Legal

Terms, policies and notices for Local & Traveler OÜ.

Terms of Use Agreement for Travelers

1. Parties

This Local & Traveler Mobile Application Terms of Use Agreement (hereinafter referred to as the "Terms of Use") applies to members registered under the "Traveler" category of the Local & Traveler mobile application and is entered into with Local & Traveler OÜ (hereinafter referred to as "L&T"), the developer and owner of the Local & Traveler mobile application, having its registered office at Ahtri tn 12, Kesklinna linnaosa, Tallinn, Harju maakond, 15551, Estonia.

L&T and the Traveler shall each be referred to individually as a “Party” and collectively as the “Parties.”

2. Definitions

L&T refers to Local & Traveler OÜ acting as an electronic commerce intermediary service provider.

Local & Traveler Mobile App Application and Website (hereinafter referred to as “Local&Traveler” or the “Mobile Application”) refers to the mobile application developed and owned by L&T acting as an intermediary service provider.

Local refers to an independent natural person who has the status of an electronic commerce service provider, who registers on the Local&Traveler application and, for various reasons, transfers their experience to Travelers at their location, shares their knowledge and experience, and socially accompanies Travelers.

Traveler refers to a natural person who visits a place for any reason and requests to benefit from the experiences of the Local and to be accompanied by the Local.

Member refers to any person registered with Local&Traveler.

L&T Services refer to the electronic commerce intermediary services provided by L&T to enable the Local and the Traveler to come together electronically so that the Local can provide services to the Traveler.

Service refers to any service provided by the Local to the Traveler and agreed upon by the Parties within the scope of their requests.

Service Fee refers to the fee requested by the Local from the Traveler for the services to be provided.

Commission Fee refers the fee determined exclusively by L&T, to which L&T is entitled in its capacity as an intermediary service provider, calculated on the basis of the service fee offered by the Local and accepted by the Traveler for services agreed upon between the Local and the Traveler.

3. Services Provided by L&T

a. L&T ensures that the service information created by the Local and the Traveler is displayed on the Local&Traveler mobile application in accordance with the content notified to it and within the framework of these Terms of Use.

b. L&T provides services limited to the allocation of a profile area to the Traveler on the mobile application, the infrastructure for creating and publishing service listings, the establishment of means enabling communication between the Local and the Traveler, the possibility of creating reservations between the Local and the Traveler, the establishment of a rating/evaluation infrastructure after the service, and the provision of technical support and an internal communication system.

c. L&T is only an online platform and is not the owner or provider of the services listed on the mobile application. In accordance with the legislation, L&T is an electronic commerce intermediary service provider and is not obliged to control the content provided by real and legal persons using the electronic environment, to investigate whether there is any unlawful activity or situation regarding such content or the goods or services subject to such content, or to intervene in the content, quality, or method of the service.

ç. The mobile application facilitates bringing the Traveler and the Local together, enabling experience sharing, cultural interaction, companionship in organized reservations, and thus establishing a relationship based on trust and sincerity between the Parties.

4. Terms of Use

a. By selecting the checkbox stating "I have read, understood and agree to the Terms of Use", the Traveler fully accepts these Terms of Use. Acceptance of the Terms of Use is a prerequisite for accessing the Mobile Application and the services provided by L&T. Partial acceptance of these Terms of Use shall not be permitted.

b. Registration with the Mobile Application is free of charge. The provisions regarding the application usage fees payable to L&T remain reserved.

c. Individuals under the age of eighteen (18), persons lacking legal capacity, or persons with limited legal capacity may not register as members of the Mobile Application.

d. The Traveler is responsible for maintaining the confidentiality and security of his/her username, password, and other account credentials. Any activity carried out through the Traveler's account shall be deemed to have been performed by the Traveler. The Traveler shall be solely liable for any unauthorized use resulting from the disclosure of account credentials and shall indemnify L&T against any claims, losses, or damages arising therefrom. The Traveler shall not access or use the data of other members without authorization.

e. The Traveler shall not use robots, bots, automated access methods, malicious software, viruses, or any technology that may interfere with the operation of the Mobile Application or the rights of other members. The Traveler shall not use the Mobile Application for any unlawful, fraudulent, or unauthorized purpose or to create or maintain databases, directories, or similar records on behalf of any person or entity.

f. While L&T implements reasonable technical measures to protect the Mobile Application against viruses and other harmful software, it does not warrant that the Mobile Application will be free from such threats. The Traveler is responsible for maintaining appropriate security measures and acknowledges that L&T shall not be liable for any damage, malfunction, or data loss affecting the Traveler's own devices or software.

g. The Traveler shall provide accurate and up-to-date profile information and shall not create misleading profiles, provide false information, engage in unlawful activities, infringe the rights of others, or violate L&T's policies relating to privacy, personal data protection, or the use of the Mobile Application.

h. Without limitation, the Traveler shall not upload, publish, or transmit any content that is unlawful, defamatory, abusive, discriminatory, misleading, fraudulent, obscene, threatening, infringes intellectual property rights, violates consumer protection laws, promotes illegal activities, exploits minors, distributes spam, malware, or pirated content, or otherwise violates applicable law or the rights of third parties. Any opinions, comments, or content shared by members are solely those of the respective member and shall not be attributed to L&T. L&T shall not be liable for such content and reserves the right to seek recourse against the responsible member for any loss or damage incurred.

i. The Traveler may not assign or transfer, in whole or in part, any of his/her rights or obligations under these Terms of Use to any third party. Except in the case of group bookings or organized reservations, the Traveler may only make reservations on his/her own behalf using accurate and up-to-date information. Except for the services provided directly by L&T through the Mobile Application, any contract relating to goods or services booked through the Mobile Application is concluded solely between the Traveler and the relevant Local. L&T is not a party to such contract and assumes no responsibility for the performance, quality, legality, invoicing, tax obligations, required permits, or after-sales services relating to the goods or services offered by the Local. The Traveler agrees that any claim arising from such services shall be directed exclusively against the relevant Local. The Local acts as an independent service provider and is neither an employee nor a legal representative of L&T.

j. The Traveler undertakes to comply with all applicable laws while using the services, to refrain from any conduct that may endanger the safety or security of the Local, other Travelers, or third parties, and to communicate with other members respectfully. The Traveler shall be solely responsible for his/her own acts and omissions in connection with the services received.

k. The Traveler freely selects the Local from whom he/she wishes to receive services. The Traveler may request information from the Local regarding any licenses, permits, qualifications, or other authorizations that may be required under applicable law or by the nature of the services. The Traveler is responsible for exercising reasonable care when selecting a Local. L&T has no obligation to verify the existence, validity, or accuracy of any licenses, permits, qualifications, or other documents held by the Local. The Local remains solely responsible for providing services lawfully and in compliance with applicable legislation. The Traveler acknowledges that L&T shall not be liable for any loss or damage resulting from the Traveler's own negligence or from the services provided by the Local.

l. Any civil, administrative, criminal, contractual, or other liability arising from the failure of the Traveler or any other member to comply with these Terms of Use shall be borne solely by the Traveler or the relevant member, even where such liability is not expressly provided for in these Terms of Use.

m. The Traveler acknowledges that the software enabling access to and use of the Mobile Application may not be error-free and that L&T makes no representation or warranty, whether express or implied, regarding its uninterrupted operation, availability, reliability, security, or error-free performance.

n. In accordance with the European Union's Digital Services Act (DSA), L&T provides an easily accessible electronic notice mechanism for reporting illegal content available on the Mobile Application. Upon receipt of a sufficiently substantiated notice, L&T shall review the matter without undue delay and take appropriate measures where required under applicable law. Where the Traveler breaches these Terms of Use, engages in unlawful conduct, becomes the subject of repeated complaints, or where immediate action is required due to fraud, personal data breaches, cybersecurity risks, public order, or other circumstances provided for under applicable law, L&T may restrict the provision of its intermediary services, suspend the Traveler's account, or permanently terminate the account. Users whose accounts have been suspended or whose content has been removed shall have the right to submit a complaint through L&T's internal complaint-handling system free of charge for at least six (6) months following the relevant decision.

5. Profile Information

a. The Traveler is obliged to enter the information requested by L&T into the mobile application accurately and up-to-date for the purpose of completing the membership process and fulfilling obligations arising from the legislation.

b. Following the completion of mandatory information on the mobile application, the Traveler may complete their profile information as they wish, provided that it is accurate and up-to-date. In order to establish trust with other members, the Traveler may verify their profile by submitting identity verification documents and obtain a verified profile account. Such practices may facilitate the Traveler’s access to the Local or other members during the service request process.

6. Reservation Process

a. Following completion of the membership process, the Traveler may create a reservation through the mobile application depending on the availability of the Local deemed appropriate by the Traveler. The Traveler may submit requests to and receive offers from a Local of their choosing. The Traveler shall be entirely free in selecting the Local. Where an agreement is reached between the Traveler and the Local regarding the requested service content, the Traveler shall make payment of the service fee requested by the Local through the mobile application and via intermediary payment institutions contracted by L&T. The Traveler agrees and undertakes to make such payment in compliance with applicable laws. L&T may temporarily suspend the relevant members’ ability to make payments through the online payment method, restrict additional features offered for online payments, or completely discontinue such services due to transactions giving rise to security concerns. L&T shall bear no liability towards members or third parties arising from the temporary suspension or complete discontinuation of the mobile application or the online payment method.

b. Following completion of the payment, the Local and the Traveler may communicate with each other and mutually share all requests and expectations.

c. Following the provision of the service, the Traveler may rate the Local through the mobile application and provide feedback regarding the service.

