMS or push notification, only to members who have given separate, specific, opt-in consent to receive them. You choose each channel separately: you can tick the box when you sign up, which turns on offers by email, answer a question we show you once in the Service, or change your choices at any time in Profile, under Communication choices. Offers by SMS start only after you verify your mobile number, including when you asked for offers at sign-up or in the one-time question, and push notifications are set in the mobile app, which also asks for your device's permission. That consent is never pre-ticked and is never a condition of using the Service or holding a membership. Offers may be personalised to your preferences, and may include offers around your birthday if you have given us your date of birth.

You can withdraw your consent at any time, for each channel separately, in Profile, under Communication choices, and with the one-click unsubscribe link in every promotional email, without signing in. A withdrawal applies to new messages straight away. Withdrawing offers by email also cancels a request for offers by SMS that is still waiting for your mobile number to be verified, and if you change or remove your mobile number, offers by SMS stop until you turn them on again. We keep a record of each consent and each withdrawal: the channel, the date and time, where it was given or withdrawn (sign-up, profile, the one-time question, the unsubscribe link or our support team) and the version of this Policy that applied, so that we can show we had your consent (Section 8).

Service messages, such as verification codes, booking and redemption confirmations, account and security alerts, membership, payment and gift messages, partner app notifications about bookings, redemptions and reviews, and changes to our terms, are not promotional. We send them on the basis of our contract with you, Art. 6(1)(b), for as long as you hold an account, whether or not you have given marketing consent. We do not use open tracking or click tracking in account email.


16. Payments

DiscoverPass memberships are paid subscriptions, monthly or yearly, which may start with a free trial. You can also buy a DiscoverPass membership as a gift for someone else. Payments are taken through Stripe Checkout, a payment page hosted by Stripe (Stripe Payments Europe, Limited, Ireland). You enter your card or other payment details directly on Stripe's page. They never reach our servers, and we never see or store your full card number.

What we store. The identifiers Stripe assigns to you as a customer and to your subscription; your plan, subscription status, free-trial end, current period end, cancellation and the date of your first payment; and, for gifts, the gift purchase records described below. Invoices and receipts are issued and held in our Stripe account.

What Stripe receives. Your email address and your Discoverly account identifier, so that payments can be linked to your account, together with the payment details you enter on Stripe's page and, where needed to calculate tax, your billing address.

Free trials. So that a free trial is used only once, we keep a keyed hash of your verified phone number and of the card fingerprint Stripe gives us. A keyed hash cannot be turned back into the number without a secret key held only in our database.

Gifts. When you buy a gift, you give us the recipient's email address and, if you wish, a personal message. We use them to deliver the gift: we send the recipient an email with the gift and your message, and we send you a confirmation. The recipient redeems the gift with its code in their own account. The legal basis is the performance of our contract with you, Art. 6(1)(b), and the legitimate interest, Art. 6(1)(f), of you and of the recipient in the gift reaching the recipient.

Stripe's role. Stripe acts as our processor when it processes payments on our instructions, and as an independent controller for its own purposes, such as fraud prevention and meeting its financial and regulatory obligations, under the Stripe Privacy Policy (https://stripe.com/privacy).

Legal basis. Contract, Art. 6(1)(b), to sell and manage your membership or gift; legal obligation, Art. 6(1)(c), to keep payment, invoice and tax records under Greek tax law; legitimate interest, Art. 6(1)(f), in preventing fraud and trial abuse. Retention periods are in Section 8.


17. Changes to This Policy

We may update this Policy to reflect changes in our processing, the law or our business. When we make material changes we will update the Effective Date and version above, notify you in the Service or by email, and, where the change requires it, ask for your consent again.


18. Contact Us

DISCOVERLY P.C. (DISCOVERLY I.K.E.)