NearGo PRIVACY POLICY

Version: 1.2 Effective date: 3 June 2026

1. INTRODUCTION

Podjetniški Projektni Center ANAplus d.o.o. (hereinafter "NearGo" or "we") respects your privacy and is committed to protecting your personal data in accordance with:

• The General Data Protection Regulation (GDPR, EU Regulation 2016/679)
• All applicable data protection regulations

2. DATA CONTROLLER

Personal data controller:

Podjetniški Projektni Center ANAplus d.o.o. Ljubljanska cesta 11, 3000 Celje, Slovenia

Email: info@getneargo.com Phone: +386 40 642 239

3. DATA WE COLLECT

3.1 Data you provide yourself

At registration:

• Email address
• Password (stored encrypted)
• First name and last name (optional)
• Phone number (optional)
• Year of birth (for age verification)

During use:

• Profile settings (interests, categories)
• Ratings and reviews
• Wishlist (favorites list)
• Purchase history

Vendor accounts (additional):

• Company name
• Tax number
• Registered address
• Bank account / IBAN (for payouts)
• Company contact details

3.2 Data collected automatically

Technical data:

• IP address
• Device type (iOS, Android)
• Operating system version
• Application version
• Device identifier (Device ID)

Usage patterns:

• Offer views
• Clicks and interactions
• Usage times
• Crash reports

Location data:

• GPS location (only with explicit permission)
• City location (based on IP)
• Search radius (user-defined)

3.3 Data from third-party sources

• Social login data (Google, Apple) — in accordance with their policies
• Payment data via Stripe (NearGo does NOT have access to full card details)

4. PURPOSES OF DATA PROCESSING

4.1 Legal bases for processing

We process your data on the following legal bases:

a) Contractual obligation (Art. 6/1/b GDPR):

• Service provision
• Payment processing
• Sending transactional emails

b) Legal obligation (Art. 6/1/c GDPR):

• Retention of accounting records (10 years)
• Anti-money laundering
• Tax obligations

c) Legitimate interest (Art. 6/1/f GDPR):

• Service improvement
• Fraud prevention
• System security

d) Consent (Art. 6/1/a GDPR):

• Marketing communications
• Push notifications
• Location data
• Cookies (analytical)

4.2 Specific purposes

5. SHARING DATA WITH THIRD PARTIES

5.1 Our data processors

The following providers have access to some of your data to provide the service:

Ticketmaster is not a processor of your personal data. We use it as an external source of event information (search/discovery): when you search, only search parameters (location, keywords) are sent, without your personal data. Any purchase at Ticketmaster takes place on their external page; NearGo does not process their payments.

5.2 Transfers outside the EU

Some processors are located outside the EU (mainly the USA). Transfers are safeguarded by:

• EU Standard Contractual Clauses
• EU-US Data Privacy Framework
• Other safeguards in accordance with GDPR

5.3 Disclosure to authorities

We may disclose your data to:

• Competent authorities upon their lawful request
• In court proceedings
• Where there is suspicion of a criminal offense

6. DATA RETENTION PERIOD

7. YOUR RIGHTS

In accordance with the GDPR, you have the following rights:

7.1 Right of access (Art. 15)

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

7.2 Right to rectification (Art. 16)

You may request correction of inaccurate or incomplete data.

7.3 Right to erasure "right to be forgotten" (Art. 17)

You may request the deletion of your data, except in cases of:

• Statutory retention obligation (accounting)
• Necessary for the defense of legal claims

7.4 Right to restriction of processing (Art. 18)

You may request a temporary restriction of data processing.

7.5 Right to data portability (Art. 20)

You may request your data in a structured format for transfer.

7.6 Right to object (Art. 21)

You may object to the processing of your data, especially for marketing purposes.

7.7 Right to withdraw consent

You may withdraw given consent at any time.

7.8 How to exercise rights

Send requests to: info@getneargo.com Phone: +386 40 642 239 Response time: 30 days (extendable to 60 days) Cost: free of charge (except for manifestly unfounded requests)

7.9 Right to lodge a complaint

You have the right to lodge a complaint with the competent data protection supervisory authority in your country of residence. List of EU authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en

8. DATA SECURITY

8.1 Technical measures

• HTTPS/TLS encryption of all connections
• Password encryption with bcrypt
• Row-Level Security (RLS) in the database
• Regular security audits
• Data backup

8.2 Organizational measures

• Restricted employee access to data
• Clean desk policy
• Regular training
• NDA agreements signed

8.3 Breach notification

In the event of a security breach that may affect your data:

• We notify the competent supervisory authority within 72 hours
• We notify affected users (if the risk is high)

9. CHILDREN

NearGo does NOT collect data from children under 13. The application is intended for users over the age of 18.

If we discover that we have unknowingly collected data from a child, we delete it immediately.

10. POLICY CHANGES

This Privacy Policy may change. We will inform you of material changes:

• By email
• Through an in-app notification
• 30 days before the effective date

11. CONTACT

Email: info@getneargo.com Phone: +386 3 898 00 24, +386 40 642 239

Podjetniški Projektni Center ANAplus d.o.o. Ljubljanska cesta 11, 3000 Celje, Slovenia VAT ID: SI16311647 Registration No.: 6452515000 IBAN: SI56 2900 0005 1317 804 (Unicredit Banka Slovenija)

Podjetniški Projektni Center ANAplus d.o.o. Ljubljanska cesta 11, 3000 Celje, Slovenia

Translation in progress

This document is currently being translated. Please refer to the Slovenian version for the latest information.

For questions, contact: Email: info@getneargo.com Phone: +386 40 642 239