7. Service Fee and Commission Fee

a. The service fee shall be freely determined by mutual agreement between the Local and the Traveler. However, L&T may provide recommendations within certain price ranges corresponding to the relevant service in order to improve the usability of the mobile application. The Local and the Traveler are free to agree on a service fee below or above such recommendations. L&T’s recommendations shall not be binding and shall not be interpreted against the members.

b. The Traveler and the Local agree and undertake not to engage in any acts or transactions against L&T for the purpose of reducing or eliminating the commission fee to which L&T is entitled. If it is determined by L&T that the parties have reached an agreement without notifying L&T and submitted an offer in order to avoid paying the intermediary service fee, L&T shall be entitled to the commission fee for the service provided.

c. The Traveler shall make payments through intermediary payment institutions cooperating with L&T via the mobile application. L&T does not directly carry out collection transactions. The relationship between the payment institution and the Local and the Traveler is independent from L&T, and the fulfilment of obligations and responsibilities stipulated under the applicable legislation belongs to the relevant payment institution.

ç. The service fee payment to the Local shall be made after deduction of the commission fee to which L&T is entitled from the service fee paid by the Traveler.

d. The Local shall be exclusively responsible for all tax-related obligations arising from the service fee. The Local shall also be responsible for issuing invoices, receipts, and fulfilling any similar obligations relating to the service fee. L&T reserves the right to notify or report to the competent authorities and institutions in the event that it detects a suspicious transaction regarding the transfer of funds between the parties.

8. Cancellation and Refund

a. Payments made through the online payment method may be refunded to the Traveler under the following conditions:

a.a. In the event of any cancellation made by the Local prior to the performance of the service, the fee paid by the Traveler shall be refunded in full.
a.b. In the event of any cancellation made by the Traveler up to 48 hours before the performance of the service, the fee paid by the Traveler shall be refunded in full. If the cancellation is made by the Traveler between 24 and 48 hours before the performance of the service, 50% of the fee paid by the Traveler shall be refunded. No refund shall be made for any cancellation carried out by the Traveler less than 24 hours before the performance of the service.
a.c. If the services undertaken by the Local are not provided despite no cancellation having occurred, the fee paid by the Traveler shall be refunded.
a.d. Any refund shall be processed within fourteen (14) days and credited to the credit card or debit card used by the Traveler to make the original payment.

9. Mobile Application Ranking and Recommendation Parameters

a. L&T shall refrain from any acts or conduct that may actively lead to manipulation while ranking members and carrying out visibility functions within the mobile application. L&T shall rank members within the mobile application based on objective criteria by taking into account factors such as the ratings members receive from one another, information regarding Travelers’ experiences, whether the service fees requested by Locals are relatively high or low, whether the Local or the Traveler has withdrawn from the performance of the service, the frequency with which Locals provide services, the frequency with which Travelers receive services, members’ active use of the mobile application, comments made by Travelers, whether members have fully completed their profile information, whether members have verified profiles, behavioural analysis activities, trust score assessments carried out within the scope of automated decision-making processes, and the vehicles owned by Locals for the provision of services.

10. Intellectual and Industrial Property Rights

a. All intellectual property rights relating to the L&T name, trademarks, logos, the Mobile Application, its design, software, domain name, and all related content are owned by or licensed to L&T. Members may not use, reproduce, modify, distribute, or otherwise exploit such intellectual property without the prior written consent of L&T.

b. All intellectual property rights in the Mobile Application, including its source code, object code, software, databases, systems, and any updates or derivative versions, are owned by or licensed to L&T. Except as expressly permitted by these Terms of Use or applicable law, Members may not copy, reproduce, modify, adapt, translate, reverse engineer, decompile, disassemble, distribute, publish, publicly display, transmit, or otherwise exploit any part of the Mobile Application without L&T's prior written consent.

c. If a Member infringes the intellectual property rights of L&T or any third party, including other Members, the infringing Member shall be solely responsible for such infringement and shall indemnify L&T against any loss, damage, liability, or expense arising therefrom.

d. Any opinions, reviews, recommendations, comments, photographs, videos, images, or other content published through the Mobile Application remain the responsibility of the Member who submitted them. L&T does not guarantee the accuracy, completeness, reliability, or usefulness of such content and assumes no responsibility for it. Members represent and warrant that the content they upload does not infringe the personal, intellectual property, or industrial property rights of any third party and agree to indemnify L&T for any loss or damage arising from a breach of this obligation.

e. If L&T determines that any content violates these Terms of Use or applicable law, it may remove such content without prior notice and may restrict, suspend, or terminate the relevant Member's access to the Mobile Application. Where required or permitted by applicable law, L&T may also report the relevant content or conduct to the competent public authorities.

11. Processing of Personal Data and Access to Data

a. L&T may process the personal data of members for the purpose of providing mobile application services. In this context, L&T is also obliged to retain all information relating to members available on the mobile application, including but not limited to reservation data, service data, and similar information, for the periods prescribed under applicable legislation. L&T fulfills its obligations regarding the processing of personal data in full compliance with the General Data Protection Regulation (“GDPR”) and applicable local data protection laws. The privacy notice, as well as policies and procedures regarding the processing of personal data, are made available to members through the application.

b. The Traveler acknowledges and undertakes that it acts as an independent data controller with respect to Local data; that it shall process any personal data obtained through the use of the mobile application solely for the purpose of the performance of the service; that it shall not process such personal data unlawfully or transfer it to third parties; that it shall take all necessary administrative and technical measures to ensure the security of personal data; and that it shall fulfill all obligations set forth under the General Data Protection Regulation (“GDPR”) and applicable local data protection laws.

c. The Traveler undertakes that, in the event of processing personal data through audio or video recording during the service, it shall not act in violation of the privacy of third parties, shall inform such persons and obtain their consent, and shall act in compliance with applicable law. The Traveler accepts and declares that any liability arising from non-compliance with these obligations shall rest exclusively with the Traveler.

ç. The Traveler may access their own information on their profile page. For the purpose of ensuring data security, the Traveler may access the Local’s information for a period of 7 days following the receipt of the service. After this period, the Traveler’s access to the Local’s data shall be revoked.

12. Communication and Notifications

a. L&T establishes an internal communication system via its e-mail addresses or communication channels within the mobile application in order to communicate with the Traveler. All communications between the Parties shall be carried out through these channels.

b. All notifications, contract amendments, changes to the Terms of Use, and correspondence between the Parties shall be conducted through the internal communication system.

13. Limitation of Liability

a. As repeatedly stated in these Terms of Use, L&T is solely an online intermediary platform and is not the owner or provider of the services available on the mobile application. In accordance with applicable legislation, L&T acts as an electronic commerce intermediary service provider. Services provided by the Local are rendered solely and exclusively by the Local, and L&T bears no responsibility in this regard.

b. The services offered through this platform do not constitute professional tourist guide services. Locals are individuals who share their personal experiences. In cases where services are provided in a professional or commercial capacity, L&T shall take measures to the extent permitted by applicable legislation.

c. The mobile application is a platform established for the purpose of sharing experiences and enabling members to post listings. Unless identity verification is requested by the parties, L&T does not guarantee the accuracy of identities or licenses.

ç. L&T shall not be liable, except for mandatory liabilities arising from applicable law, for any direct or indirect damages arising from access to or use of the mobile application, the content or data therein, or any programs, including but not limited to breaches of the service relationship between the Local and the Traveler, or the safety, content, quality, or legality of the services. L&T shall not accept any liability for interruption of transactions, errors, omissions, or interruptions resulting from breaches, tort, negligence, or other causes. By accessing or using the mobile application, it is accepted that L&T is released from any and all liability, including court costs and other claims. L&T shall in no way be held responsible for the actions of members.

d. In the event that L&T becomes aware that content provided by members is unlawful, it shall remove such content from publication without delay, not exceeding forty-eight hours, and notify the relevant member and competent authorities, stating the reasons.

14. Force Majeure

a. Any extraordinary circumstances beyond the control of L&T and the members, which could not have been foreseen or prevented and which directly affect the performance of contractual obligations, including but not limited to fire, riots, floods, strikes, epidemics, curfews, war, civil unrest, and similar events, shall be deemed force majeure events.

b. If either Party is unable or will be unable to perform any of its obligations due to force majeure, it shall not be held liable for such obligations. The Parties shall fulfill their obligations upon the cessation of the force majeure event. If the force majeure event continues for more than 30 days, the Parties may terminate the Agreement.

c. In cases where the service to be provided by the Local to the Traveler cannot be performed due to force majeure, the provisions of Article 8 shall apply.

15. Amendments to the Agreement

a. L&T reserves the right to unilaterally amend or modify these Terms of Use at any time for the purpose of ensuring continuity of its services, adapting to technical requirements, or complying with legislation. In the event of any changes, L&T shall publish the updated Terms through the internal communication system with a revised date and may notify users via e-mail or mobile notification. The updated Terms shall enter into force 15 days after notification and continued use of the mobile application shall be subject to the updated Terms.

