Privacy Policy

The data controller for SHOUTR is:
GOOMIO Oy
Y-tunnus / Business ID: 3575343-2
Veturitie 20
00520 Helsinki, Finland
Contact: info@goomio.fi

GOOMIO Oy has not appointed a statutory Data Protection Officer. The address above is the controller's contact point for privacy matters.

SHOUTR is a live local social space for adults. You can join the local public conversation (LIVE), discover people nearby when you want to, message privately, and optionally use WILD, an 18+ mode inside Discover. Dating and flirting are possibilities inside SHOUTR — not the definition of it.

Depending on how you use SHOUTR, the following categories may be processed:

• Account information and login identifiers, such as a phone number or other sign-in identifier.
• Age and age-assurance status (see section 06).
• Profile information and profile/discovery preferences you choose.
• Photos and media: profile gallery, Private Album, and My Vault content.
• Location and proximity data used to show what is happening around you.
• LIVE content you post publicly to your local area.
• Private messages and Flash interactions.
• Saved / Favorites lists and Private Album access permissions you grant or receive.
• Reports, moderation records and related context.
• Device and app technical information needed for security and reliability.
• Purchase and entitlement information relating to the 24H Wristband.
• Support communications you send us.

Service providers are used in the following categories: authentication / OTP, backend, database and storage, payments, push notifications, and analytics if it is ever introduced. TODO — provider names, the data types each one processes and their location / transfer basis are added once the technical stack is locked, before launch

• Providing the service and its core features.
• Authentication and account security.
• Local discovery and proximity-based functionality.
• Communication between users.
• Safety, moderation and handling reports.
• Fraud and abuse prevention.
• Customer support.
• Legal compliance.
• Payments and premium entitlement (24H Wristband).
• Service security and reliability.
• Optional analytics, only if introduced later and only on the basis described in section 12.

We rely on: performance of a contract (providing SHOUTR to you); legitimate interests (safety, abuse prevention, security, service improvement); legal obligation (responding to lawful requests, accounting); and consent where required — for example optional analytics, certain notifications, and features you explicitly opt into such as WILD. You can withdraw consent at any time; withdrawal does not affect processing already carried out.

SHOUTR is for adults aged 18 and over. We may use an age-assurance or verification service to confirm eligibility. Entering a birth year on its own is not treated as verified age.

Our target model is that SHOUTR receives only a status confirmation — for example “18+ verified” — together with the time of verification and, where needed, a verification reference or method identifier. Images of identity documents are not stored in SHOUTR's own systems where the check can be completed without them.

TODO — age-assurance provider is TBD and confirmed before launch

SHOUTR is location-based: your approximate location is used to show local LIVE content and nearby people. Your exact GPS position is not shown to other users. Discover works on an approximate, fuzzed location and other users see an approximate distance, not coordinates.

TODO — exact rounding method, technical resolution and storage are locked in the backend phase

SHOUTR keeps three separate media layers. Your profile gallery follows your profile and discovery visibility. Your Private Album is private: another user can request access, and only you can approve it. Access may later be temporary and revocable. My Vault is personal storage visible only to you; nothing in it appears on your profile or Private Album automatically, and you decide if and when to send something in a private chat.

Buying a 24H Wristband never overrides another person's consent. It does not unlock anyone's Private Album, and it does not reveal a Mystery profile.

SHOUTR is intentionally designed so that old private conversations do not stay forever. When a conversation has been inactive long enough, it moves into an expiring state and a 24-hour countdown starts. A new message cancels the countdown. If neither person resumes it, the normal user-facing conversation disappears. Saving or favouriting a person does not preserve chat history — it only makes that person easier to find again.

We cannot promise that every trace is immediately erased from every system. Safety and abuse prevention, reported-content evidence, security backups, dispute handling and legal obligations may require limited retention for a period.

TODO — the inactivity threshold before the countdown, and the backup cycle, are confirmed against the chosen backend before the final version of this policy

Private chats are not available for casual staff browsing. If you report content or another user, limited relevant content and context may be preserved and made available for moderation and safety review. We may also process content where required to investigate abuse, prevent fraud or security incidents, or to respond to lawful requests from authorities.

We share data with service providers acting as processors on our behalf — for example hosting, authentication, payments, media storage, push notifications and age assurance — strictly as needed to run SHOUTR. We may also disclose data to authorities where legally required.

We prefer EU/EEA regions where possible. If personal data is transferred outside the EEA, the actual applicable transfer mechanism and safeguards are stated here.

TODO — final processor list, locations and transfer mechanisms are published before launch

This website runs on a necessary-only basis. No analytics or marketing technologies are in use. Analytics is not treated as necessary for providing the service. If non-essential analytics or marketing tracking is added later, a consent mechanism is implemented at that point and those categories stay off until you switch them on. You can review your choices in Cookie Settings.

We keep personal data only as long as needed for the purpose it was collected for, or as long as required by law. The principles we apply per category:

• Account, profile and media — for the lifetime of the account, then through the deletion process.
• Location — only as long as needed to deliver local functionality.
• Private chats — according to the SHOUTR chat lifecycle and its expiring state.
• LIVE content — final retention period TBD.
• Report and moderation evidence — for as long as the safety and moderation need exists.
• Support requests — retention defined before launch.
• Backups — according to the actual backup cycle of the backend.
• Payment and accounting records — for the period required by applicable law.

TODO — concrete periods for LIVE content and support requests are set before launch

Under the GDPR you can request:

• Access to your personal data.
• Correction of inaccurate data.
• Deletion of your data (see Delete Your Account).
• Restriction of processing.
• Objection to processing based on legitimate interests.
• Data portability, where applicable.
• Withdrawal of consent, where processing is based on consent.

You can also lodge a complaint with your local supervisory authority. In Finland this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto).

Send rights requests to info@goomio.fi.

We use technical and organisational measures appropriate to the risk, including access controls and encryption in transit. No service can guarantee absolute security, and we do not claim otherwise.

SHOUTR is not for anyone under 18. We do not knowingly process data of minors. If we learn that an account belongs to a minor, we will close it.

We may update this policy as the product and its providers are finalised. Material changes will be communicated in the app or on this page.