Privacy Policy

CueWorker, Inc., 1301 N Broadway STE 32998, Los Angeles, CA 90012, United States, is responsible for your personal information. It is the “controller” under the EU and UK General Data Protection Regulation (GDPR) and the “business” under California privacy law.

Hedell Group Inc., 8-17-5 Ginza, Chuo-ku, Tokyo, Japan, operates LocaRide in Japan and provides, and processes payment for, all Sessions in Japan. It receives the information described in Section 5.2 to provide your bookings and handles that information for those purposes in accordance with this Policy and applicable Japanese law, including the Act on the Protection of Personal Information.

Questions about this Policy: privacy@loca-ride.com

2.1 Information you give us

• Account information: your name, email address, password (stored in hashed form), country of residence and preferred language.
• Profile information: profile photo, self-introduction, languages you speak, and other details you choose to add, such as your nationality or gender.
• Sign-in with third parties: if you sign in with Google, Facebook or Apple, we receive your name, email address and profile picture from that service, as permitted by your settings there.
• Booking information: Session requests, dates, meeting places, number of participants, the experiences you choose and, for experiences involving alcohol, your confirmation that you are 20 or older.
• Communications: messages you exchange with other users (and their translations), reports you submit, and messages you send to our support team.
• Ratings and reviews you give and receive.
• Identity verification: if you apply to become a Local, your identity is verified through Stripe’s identity verification service, which may collect images of your identity document and of your face. We receive the verification result.
• Payment information: card payments are processed by Stripe. Neither we nor Hedell Group Inc. store your full card number. We receive limited information about your transactions, such as the amount and payment status.

2.2 Information collected automatically

• Usage and device information: pages and screens viewed, actions taken, access dates and times, IP address, device and browser type, operating system and app version.
• Approximate location: the country inferred from your IP address, which we use to suggest your country of residence and to show the version of our documents that likely applies to you.
• Cookies and similar technologies (see Section 8).
• Push notification tokens, if you allow notifications in our apps.

• To provide, operate and maintain the Service, including your account.
• To determine which company provides your account, based on your country of residence.
• To match Travelers and Locals and to enable requests, bookings, messaging and reviews.
• To process payments, refunds and payouts (through Hedell Group Inc. and Stripe).
• To translate messages and other content between languages.
• To verify identity, keep the Service safe, and detect and prevent fraud, abuse and violations of our Terms of Service.
• To respond to your inquiries and provide customer support.
• To send you service messages, such as booking updates, security alerts and notifications.
• To analyze how the Service is used, improve it, and measure the effectiveness of our advertising.
• To comply with legal obligations and to establish, exercise or defend legal claims.
• To create statistics that do not identify you.

If the GDPR or the UK GDPR applies to you, we rely on the following legal bases:

• Performance of a contract: to provide the Service and your bookings.
• Legitimate interests: to keep the Service safe, prevent fraud, improve the Service and communicate with you, where these interests are not overridden by your rights.
• Consent: for example, for push notifications and, where required, non-essential cookies. You can withdraw your consent at any time.
• Legal obligations: for example, to keep transaction records.

We do not sell your personal information for money. We share it only as described below.

5.1 With other users

When you send or receive a request, or are matched, we share what is needed for the Session, such as your display name, profile photo, profile, languages, Session details and messages. If you confirm that you are 20 or older for an experience involving alcohol, the Local can see that you made this confirmation. Reviews may be shown publicly on the Service.

5.2 With Hedell Group Inc. (Japan)

Because all Sessions take place in Japan and are provided and paid for through Hedell Group Inc., we share with it the information needed to provide your bookings, process payments and refunds, provide support, keep users safe and comply with Japanese law. This includes your account and profile information, booking details, messages relating to your bookings, and payment information.

5.3 With service providers

We use service providers that process personal information on our behalf, under contracts that require them to protect it and use it only to provide their services to us:

• Stripe: Payments, refunds, payouts to Locals and identity verification of Locals
• Vercel: Hosting, file storage and site performance analytics
• PlanetScale: Database hosting
• Upstash: Caching and rate limiting
• Resend: Email delivery
• Sentry: Error monitoring
• DeepL and Google Cloud Translation: Translation of messages and other content
• Google Firebase Cloud Messaging: Push notifications in our apps
• Cloudflare: Content delivery, security and bot protection

5.4 Sign-in and advertising partners

If you choose to sign in with Google, Facebook or Apple, those companies process information under their own privacy policies. We use the Meta Pixel from Meta Platforms, Inc. to measure the effectiveness of our advertising; Meta receives information about your use of our website, such as pages visited, together with identifiers such as your IP address and browser information.