16. Dispute Resolution

a. In the event of any dispute arising out of or in connection with these Terms of Use, the Parties agree to first attempt to resolve the dispute amicably and in good faith through L&T's internal communication channels.

b. If the dispute cannot be resolved amicably, these Terms of Use shall be governed by and construed in accordance with the substantive laws of the Republic of Estonia.

c. Notwithstanding Section (b) above, Travelers who qualify as Consumers under the laws of the European Union and who reside in a Member State of the European Union (EU) or the European Economic Area (EEA) shall retain all mandatory consumer protection rights available under applicable law. In particular:

such Travelers may bring claims against L&T either before the competent courts of Estonia or the courts of the EU/EEA Member State in which they are habitually resident;
L&T may bring legal proceedings against a Consumer only before the courts of the Consumer's country of habitual residence; and
the application of Estonian law shall not deprive Consumers of the protection afforded by the mandatory provisions of the laws of their country of habitual residence.

d. In any dispute arising out of or relating to these Terms of Use, L&T's records, including electronic records such as computer logs and audio recordings, may be submitted as evidence to the extent permitted by applicable law.

17. Termination and Duration

a. In the event that the Member violates any provision of these Terms of Use or if L&T has reasonable suspicion thereof, L&T may unilaterally terminate the membership and the Terms of Use Agreement.

b. In addition to the above, L&T reserves the right to unilaterally terminate the Terms of Use Agreement if 5 years have elapsed since the Member’s last transaction date.

c. The Member has the right to terminate the Terms of Use Agreement and cancel their membership at any time by notifying L&T.

18. Entry into Force

a. These Terms of Use shall enter into force upon the Traveler's acceptance by electronic means. By accepting these Terms of Use, the Traveler acknowledges that he/she has read, understood, and agreed to be bound by all of their provisions. Although these Terms of Use may be made available in different languages, the English version shall prevail in the event of any inconsistency or discrepancy.

Terms of Use Agreement for Locals

1. Parties

This Local & Traveler Mobile Application Terms of Use Agreement (hereinafter referred to as the "Terms of Use") applies to members registered under the "Local" category of the Local & Traveler mobile application and is entered into with Local & Traveler OÜ (hereinafter referred to as "L&T"), the developer and owner of the Local & Traveler mobile application, having its registered office at Ahtri tn 12, Kesklinna linnaosa, Tallinn, Harju maakond, 15551, Estonia.

L&T and the Local shall each be referred to individually as a “Party” and collectively as the “Parties.”

2. Definitions

L&T refers to Local & Traveler OÜ acting as an electronic commerce intermediary service provider.

Traveler refers to a natural person who visits a place for any reason and requests to benefit from the experiences of the Local and to be accompanied by the Local.

Member refers to any person registered with Local&Traveler.

L&T Services refer to the electronic commerce intermediary services provided by L&T to enable the Local and the Traveler to come together electronically.

Service refers to any service provided by the Local to the Traveler and agreed upon by the Parties within the scope of their requests.

Service Fee refers to the fee requested by the Local from the Traveler for the services to be provided.

Commission Fee refers to the fee determined exclusively by L&T, based on the service fee proposed by the Local and accepted by the Traveler for the services agreed between the Local and the Traveler, and earned by L&T in its capacity as an intermediary service provider. The commission fee has been determined as 20% of the service fee.

Regulation refers to the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers published in the Official Gazette dated 29.12.2022 and numbered 32058.

3. Services Provided by L&T

b. L&T provides services limited to the allocation of a profile area to the Local on the mobile application, the infrastructure for creating and publishing listings, the establishment of means enabling communication between the Local and the Traveler, the possibility of creating reservations, the establishment of a rating/evaluation infrastructure after the service, and the provision of technical support and an internal communication system.

c. L&T is only an online platform and is not the owner or provider of the services listed on the mobile application. In accordance with the applicable legislation, L&T is an electronic commerce intermediary service provider and is not obliged to control the content provided by real and legal persons using the electronic environment, to investigate whether there is any unlawful activity or situation regarding such content or the goods or services subject to such content, or to intervene in the content, quality, or method of the service.

d. The mobile application facilitates bringing the Traveler and the Local together, enabling experience sharing, cultural interaction, companionship in organized reservations, and thus establishing a relationship based on trust and sincerity between the Parties.

4. Terms of Use

a. By ticking the checkbox stating “I have read, understood and accept the Terms of Use Agreement” on the mobile application, the Local fully accepts these Terms of Use. If the Terms of Use are not accepted, the Local shall not be allowed to access the mobile application and the services provided by L&T. No Member has the right to partially accept the Terms of Use. Each Member agrees to comply with the Terms of Use determined by L&T.

b. Membership to the mobile application is free of charge. Provisions regarding the commission fee to which L&T is entitled are reserved.

c. Persons under the age of 18 or adults lacking legal capacity or with limited capacity may not become members of Local&Traveler.

d. The username and password required by the Local to carry out transactions through the mobile application are created by the Local during the membership process, and the security and confidentiality of such information are entirely the responsibility of the Local. The Local may not share such password with any third party. The right to use the password belongs exclusively to the Local. The responsibility for the security, storage, protection from third parties, and use of the tools enabling access to the mobile application (e-mail, username, password, etc.) lies solely with the Local.

e. The Local shall be solely responsible for any and all damages arising from the disclosure of his/her password to third parties. The Local acknowledges, represents, and undertakes that all transactions carried out using his/her username and password shall be deemed to have been performed by the Local, that the Local shall be solely responsible for all liabilities arising from such transactions, that the Local shall not raise any objection claiming that such transactions were not performed by him/her, and that the Local shall not refrain from fulfilling his/her obligations on the basis of such objection. The Local further acknowledges, represents, and undertakes that he/she shall be solely liable for all consequences arising from such unauthorized use and for any claims, demands, lawsuits, or actions that may be brought against L&T by third parties or competent authorities due thereto, and shall fully indemnify and hold L&T harmless against any and all losses, damages, liabilities, costs, and expenses incurred by L&T. L&T reserves all rights to claim compensation and pursue any other legal remedies arising from such unauthorized use. The Local further undertakes not to access, obtain, use, copy, disclose, or otherwise exploit the data of other members without authorization and acknowledges that any liability arising from a breach of this obligation shall rest exclusively with the Local.

f. The Local shall not access the Mobile Application through robots, bots, scripts, automated login methods, or any similar technologies. The Local shall not engage in any activity that prevents, restricts, disrupts, or makes more difficult the access of other members to the Mobile Application, nor shall the Local infringe upon or violate the personal or property rights of other members. The Local shall not use any technology capable of damaging the Mobile Application or any content contained therein, distribute viruses, malware, or other harmful software, or use the Mobile Application for any unlawful, fraudulent, or unauthorized purpose. Furthermore, the Local shall not use the Mobile Application for the purpose of creating, maintaining, controlling, updating, or modifying any database, registry, directory, or similar compilation on behalf of any person or entity. In the event of any breach of the foregoing obligations, the Local shall be solely responsible for any claims, damages, liabilities, or compensation sought by third parties.

g. Although L&T has implemented reasonable technical and organizational measures within the limits of available technology to protect the Mobile Application against viruses, malware, and similar harmful software, L&T does not warrant that the Mobile Application is free from such threats. The Local is solely responsible for obtaining and maintaining adequate virus protection software and taking all necessary security precautions. The Local acknowledges, represents, and undertakes to carry out all activities on the Mobile Application in a manner that does not cause any technical damage, disruption, or impairment to the Mobile Application. The Local further agrees that L&T shall not be liable for any errors, malfunctions, data loss, software failures, operating system failures, or any other damages occurring on the Local's own devices, software, or systems.

h. The Local shall provide accurate, complete, and up-to-date information when creating and maintaining his/her profile on the Mobile Application. The Local shall not create a false or misleading profile, provide inaccurate or deceptive information, engage in any activity that may pose a security risk to L&T or other members, perform any act or transaction in violation of applicable national or international laws and regulations, engage in unlawful or criminal conduct including, without limitation, the dissemination of inappropriate content, harassment, fraud, insult, or defamation, act contrary to public morals or generally accepted ethical principles, or violate L&T's policies regarding the protection of personal data, privacy, confidentiality, or any other policies governing the use of the Mobile Application.

i. Without limitation, while using the Mobile Application, the Local shall not upload, publish, transmit, share, distribute, or otherwise make available any content or engage in any conduct that:

promotes racism, hatred, discrimination, or physical harm against any individual or group;
contains abusive, offensive, insulting, defamatory, threatening, obscene, or otherwise unlawful content directed at other members;
harasses other members or encourages harassment;
contains unsolicited commercial communications, junk mail, chain letters, spam, or similar unsolicited messages;
promotes information that the Local knows to be false, misleading, or deceptive;
promotes or facilitates illegal activities or unfair competition;
encourages copyright infringement or the unlawful or unauthorized reproduction of another person's copyrighted works, including the distribution of pirated software, images, audio or video files, links thereto, or information intended to circumvent technological protection measures;
contains password-protected, restricted-access, hidden, or inaccessible pages or images that are not lawfully linked from another publicly accessible source;
exploits persons under the age of eighteen (18), contains sexual or violent material involving minors, or solicits personal information from minors;
provides instructions relating to unlawful activities, including but not limited to the manufacture or acquisition of illegal weapons, invasion of another person's privacy, or the creation or dissemination of computer viruses or malicious software;
requests passwords or personally identifiable information from others for commercial or unlawful purposes;
includes contests, sweepstakes, lotteries, barter arrangements, advertisements, pyramid schemes, or other commercial activities without the prior written approval of L&T;
records, stores, discloses, disseminates, or otherwise misuses the personal data of other persons;
infringes the intellectual or industrial property rights of third parties, including trademarks, patents, copyrights, or similar rights;
constitutes an unfair commercial practice, restricts competition, or violates any applicable consumer protection legislation.

The foregoing list is illustrative and not exhaustive.

j. Any content, opinions, ideas, comments, statements, or views shared by members through the Mobile Application are solely the personal opinions of the respective members and shall not be deemed to reflect the opinions or views of L&T. L&T shall have no responsibility or liability whatsoever in relation to such content. Should L&T incur any loss, damage, liability, or expense arising from such content, statements, opinions, or comments, L&T expressly reserves the right of recourse against the relevant member and to seek full compensation for any damages suffered.

k. The Local may not assign, transfer, delegate, or otherwise dispose of, in whole or in part, any of his/her rights or obligations arising under these Terms of Use to any third party without the prior written consent of L&T.

l. The Local shall personally perform the services offered through the Mobile Application. Except for the services provided directly by L&T to the Local through the Mobile Application, any contractual relationship relating to the goods and/or services offered by the Local via the Mobile Application shall be established solely between the Local and the Traveler purchasing such goods and/or services. L&T is not a party to such contractual relationship. Accordingly, the Local shall be solely and exclusively responsible for, without limitation, the quality, safety, legality, regulatory compliance, and timely performance of all goods and services offered through the Mobile Application; obtaining and maintaining all permits, licenses, authorizations, and other documents required for the provision of such services; issuing invoices and other legally required documentation; complying with all applicable tax obligations; delivering all mandatory documents to the relevant parties; and providing any after-sales services required under applicable law. The Local acknowledges and agrees that L&T bears no responsibility whatsoever for the performance of the services offered by the Local and that any complaint, claim, demand, dispute, or legal action relating to such services shall be directed exclusively against the other contracting party. The Local further acknowledges that he/she is neither an employee, representative, agent, partner, franchisee, nor legal representative of L&T under any circumstances. The Local further acknowledges that, pursuant to applicable European Union legislation (including, without limitation, the DAC7 Directive) and the tax laws of the Republic of Estonia, L&T may be legally required to collect, process, retain, and report the Local's identification details, contact information, bank account details, and income generated through the Mobile Application to the competent tax authorities, including the Estonian Tax and Customs Board.

m. The Local acknowledges, represents, and undertakes that all services offered through the Mobile Application shall be performed in full compliance with applicable laws and regulations, that the Local shall refrain from any act or omission that may endanger the health, safety, or security of himself/herself, the Traveler, or any third party during the performance of the services, and that all legal, administrative, civil, and criminal liability arising from or in connection with the performance of such services shall rest solely and exclusively with the Local.

n. Where the Local represents that the services offered through the Mobile Application are provided on a professional basis, the Local shall obtain and maintain all licenses, permits, authorizations, registrations, certificates, and any other approvals required under applicable laws and regulations for the lawful provision of such services. Notwithstanding the foregoing, even where the Local does not represent the services as being professional in nature, or where the services provided exceed the intended scope or purpose of the Mobile Application, the Local shall nevertheless be solely responsible for obtaining and maintaining any licenses, permits, authorizations, registrations, certificates, or similar legal documents required under applicable law. L&T shall have no obligation to verify, investigate, monitor, or confirm whether the Local possesses or maintains the licenses, permits, authorizations, registrations, certificates, or other legal documentation required for the provision of the relevant services, nor shall L&T be responsible for verifying their authenticity, validity, or continuing effectiveness. However, where L&T reasonably suspects or determines that the services offered by the Local are unlawful, or where it becomes aware that the Local is providing services requiring mandatory licenses, permits, or other official authorizations without possessing such documentation, L&T may, at its sole discretion and without prejudice to any other rights or remedies available under applicable law:

temporarily restrict or suspend the Local's access to or use of the Mobile Application;
permanently terminate the Local's account and access to the Mobile Application; and/or
notify or report the relevant facts and circumstances to the competent judicial, administrative, regulatory, or law enforcement authorities.

The Local acknowledges and agrees that he/she shall remain solely responsible towards the Traveler for ensuring that all services are provided lawfully and in compliance with applicable legislation. Furthermore, where requested by L&T, the Local shall promptly provide copies of any licenses, permits, authorizations, certificates, registrations, or other documents demonstrating compliance with applicable legal requirements. The Local further acknowledges, represents, and undertakes that, should any unlawful act, omission, breach of applicable law, or failure to obtain or maintain the required legal documentation in connection with the services offered by the Local cause L&T to suffer any direct or indirect loss, damage, liability, administrative sanction, judicial claim, penalty, cost, or expense, the Local shall fully indemnify, defend, and hold harmless L&T against any and all such losses, damages, liabilities, costs, and expenses.

o. Where the Local uses any vehicle in the performance of the services, the Local shall provide, upon request, all information and documentation demonstrating that he/she is duly qualified, licensed, and authorized to operate such vehicle in accordance with applicable laws and regulations, for the purpose of ensuring the safety of the parties. The Local shall obtain and maintain all permits, licenses, insurance policies, registrations, and other documents required under applicable legislation for the lawful use of the vehicle in connection with the services. The Local shall be solely and exclusively responsible for any civil, administrative, criminal, financial, or other liabilities arising from or in connection with the use of such vehicle during the performance of the services. L&T shall use the information relating to the Local's vehicle solely for the purposes of filtering and ranking service listings within the Mobile Application.

p. Any civil, administrative, criminal, contractual, or other liability arising from the failure of the Local or any other member to comply with these Terms of Use shall be borne solely by the Local or the relevant member, even where such liability is not expressly provided for in these Terms of Use.

q. The Local acknowledges and agrees that software is not inherently error-free and that all software enabling the Local to access and use the Mobile Application may contain errors, defects, interruptions, vulnerabilities, or other technical limitations. The Local further acknowledges that L&T makes no representation, warranty, guarantee, or undertaking, whether express or implied, regarding the uninterrupted operation, availability, accuracy, reliability, security, or error-free functioning of such software.

r. Pursuant to the European Union's Digital Services Act (DSA), L&T provides an easily accessible electronic notice mechanism through which illegal content available on the Mobile Application may be reported. Upon receipt of a sufficiently substantiated notice concerning allegedly illegal content, L&T shall assess the notice without undue delay and, where appropriate, take the measures required under applicable law. Where the Local breaches these Terms of Use, engages in any unlawful conduct, or becomes the subject of repeated complaints, reports, or notices submitted by users or competent authorities, L&T may request the Local to provide an explanation regarding the relevant acts or circumstances. The Local shall submit such explanation to L&T within thirty (30) business days. If the Local fails to provide the requested explanation within the prescribed period, provides an explanation that is incomplete or insufficient, or if L&T determines, following its assessment, that the Local has violated these Terms of Use or applicable law, L&T may restrict the provision of its intermediary services to the Local, suspend the Local's account, or permanently terminate the Local's account. L&T shall notify the Local of any decision to restrict, suspend, or terminate the account together with the reasons for such decision. The Local shall have the right to submit explanations and to object to such decision within a reasonable period following receipt of the notification. The intermediary service relationship between the Parties shall be deemed terminated as of the date on which the notification of termination is delivered to the Local. Notwithstanding the foregoing, where immediate action is required under applicable legislation, or where the circumstances concern public order, urgent matters, fraud, personal data breaches, cybersecurity risks, or any other situation requiring immediate intervention, L&T may immediately restrict, suspend, or terminate the Local's access to the Mobile Application without prior notice, to the extent permitted by applicable law. Users whose accounts have been suspended or whose content has been removed shall have the right to submit a complaint through L&T's internal complaint-handling system free of charge for a period of six (6) months following the relevant decision.

5. Profile Information

a. The Local is obliged to enter into the mobile application the information requested by L&T accurately and up-to-date for the purpose of completing the membership process and fulfilling obligations arising from applicable legislation.

b. Following the completion of mandatory information on the mobile application, the Local may complete their profile information as they wish, provided that such information is accurate and up-to-date. In addition, in order to prove that the service provided is professional or compliant with legislation, the Local may upload licenses, permits, or similar documents to their profile. The Local may also verify their profile by submitting identity verification documents in order to establish trust with Travelers. Such practices may contribute to the Local reaching more Travelers and ranking higher in listings, as explained below.

6. Service Fee and Commission Fee

a. Any amendments relating to the service between the Members must be jointly agreed upon by the Local and the Traveler through the mobile application. The service fee shall be freely determined upon the mutual agreement of the Local and the Traveler via the mobile application. However, L&T may provide recommendations regarding certain price ranges that may correspond to the relevant service in order to improve the usability of the mobile application. The Local and the Traveler are free to agree on a service fee below or above such recommended price ranges. Any recommendations made by L&T regarding service fees are non-binding and may not be interpreted against the Members.

b. The Local agrees and undertakes not to engage in any acts or transactions against L&T aimed at reducing or eliminating the commission fee to which L&T is entitled. If L&T determines that, in relation to a service request submitted through the mobile application, the parties have reached an agreement and exchanged offers without notifying L&T for the purpose of avoiding payment of the intermediary commission fee to L&T, L&T shall remain entitled to the commission fee in respect of the relevant service, and such commission fee shall be paid by the Local to L&T.

c. The Local is obliged to provide their bank account details within the mobile application.

d. The Traveler shall make payments through intermediary payment institutions cooperating with L&T via the mobile application. L&T does not directly carry out collection transactions. The relationship between the payment institution and the Local and Traveler is independent from L&T, and the fulfilment of obligations and responsibilities stipulated under the applicable legislation belongs to the relevant payment institution.

e. Payments received from the Traveler shall be reflected as accrued receivables in the Local’s account, and such payments shall be transferred to the Local’s bank account within 7 business days following the collection of the service fee from the Traveler. The Local shall not have the right to request payments prior to these periods, and such periods shall be determined by L&T. The payment made by the Traveler shall be transferred to the bank account notified by the Local after automatic deduction of the commission fee to which L&T is entitled. However, payments to the Local may be temporarily suspended in cases involving the protection of public order, prevention of money laundering, detection or suspicion of unlawful acts such as suspicious transactions under applicable legislation.