5.5 Legal, safety and business transfers

We may disclose information if required by law, legal process or a government request; where necessary to protect the life, safety or property of any person; or to protect our rights and enforce our Terms of Service. If we are involved in a merger, acquisition, financing, reorganization or sale of assets, your information may be transferred as part of that transaction. We may also share information with your consent or at your direction.

We are based in the United States, and our service providers store and process data in the United States and other countries. Your information is also transferred to Hedell Group Inc. in Japan to provide Sessions. These countries may have data protection laws that differ from those of your country.

Where required by law, for example for transfers from the European Economic Area, the United Kingdom or Switzerland, we use appropriate safeguards, such as adequacy decisions (including the European Commission’s adequacy decision for Japan) or standard contractual clauses approved by the European Commission and their UK and Swiss equivalents. You can ask us for more information about these safeguards.

• We keep your information for as long as your account is active and as needed to provide the Service.
• When you delete your account, we delete or anonymize your personal information within 30 days, except as described below.
• We keep information that we must retain by law, such as transaction records, for the period required by law, and information needed to resolve disputes, prevent fraud and abuse, or enforce our Terms of Service for as long as necessary for those purposes.

• Essential cookies: to keep you signed in, remember your language and other settings, and protect the Service. The Service does not work properly without them.
• Analytics: Vercel Analytics to measure site performance, and Sentry to monitor technical errors.
• Advertising measurement: the Meta Pixel, to measure the effectiveness of our advertising on Meta’s platforms.

You can block or delete cookies in your browser settings, but some features of the Service may then not work. Where the law requires your consent for non-essential cookies, we will ask for it.

Depending on where you live, you may have the right to:

• access the personal information we hold about you;
• correct inaccurate personal information;
• delete your personal information;
• receive a copy of your personal information in a portable format;
• object to, or ask us to restrict, certain processing;
• withdraw your consent at any time, where we rely on consent; and
• opt out of the “sharing” of personal information for targeted advertising (see Section 10).

You can update much of your information in your account settings and delete your account at any time. To make any other request, email privacy@loca-ride.com. We will verify your identity before acting on a request and respond within the time required by law. Where the law allows, you may use an authorized agent to make a request. If we decline your request, you may appeal by replying to our response. We will not discriminate against you for exercising your rights.

You can turn off push notifications in your device settings and manage notification preferences in the app.

This section supplements this Policy for California residents, as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA).

• Categories of personal information we collect: identifiers (such as name, email address, IP address and account ID); customer records (such as contact and payment-related information); commercial information (such as bookings and transactions); internet or other electronic network activity (such as usage data and cookies); approximate geolocation (country inferred from your IP address); audio or visual information (such as profile photos); and sensitive personal information (account login credentials and, for Local applicants, identity verification data).
• Sources: you, your devices, other users, sign-in providers, Hedell Group Inc. and our service providers.
• Purposes: the purposes described in Section 3.
• Recipients: the categories of recipients described in Section 5.
• Sale and sharing: we do not sell personal information for money. Our use of the Meta Pixel may be considered “sharing” of identifiers and internet activity for cross-context behavioral advertising. You can opt out of this sharing by emailing privacy@loca-ride.comwith the subject “Do Not Share My Personal Information.” We do not knowingly sell or share the personal information of consumers under 16.
• Sensitive personal information: we use it only for purposes permitted by law, such as providing the Service and keeping it secure, and not to infer characteristics about you.
• Retention: as described in Section 7.
• Your rights: you have the right to know and access, delete and correct your personal information, to opt out of its sale or sharing, and not to be discriminated against for exercising these rights. See Section 9 for how to make a request.

In addition to the rights described in Section 9, you have the right to lodge a complaint with the data protection authority in the country where you live or work, or where an alleged infringement took place (in the UK, the Information Commissioner’s Office). We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing.

We use reasonable technical and organizational measures to protect your information, including encrypted connections, access controls and hashed passwords. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

The Service is intended only for people aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will delete it promptly. If you believe that a minor has provided us with personal information, please contact us at privacy@loca-ride.com.

We may update this Policy from time to time. If we make material changes, we will notify you on the Service or by email before they take effect. The “Last updated” date above shows when this Policy was last changed.

This Policy is written in English. Any translation is provided for convenience only, and the English version governs.

CueWorker, Inc.
1301 N Broadway STE 32998, Los Angeles, CA 90012, United States
Privacy inquiries: privacy@loca-ride.com
General support: support@loca-ride.com