7. Refund of Fees

a. Payments made through the online payment method may be refunded to the Traveler under the following conditions:

a.a. In the event of any cancellation made by the Local prior to the performance of the service, the fee paid by the Traveler shall be refunded in full.
a.b. In the event of any cancellation made by the Traveler up to 48 hours before the performance of the service, the fee paid by the Traveler shall be refunded in full. If the cancellation is made by the Traveler between 24 and 48 hours before the performance of the service, 50% of the fee paid by the Traveler shall be refunded. No refund shall be made for any cancellation carried out by the Traveler less than 24 hours before the performance of the service.
a.c. If the services undertaken by the Local are not provided despite no cancellation having occurred, the fee paid by the Traveler shall be refunded.

8. Mobile Application Ranking and Recommendation Parameters

a. L&T shall refrain from any acts or conduct that may actively lead to manipulation while ranking Locals and carrying out visibility functions within the mobile application. L&T shall rank Locals within the mobile application based on objective criteria by taking into account factors such as the ratings received by Locals from Travelers, information regarding Travelers’ experiences, whether the service fees requested by Locals are relatively high or low, whether the Local has withdrawn from the performance of the service, the frequency with which Locals provide services, Locals’ active use of the mobile application, comments made by Travelers, whether Locals have fully completed their profile information, whether Locals have verified profiles, behavioural analysis activities, trust score assessments carried out within the scope of automated decision-making processes, and the vehicles owned by Locals for the provision of services.

9. Intellectual and Industrial Property Rights

a. The L&T trademark and logo, the design and software of the mobile application, the domain name, and all trademarks, designs, logos, and other content created by L&T are the exclusive property of L&T. Members may not use, share, or modify them without prior written consent of L&T.

b. All intellectual property rights related to the software, source code, databases, and systems forming the mobile application, including their developed versions, belong exclusively to L&T or are used under license by L&T, without limitation as to place, time, content, medium, or number. Such materials may not be copied, processed, reverse-engineered, reproduced, distributed, publicly performed, transmitted, stored, adapted, translated, or otherwise used without prior written consent of L&T.

c. In the event that members infringe the intellectual property rights of L&T or third parties, including other members, the infringing member shall be obliged to compensate all damages incurred by L&T.

d. All content published by members through the mobile application, including opinions, recommendations, explanations, reviews, offers, or other information, belongs to the relevant authors. The authors are solely responsible for such content. L&T does not guarantee the accuracy, completeness, or usefulness of any information on the mobile application and does not accept or assume responsibility for any opinions or statements made by individuals. Members undertake that any content they publish does not infringe the personal rights, intellectual property rights, or industrial property rights of third parties and accept full liability for any violations.

e. L&T may immediately remove content that violates these Terms of Use, restrict, suspend, or terminate the relevant member’s access, and notify competent authorities where such content constitutes a criminal offense.

10. Processing of Personal Data and Access to Data

a. L&T may process the personal data of its members for the purpose of providing mobile application services. L&T acts in compliance with the General Data Protection Regulation (GDPR) and all applicable local data protection laws and fulfills its obligations in this respect fully and duly. In this context, L&T is obliged to retain all personal data of members available on the mobile application, including but not limited to reservation data, service data, and similar information, for the periods prescribed under applicable legislation. The privacy notice and the policies and procedures regarding the processing of personal data are made available to members through the application.

b. The Local acknowledges and undertakes that it acts as an independent data controller with respect to Traveler data; that it shall process any personal data obtained through the use of the mobile application solely for the purpose of performing the service; that it shall not process such personal data unlawfully or transfer it to third parties; that it shall implement all necessary administrative and technical measures to ensure the security of personal data. The Local further agrees and undertakes to comply with all obligations set forth under the General Data Protection Regulation (GDPR) and applicable local data protection laws.

c. The Local may access their own listings and performance data via their profile page. For the purpose of ensuring data security, the Local may access Traveler data for a period of 7 days following the provision of the service. After this period, access to such data shall be revoked.

11. Communication and Notifications

a. L&T establishes an internal communication system via its e-mail addresses or communication channels within the mobile application in order to communicate with the Local. All communications between the Parties shall be conducted through these channels.

b. All notifications, contract amendments, changes to the Terms of Use, and correspondence between the Parties shall be conducted through the internal communication system. The Local may access, store, and copy the Terms of Use through this system.

c. The Local shall notify L&T of any changes in their information through the internal communication system.

12. Limitation of Liability

a. As repeatedly stated throughout these Terms of Use, L&T is solely an online intermediary platform and is neither the owner nor the provider of the services offered through the Mobile Application. Under applicable legislation, L&T operates as an electronic commerce intermediary service provider. All services are provided solely by the Local, and L&T assumes no responsibility or liability in relation to such services.

b. The services offered through the Mobile Application do not constitute professional tourist guiding services. Locals are individuals who share their personal knowledge and experiences. Where services are provided on a professional basis, L&T shall take the measures required under applicable law to the extent permitted by legislation.

c. The Mobile Application is a platform designed to facilitate the sharing of experiences and the publication of service listings by its users. Unless identity verification is specifically requested, L&T does not verify or guarantee the identity, qualifications, licenses, or credentials of its members.

d. To the fullest extent permitted by applicable law, and without prejudice to any mandatory statutory liability, L&T shall not be liable for any direct, indirect, incidental, or consequential loss or damage arising from access to or use of the Mobile Application, the services provided by the Local, or any dispute, breach, negligence, unlawful act, interruption, error, omission, or other matter relating to the relationship between the Local and the Traveler. L&T shall not be responsible for the acts or omissions of the Local or any other member.

e. Where L&T becomes aware that content provided by the Local or any other member is unlawful, L&T shall, in accordance with applicable legislation, act without undue delay by removing or disabling access to such content and, where required, notifying the relevant member and the competent public authorities with the reasons for its decision. L&T shall also provide an easily accessible electronic notice mechanism for reporting allegedly unlawful content.

13. Amendments to the Agreement

a. L&T reserves the right to amend or modify these Terms of Use at any time to ensure the continuity of its services, address technical requirements, or comply with applicable legislation. Any amendments shall be published through the internal communication system with the updated revision date and, where deemed appropriate, notified to members by email or mobile notification for their acceptance. Unless otherwise required by applicable law, the amended Terms of Use shall enter into force fifteen (15) days after notification to the members, and continued use of the Mobile Application or its services after such date shall be subject to the revised Terms.

14. Dispute Resolution

a. These Terms of Use shall be governed by and construed in accordance with the laws of the Republic of Estonia. Any dispute arising out of or in connection with these Terms of Use shall be subject to the exclusive jurisdiction of the Harju County Court in Tallinn, Estonia.

b. In the event of any dispute arising out of or relating to these Terms of Use, L&T's records, including electronic records such as computer logs and audio recordings, may be submitted as evidence to the extent permitted by applicable law.

15. Termination of the Agreement

a. L&T may terminate these Terms of Use and cancel a Member's account with immediate effect if the Member breaches any provision of these Terms of Use or if L&T reasonably suspects that such a breach has occurred.

b. In addition to Section 13.1 above, L&T may terminate these Terms of Use if five (5) years have elapsed since the Member's last transaction on the Mobile Application.

c. A Member may terminate these Terms of Use and close his/her account at any time by providing notice to L&T.

d. If any reservation or payment is completed after the effective date of termination, the Local shall be entitled only to the payment relating to the relevant service, less any applicable commission fees payable to L&T.

16. Entry into Force

a. This Agreement enters into force upon electronic acceptance by the Local, and such acceptance shall be deemed as full acknowledgment and understanding of all provisions.

Privacy Notice

1. Introduction

Welcome to Local & Traveler.

This Privacy Notice has been prepared to explain how your personal data is collected, used, shared, stored, and protected when you use the Local & Traveler website, mobile application, and all related services.

At Local & Traveler, we are committed to protecting your privacy and safeguarding your personal data. We process your personal data in accordance with the applicable European Union data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Digital Services Act ("DSA"), applicable electronic communications and cookie regulations, and other relevant legal requirements.

This Privacy Notice applies to:

Individuals who visit our website;
Users of our mobile application;
Locals offering services through the platform;
Travelers making reservations through the platform;
Individuals using our customer support services;
Individuals receiving marketing communications; and
All other natural persons whose personal data is processed in connection with our services.

Where additional privacy information is required for specific services or features of the Platform, such information will be provided to you at the time your personal data is collected.

For the purposes of this Privacy Notice, the following terms shall have the meanings set out below unless the context requires otherwise:

User means any natural person who visits, uses, creates an account on, or otherwise interacts with the Platform for any purpose.

Traveler means a User who browses, books, purchases, or benefits from services offered by a Local through the Platform.

Local means any natural or legal person who offers experiences, activities, or other services through the Platform.

Platform means the website, mobile application, and all related digital services operated by Local & Traveler.

Services means reservation services, experience-sharing services, activity organization, communication services, payment services, user interaction features, and all other services made available through the Platform.

Personal Data means any information relating to an identified or identifiable natural person.

Processing means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, sharing, dissemination, restriction, erasure, anonymization, or any other form of processing.

Controller means the natural or legal person that determines the purposes and means of the processing of Personal Data.

Processor means a natural or legal person that processes Personal Data on behalf of the Controller and in accordance with its instructions.

Service Provider means any third-party natural or legal person providing services on behalf of Local & Traveler for the operation, maintenance, development, or support of the Platform.

Business Partner means any natural or legal person collaborating with Local & Traveler in connection with the provision of certain services or commercial activities relating to the Platform.

Third Party means any natural or legal person other than Local & Traveler, the Traveler, or the Local.

Public Authority means courts, law enforcement authorities, regulatory and supervisory authorities, and any other competent public authority to whom Personal Data may be disclosed where required by applicable law.

Cookies and Similar Technologies means cookies, software development kits (SDKs), pixel tags, local storage technologies, and similar technologies used to operate the Platform, remember user preferences, measure performance, enhance security, and improve the user experience.

Profiling means any form of automated processing of Personal Data used to evaluate certain personal aspects of a User in order to provide personalized services, recommendations, improve Platform security, or enhance the overall user experience.

Applicable Data Protection Laws means the General Data Protection Regulation (GDPR), together with all other applicable European Union legislation and national laws relating to data protection, privacy, electronic communications, and online platform services.

2. About the Data Controller

The Controller responsible for the processing of your Personal Data under this Privacy Notice is:

Data Controller: LOCAL AND TRAVELER OÜ (hereinafter referred to as the "Company" or "L&T").

Registered Address: Ahtri tn 12, Kesklinna linnaosa, Tallinn, Harju maakond, 15551, Estonia

If you have any questions regarding the processing of your Personal Data or this Privacy Notice, or if you wish to exercise your rights under the GDPR, you may contact us using the contact details provided above.

Upon receiving your request, we will review and respond to it within the time limits prescribed by the applicable data protection laws. Where necessary, we may request additional information to verify your identity or to enable us to process and respond to your request appropriately.

3. Who Does This Privacy Notice Apply To?

This Privacy Notice applies to all natural persons whose Personal Data is processed in connection with the website, mobile application, and related services provided by L&T.

In particular, this Privacy Notice applies to:

Travelers who search for, book, purchase, or receive services through the Platform;
Locals who offer or intend to offer services through the Platform;
Individuals who visit our website or use our mobile application;
Users who create an account or register on the Platform;
Users participating in identity verification processes;
Individuals who contact our customer support services;
Individuals who choose to receive marketing communications, newsletters, promotional offers, or other announcements;
Users who participate in surveys, submit reviews, ratings, or otherwise provide feedback regarding the Platform;
Users who upload or share photographs, videos, reviews, comments, or other content through the Platform; and
All other natural persons whose Personal Data is processed in connection with the provision of our Services.

This Privacy Notice applies solely to Personal Data processing activities carried out by L&T in its capacity as the Controller.

Where Personal Data is processed as part of a legal relationship established directly between a Local and a Traveler through the Platform, the relevant parties may also act as separate or independent controllers under the applicable data protection laws with respect to their own processing activities.

Our Platform may contain links to third-party websites, applications, or services. This Privacy Notice applies only to the Platform and Services operated by L&T. L&T is not responsible for the privacy practices or Personal Data processing activities of third parties. We therefore encourage you to review the privacy policies of those third-party websites, applications, or services before providing any Personal Data.

4. What Personal Data Do We Collect?

Depending on the nature of the Services provided through our Platform, we may collect and process the following categories of Personal Data. The Personal Data we collect may vary depending on the Services you use, your activities on the Platform, and the nature of your relationship with us.

4.1 Identity Information

We may process information used to identify you, including your first and last name, date of birth, nationality, identity card or passport details, information contained in official identification documents submitted for identity verification purposes, and, where applicable, your driver's licence information.

4.2 Contact Information

We may process your contact details, including your email address, telephone number, postal address, and any other contact information you choose to provide to us.

4.3 Account and Profile Information

We may process information relating to your user account on the Platform, including your username, profile information, biography, interests, preferred language, profile photograph, verified account status, and account settings.

4.4 Reservation and Service Information

We may process information relating to reservations you make and the Services you receive or provide through the Platform. This may include reservation dates, service details, trip information, availability information, cancellation records, requests, complaints, and customer support records.

4.5 Location Information

We may process your location information where necessary to provide our Services or enable certain Platform features. This may include travel routes, locations where Services are provided, and, where you have granted permission, your device's real-time location data.

4.6 Identity Verification Information

Where you request account verification or where identity verification is required by applicable law, we may process information contained in identity cards, passports, driver's licences, or similar official documents, including images of such documents.

4.7 Device and Usage Information

To ensure the security of the Platform, improve its performance, and provide our Services, we may process your IP address, device information, operating system details, application usage records, session information, log files, browser information, and similar technical data.

4.8 Payment and Financial Information

We may process information relating to payments made through the Platform. As payment transactions are securely processed by authorized payment service providers, your payment card details may not be stored directly by us. However, we may process transaction identifiers, payment status, payment amounts, and other payment-related information.

4.9 Communications and Support Records

We may process correspondence between you and us, customer support requests, complaints, feedback, and call records for the purposes of improving our Services, responding to your requests, and complying with our legal obligations.

4.10 Reviews and User Content

We may process reviews, ratings, comments, photographs, videos, audio recordings, and other content that you upload or share through the Platform. Depending on your preferences and the nature of the content, such information may be visible to other users.

4.11 Marketing and Preference Information

We may process your marketing consents, communication preferences, interests, campaign participation records, survey responses, and preferences relating to our Services.

4.12 Professional and Service-Related Information

Where you provide Services professionally through the Platform, we may process your professional qualifications, licences, permits, service-related documentation, and, where applicable, information relating to vehicle ownership or authorization to operate a vehicle.

In all cases, we process only the Personal Data that is necessary to provide our Services, comply with our legal obligations, or achieve the purposes described in this Privacy Notice. We are committed to processing your Personal Data in accordance with the principle of data minimization and only to the extent necessary for the relevant processing purposes.

5. How Do We Collect Your Personal Data?

We may collect your Personal Data from different sources in order to provide our Services, perform our contractual obligations, comply with applicable legal requirements, and improve the Platform.

5.1 Personal Data You Provide Directly

We collect a significant portion of your Personal Data directly from you. For example, we may collect Personal Data when you:

Create an account on the Platform;
Create or update your profile;
Make a reservation or provide a Service;
Complete identity verification procedures;
Contact our customer support team;
Submit reviews, ratings, or comments;
Upload photographs, videos, or other content;
Participate in surveys; or
Manage your marketing communication preferences.

5.2 Personal Data Collected Automatically

When you use our Platform, certain information may be generated or collected automatically. This may include:

Your IP address;
Device information;
Operating system and application version;
Session information;
Usage statistics;
Error logs;
Security logs; and
Technical information collected through cookies and similar technologies.

We use this information to ensure the security of the Platform, resolve technical issues, improve performance, and enhance our Services.

5.3 Personal Data Obtained from Other Users

Due to the nature of our Platform, certain Personal Data relating to you may be provided by other users. For example, this may occur through:

Reservations made by a Traveler;
Service information provided by a Local;
Communications exchanged between users; and
Reviews and ratings submitted by users.

5.4 Personal Data Obtained from Third Parties

Where necessary to provide our Services, we may obtain certain Personal Data from trusted third parties. These may include:

Identity verification service providers;
Payment service providers;
Analytics and security service providers;
Cloud service providers; and
Social media platforms, where you choose to register or sign in using your social media account and authorize the sharing of your information.

Any Personal Data obtained from third parties will be processed solely for the purposes described in this Privacy Notice or as otherwise permitted by applicable law.

5.5 Cookies and Similar Technologies

We use cookies, software development kits (SDKs), pixel tags, and similar technologies on our Platform. These technologies are used to:

Ensure the proper operation of the Platform;
Enhance security;
Remember your preferences;
Analyze the use of our Services;
Measure Platform performance; and
Improve your overall user experience.

For more detailed information about our use of cookies and similar technologies, please refer to our Cookie Policy.

5.6 Meta Pixel (Facebook Pixel)

Our website uses the Meta Pixel, a marketing and analytics technology provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) ("Meta"). The Meta Pixel places cookies and similar identifiers in your browser and collects information such as your IP address, browser and device information, the pages you visit on our website, and actions you take (for example, viewing our pre-registration page).

We use the Meta Pixel to measure the effectiveness of our advertising, understand how visitors interact with our website, and deliver and optimize advertisements on Meta's platforms (such as Facebook and Instagram). The information collected may be shared with Meta, which may combine it with other data it holds. In connection with this processing, L&T and Meta may act as joint controllers for certain operations. Depending on Meta's own operations, some data may be transferred to and processed in countries outside the European Economic Area, subject to appropriate safeguards such as the EU Standard Contractual Clauses.

Legal basis and consent. The Meta Pixel is a non-essential technology. We rely on your consent (Article 6(1)(a) GDPR and applicable ePrivacy rules) as the legal basis for using it. The Meta Pixel is not loaded and sets no cookies unless and until you give your consent through the cookie banner presented when you first visit the website. If you decline, the Meta Pixel is not activated and no data is sent to Meta.

Withdrawing your consent. You may withdraw your consent at any time, with effect for the future. To do so, clear your browser's site data / cookies for this website (which resets your choice and causes the consent banner to appear again on your next visit), or use the cookie settings option if provided. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

For more information about how Meta processes personal data, please see Meta's Privacy Policy at https://www.facebook.com/privacy/policy and its information on the Meta Pixel.

6. For What Purposes and on What Legal Bases Do We Process Your Personal Data?

We process your Personal Data only for specific, explicit, and legitimate purposes. Each processing activity is based on at least one of the lawful bases for processing provided under the GDPR.

The table below summarizes the purposes for which we process your Personal Data, the categories of Personal Data that may be processed, and the corresponding legal basis under the GDPR.

Purpose of Processing	Categories of Personal Data	Legal Basis (GDPR)
Creating and managing user accounts	Identity Information, Contact Information, Account and Profile Information	Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b))
Verifying Platform membership and ensuring account security	Identity Information, Account Information, Device and Usage Information	Performance of a contract (Art. 6(1)(b)) and Legitimate Interests (Art. 6(1)(f))
Managing reservation processes	Identity Information, Reservation Information, Contact Information	Performance of a contract (Art. 6(1)(b))
Facilitating communication between Locals and Travelers	Identity Information, Contact Information, Reservation Information	Performance of a contract (Art. 6(1)(b))
Processing payments and maintaining transaction records	Identity Information, Payment Information, Reservation Information	Performance of a contract (Art. 6(1)(b)) and Compliance with a legal obligation (Art. 6(1)(c))
Providing customer support and responding to inquiries	Identity Information, Contact Information, Support Records	Performance of a contract (Art. 6(1)(b)) and Legitimate Interests (Art. 6(1)(f))
Carrying out identity verification procedures	Identity Verification Information, Identity Information	Performance of a contract (Art. 6(1)(b)), Compliance with a legal obligation (Art. 6(1)(c)), or Legitimate Interests (Art. 6(1)(f))
Verifying the qualifications of Locals providing professional services	Professional Information, Identity Information, Licence and Permit Information	Compliance with a legal obligation (Art. 6(1)(c)) and Legitimate Interests (Art. 6(1)(f))
Preventing fraud, ensuring Platform security, and detecting misuse	Identity Information, Device and Usage Information, Reservation Information, Support Records	Legitimate Interests (Art. 6(1)(f)) and, where applicable, Compliance with a legal obligation (Art. 6(1)(c))
Maintaining Platform security, resolving technical issues, and improving performance	Device and Usage Information, Log Files, IP Address	Legitimate Interests (Art. 6(1)(f))
Improving service quality and enhancing the user experience	Usage Information, Reservation Information, Reviews, Survey Responses	Legitimate Interests (Art. 6(1)(f))
Publishing user reviews, ratings, and feedback	Profile Information, Reviews, User Content	Performance of a contract (Art. 6(1)(b)) and Legitimate Interests (Art. 6(1)(f))
Providing personalized recommendations and personalizing the Platform	Profile Information, Reservation History, Interests, Usage Information	Legitimate Interests (Art. 6(1)(f))
Providing location-based services	Location Information	Performance of a contract (Art. 6(1)(b)); where real-time device location is required, your Consent (Art. 6(1)(a))
Sending marketing communications	Identity Information, Contact Information, Marketing Preferences	Consent (Art. 6(1)(a)) or, where permitted by applicable law, other lawful bases
Complying with legal obligations	Identity Information, Financial Information, Reservation Information, Legal Information	Compliance with a legal obligation (Art. 6(1)(c))
Resolving legal disputes and establishing, exercising, or defending legal claims	All relevant categories of Personal Data	Legitimate Interests (Art. 6(1)(f)) or Compliance with a legal obligation (Art. 6(1)(c))

For every processing activity, we process only the Personal Data that is necessary to achieve the relevant purpose and always apply the principle of data minimization.

Where we process your Personal Data based on your consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before such withdrawal.

Where we process your Personal Data on the basis of our legitimate interests, you have the right to object to such processing under the GDPR. Upon receiving an objection, we will reassess the relevant processing activity by balancing our legitimate interests against your fundamental rights and freedoms.

7. Who Do We Share Your Personal Data With?

We may share your Personal Data with third parties only where necessary to achieve the purposes described in this Privacy Notice, comply with our legal obligations, or pursue our legitimate business interests.

Your Personal Data may be shared with the following categories of recipients:

7.1 Other Platform Users

Due to the nature of our Platform, certain Personal Data may be shared with other users where necessary to facilitate reservations and the provision of Services. For example:

with the relevant Local in connection with a reservation made by a Traveler; or
with the relevant Traveler in connection with Services provided by a Local.

In each case, only the Personal Data necessary for the performance of the relevant Service will be shared.

7.2 Payment Service Providers

Where necessary to process payments securely, your Personal Data may be shared with authorized payment service providers, financial institutions, and payment infrastructure providers. Your payment card details may be processed directly by the relevant payment service provider through its secure payment infrastructure and may not be stored directly by us.

7.3 Our Service Providers

To operate the Platform and provide our Services, we may share your Personal Data with:

Cloud service providers;
Hosting service providers;
Information technology and software providers;
Customer support service providers;
Communication service providers;
Identity verification service providers;
Data storage and backup providers; and
Analytics and security service providers.

These service providers process your Personal Data solely on our behalf and in accordance with our instructions. Our service providers may change from time to time. An up-to-date list of our service providers, processors, and sub-processors may be made available upon request, where appropriate.

7.4 Business Partners

We may share your Personal Data with our business partners where necessary to provide specific Services through the Platform. Such disclosures are limited to the extent necessary for the provision of the relevant Services.

7.5 Professional Advisers

Where necessary to protect our rights, conduct legal proceedings, or comply with legal obligations, we may share your Personal Data with:

Lawyers;
Law firms;
Independent auditors;
Tax advisers and accountants; and
Professional consultants.

7.6 Competent Public Authorities

Where required by law or in response to lawful requests from competent public authorities, we may disclose your Personal Data to:

Courts;
Law enforcement authorities;
Regulatory and supervisory authorities;
Tax authorities; and
Data protection authorities,

or any other competent public authority, where required under applicable law.

7.7 Corporate Transactions

In the event of a corporate restructuring, merger, acquisition, sale of assets, financing transaction, or similar corporate event, your Personal Data may be disclosed to the relevant parties to the extent legally necessary. In such circumstances, appropriate contractual, technical, and organizational safeguards will be implemented to protect your Personal Data.

We do not sell your Personal Data to third parties.

Whenever we share your Personal Data, we disclose only the information necessary for the relevant purpose, apply the principle of data minimization, and implement appropriate contractual, technical, and organizational safeguards to ensure that all recipients process your Personal Data securely and in accordance with applicable data protection laws.

8. International Transfers of Your Personal Data

As part of the operation of our Platform and the provision of our Services, your Personal Data may be transferred to our service providers, affiliated companies, business partners, or other recipients located outside your country of residence.

Where your Personal Data is transferred outside the European Economic Area ("EEA"), such transfers will be carried out in accordance with Chapter V of the GDPR.

Where the European Commission has adopted an Adequacy Decision in respect of the destination country, your Personal Data may be transferred on the basis of that decision.

Where no Adequacy Decision exists, your Personal Data will be transferred only where one or more of the appropriate safeguards provided under Article 46 GDPR have been implemented. These safeguards may include:

The Standard Contractual Clauses (SCCs) adopted by the European Commission;
Binding Corporate Rules (BCRs), where applicable; or
Any other appropriate transfer mechanism recognized under applicable data protection laws.

In addition, we implement appropriate technical and organizational measures to ensure the confidentiality, integrity, and security of your Personal Data during international transfers. Depending on the circumstances, these measures may include:

Encryption of Personal Data;
Access control mechanisms;
Data minimization practices;
Contractual confidentiality obligations;
Information security policies;
Maintenance of access logs; and
Regular security testing and audits.

Where appropriate, we may also conduct transfer risk assessments and implement supplementary safeguards to ensure that international transfers provide an adequate level of protection for your Personal Data.

If you would like further information regarding our international data transfer practices or the safeguards we apply, you may contact us using the contact details provided at the end of this Privacy Notice.

9. How Long Do We Retain Your Personal Data?

We retain your Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Notice, perform our contractual obligations, comply with applicable legal obligations, resolve disputes, establish, exercise or defend legal claims, and pursue our legitimate business interests.

When determining the appropriate retention period for your Personal Data, we take into account the following criteria:

The purpose for which the Personal Data was collected and processed;
The nature of the Services provided;
The contractual relationship between the parties;
Applicable European Union legislation and national laws;
Tax, accounting, and other statutory record retention requirements;
Potential legal disputes and applicable limitation periods; and
Information security requirements and fraud prevention considerations.

The table below sets out the general retention periods applicable to different categories of Personal Data.

Category of Personal Data	General Retention Period
Account and Profile Information	Retained for as long as your account remains active or until you request its deletion. Where required by law or justified by our legitimate interests, certain information may be retained for a longer period.
Reservation and Service Information	Retained after completion of the relevant reservation for the period required under applicable laws and as necessary to address potential legal claims.
Payment and Financial Information	Retained for the period required under applicable tax, accounting, financial reporting, and other legal obligations.
Identity Verification Information	Retained until the identity verification purpose has been fulfilled or for the period required under applicable laws.
Customer Support Records	Retained for a reasonable period to enable us to respond to your requests, improve our Services, and manage potential legal claims.
Reviews, Ratings, and User Content	Retained while the relevant content remains published on the Platform or while your account remains active. Such content may be removed, anonymized, or deleted upon request, account closure, or where required by applicable law.
Marketing Data and Communication Preferences	Retained until you withdraw your consent, object to receiving marketing communications, or until the relevant processing purpose no longer exists.
Device, Usage, and Security Information	Retained for a reasonable period necessary to ensure Platform security, monitor system performance, prevent fraud, and comply with applicable legal obligations.
Legal Records and Dispute-Related Information	Retained until the relevant legal proceedings have been concluded and any applicable limitation periods have expired.

Once the applicable retention period has expired, or where there is no longer a lawful basis for processing your Personal Data, your Personal Data will be deleted, anonymized, or otherwise securely disposed of in accordance with applicable data protection laws.

In certain circumstances, we may retain your Personal Data for longer periods where necessary to comply with legal obligations, prevent fraud, maintain information security, establish, exercise or defend legal claims, or respond to ongoing legal proceedings.

We are committed to ensuring that your Personal Data is not retained for longer than necessary and that all retention practices comply with the principles of data minimization and storage limitation under the GDPR.

10. Automated Decision-Making, Profiling, and Recommendation Systems

To enhance Platform security, improve the quality of our Services, and provide a better user experience, Local & Traveler may use automated processing, recommendation systems, and limited profiling activities. These activities are intended to ensure that the Platform operates in a secure, efficient, and user-focused manner for both Travelers and Locals.

Automated Processing for Travelers

To provide Travelers with a more personalized experience, we may use automated processing to:

Recommend Locals and experiences based on your interests and preferences;
Rank search results according to your search criteria and selected filters;
Suggest Services based on your location or the destination you are searching for;
Recommend experiences based on your previous reservations and Platform activity;
Detect unusual account activity in order to protect Platform security; and
Identify fraud, abuse, and other security risks.

Automated Processing for Locals

To improve the quality and reliability of the Platform, we may also apply certain automated processing activities relating to Locals. These activities may include:

Ranking Services within search results;
Displaying Services based on selected filtering criteria;
Highlighting recommended service providers based on objective factors such as user reviews, reservation history, profile completeness, service quality, and similar criteria;
Detecting fake accounts, fraudulent activity, or other security risks; and
Conducting security analyses to identify activities that may violate our Platform Rules or applicable laws.

Our ranking and recommendation systems may consider objective criteria such as users' search preferences, the location where the Service is offered, availability, user reviews, reservation history, profile completeness, and similar relevant factors.

Where required by applicable law, you have the right to obtain further information regarding the logic involved in these automated processing activities and, where applicable, to exercise your rights under Articles 21 and 22 of the GDPR.

11. Platform Security, Trust, and Community Protection

Local & Traveler is committed to providing a safe, transparent, and trustworthy Platform for all users. To protect our Platform, prevent fraud, enforce our Platform Rules, and safeguard the rights and interests of our users, we may process your Personal Data for security and trust purposes.

Such processing may include:

Identifying fake or unverified accounts;
Protecting the security of user accounts;
Detecting unusual or suspicious account activity;
Preventing fraud, identity theft, spam, abuse, and other security threats;
Identifying activities that may violate applicable laws, our platform rules, or our terms of use;
Investigating complaints submitted by users;
Reviewing platform content and user conduct to ensure compliance with applicable laws, community standards, and our terms of use; and
Protecting our information systems against unauthorized access and other cybersecurity threats.

For these purposes, we may process Identity Information, Account Information, Device and Usage Information, IP addresses, security logs, reservation information, user-generated content, communications, and complaint records.

Messages exchanged between users through the Platform and other communications may be processed automatically for the purpose of providing our Services. In addition, where reasonably necessary to ensure Platform security, investigate fraud, respond to user complaints, comply with legal obligations, or investigate suspected violations of our Terms of Use or applicable law, we may review relevant communications in a limited, proportionate, and lawful manner.

These processing activities are primarily based on our legitimate interests in maintaining a secure and trustworthy Platform and, where applicable, on our legal obligations under relevant laws.

Local & Traveler implements appropriate technical and organizational measures to safeguard Personal Data and regularly assesses the potential impact of these activities on the rights and freedoms of users.

12. Public Content and User-Generated Content

Certain features of our Platform are designed to enable users to share information publicly. Depending on your choices, the following information may be visible to other users:

Your profile information;
Profile photograph;
Biography;
Descriptions of the services you provide;
Photographs and videos relating to your services;
Reviews;
Ratings;
Comments; and
Any other content that you voluntarily choose to make available through the platform.

Such information may be displayed to other users where necessary for the operation of the Platform and the provision of our Services.

Any information you choose to make publicly available may be viewed, shared, or, where permitted by applicable law, accessed by third parties. We therefore encourage you to exercise caution before publishing Personal Data or other content through the Platform.

Even if you close your account or delete certain content, we may retain limited copies where necessary to comply with legal obligations, resolve disputes, prevent fraud, protect the rights of other users, or otherwise as permitted or required by applicable law.

13. Users Under the Age of 18

Our Platform is not intended for individuals under the age of 18. Individuals under the age of 18 are not permitted to create an account, make reservations, or offer Services through the Platform.

If we become aware that we have collected or processed Personal Data relating to an individual under the age of 18 without an appropriate legal basis, we will take reasonable steps to delete or anonymize such Personal Data without undue delay.

If you are a parent or legal guardian and believe that a person under the age of 18 has provided us with Personal Data in violation of this Privacy Notice or applicable law, please contact us using the contact details provided at the end of this Privacy Notice.

14. Security of Your Personal Data

We implement appropriate technical and organizational measures to protect the confidentiality, integrity, and availability of your Personal Data.

Taking into account the nature of the risks, the scope of the processing activities, technological developments, and applicable legal requirements, these measures may include, where appropriate:

Access control and authorization mechanisms;
Identity verification procedures;
Encryption of personal data;
Firewalls and network security solutions;
Logging and monitoring of system activities;
Regular security testing and risk assessments;
Data backup and business continuity measures;
Privacy and information security training for our personnel;
Data protection and confidentiality agreements with our processors and service providers; and
Restricting access to personal data on a need-to-know basis.

However, no method of transmitting data over the internet or storing electronic data can be guaranteed to be completely secure. We therefore encourage all users to protect the confidentiality of their account credentials, use strong passwords, and notify us immediately if they suspect any unauthorized access to their account.

Where a Personal Data breach occurs that is likely to affect the rights and freedoms of individuals, we will comply with our obligations under applicable data protection laws, including notifying the competent supervisory authority and, where required, the affected individuals.

15. Your Rights

Subject to the applicable data protection laws, you may have the following rights regarding your Personal Data:

to obtain confirmation as to whether we process your Personal Data;
to request access to your Personal Data;
to request the rectification of inaccurate or incomplete Personal Data;
to request the erasure of your Personal Data under certain circumstances;
to request the restriction of processing under certain circumstances;
to receive your Personal Data in a structured, commonly used, and machine-readable format and to request its transmission to another controller where technically feasible;
to object to processing based on our legitimate interests;
to object at any time to the processing of your Personal Data for direct marketing purposes;
to withdraw your consent at any time where processing is based on your consent, without affecting the lawfulness of processing carried out before such withdrawal; and
where applicable, not to be subject solely to a decision based on automated processing, including profiling, and to request human intervention, express your point of view, and contest such a decision.

These rights are not absolute and may be subject to the conditions, exceptions, and limitations provided under applicable data protection laws.

If you wish to exercise any of your rights, you may contact us using the contact details provided in this Privacy Notice.

16. Right to Lodge a Complaint with a Supervisory Authority

If you believe that your Personal Data has been processed in violation of applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority in the country of your habitual residence, your place of work, or the place where the alleged infringement occurred, in accordance with Article 77 of the GDPR.

Before contacting a supervisory authority, we encourage you to contact us first so that we have the opportunity to address your concerns promptly and efficiently. However, this does not affect or limit your right to lodge a complaint with a competent supervisory authority at any time.

17. Contact Us

If you have any questions, requests, or concerns regarding this Privacy Notice or the processing of your Personal Data, or if you wish to exercise your rights under applicable data protection laws, you may contact us using the contact details below.

Local & Traveler OÜ

Registered Address: Ahtri tn 12, Kesklinna linnaosa, Tallinn, Harju maakond, 15551, Estonia

Your request will be reviewed and responded to within the time limits prescribed by the applicable data protection laws. Where necessary, we may request additional information to verify your identity or to enable us to properly assess and process your request.

Cancellation and Refund Policy

L&T provides guidance to its users regarding cancellations and refunds in order to protect the rights and legitimate interests of all parties. Appropriate measures have been implemented to ensure that Travelers can easily exercise their cancellation rights through the Mobile Application.

Pursuant to Article 16 of Directive 2011/83/EU of the European Parliament and of the Council, the right of withdrawal does not apply to contracts relating to accommodation (other than for residential purposes), transport of goods, vehicle rental services, catering services, or leisure activities where the contract provides for a specific date or period of performance.

Accordingly, Travelers may cancel their bookings and request refunds under the following conditions:

If the Local cancels the booked service before its performance, the Traveler shall receive a full refund of all amounts paid.
If the Traveler cancels at least forty-eight (48) hours before the scheduled start of the service, the Traveler shall receive a full refund. If the cancellation is made between twenty-four (24) and forty-eight (48) hours before the scheduled start of the service, fifty percent (50%) of the amount paid shall be refunded. No refund shall be made for cancellations submitted less than twenty-four (24) hours before the scheduled start of the service.
If the Local fails to provide the agreed service without a valid cancellation, the Traveler shall receive a full refund of the amount paid.
Any approved refund shall be processed within fourteen (14) days and credited to the credit card or debit card used by the Traveler for the original payment.

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