1. Information collected

Information the user provides directly:

• Username, display name, email address and password (stored hashed only).
• When signing in through Google or Apple: only the account identifier held by the provider and the verified email are stored; if the provider did not supply a verified email, no address is stored at all.
• Interface language, notification settings, referral code and the details of whoever invited the user.
• Interests, preferred event categories, and the "I'm Play" profile (level, positions, weekly availability by hour).

Information collected from other users:

• Ratings received after events.
• An invitation to an event by an organiser (including recording the name of a guest who has no account).

Information collected automatically:

• Location data (in order to show events near the user).
• Usage data by means of Firebase.
• The device advertising identifier (IDFA on iOS, Advertising ID on Android), used to display advertising.

2. Purposes of processing

Information is collected and processed for these purposes only:

• Operating the application and displaying relevant events.
• Managing the user's account and verifying identity.
• Improving the user experience and personalisation.
• Sending notifications and updates (subject to the user's consent).
• Securing the system and preventing misuse.
• Displaying advertising to users who are not Premium subscribers.

3. Sharing with third parties

The application uses external providers:

Advertising is supplied by Google AdMob and is not shown to Premium subscribers. In the European Economic Area and the United Kingdom the user is asked, before any advertisement loads, whether advertising may be personalised; elsewhere advertising is personalised by default. On iOS, personalisation additionally depends on the permission granted in Apple's App Tracking Transparency prompt.

The application does not sell personal information to third parties for advertising purposes.

4. Payments and financial information

The application does not accept credit card payments and does not store any payment details, other than two financial flows:

• Premium subscription - carried out entirely through the Apple App Store or Google Play. Signing up, renewal, cancellation and refunds are managed by the provider alone.
• Ticket purchase / booking a place - the user pays the ticket seller or the venue directly. TONIKA is not a party to the settlement and does not see the amounts charged.

5. User rights

Under the Protection of Privacy Law, every user has the following rights:

• Access - to review the personal information held about them.
• Correction - to request correction of information that is wrong, incomplete or out of date.
• Deletion - to request deletion of their account and their information.

Under the Protection of Privacy Regulations (Provisions Regarding Data Transferred to Israel from the European Economic Area), a database owner shall delete information at the written request of the data subject where the information is no longer necessary for the purposes for which it was created, received, accumulated or collected.

To delete an account, see Delete your account — it can be done in the application, or by writing to us.

For privacy enquiries: support@tonika.fun

6. Age restriction

The Service is intended for users aged 18 and over only. We do not knowingly collect information from users below this age.

7. Processing information of guests without a TONIKA account

7(a) Definition and scope

"Guest without an account" - a person whose name an event organiser has entered on the invitee list of a private event (such as a birthday, wedding or party), where that person has no active TONIKA account and has not given direct consent to the processing of their information.

This section applies to all information collected about a guest without an account, and sets out the legal basis, the restrictions and the protective mechanisms that apply to it.

7(b) The legal basis for processing

Processing the information of a guest without an account rests on two combined foundations:

1. Implied consent from the context of the event

Where a person attends an event, it is presumed that they consent to the disclosure of information regarding their attendance. Accordingly, a guest invited to a private event who gave their name to the organiser for the purpose of managing the invitee list may be regarded as having given implied consent to their name being recorded for that purpose alone.

2. The organiser's responsibility as the party disclosing the information

The organiser is the party who discloses the guest's information to the application. In doing so, they take upon themselves the responsibility of ensuring that:

• The guest is aware that their details have been recorded.
• The recording is done for the purpose of managing the event only.
• No information beyond what is required has been disclosed.

Restriction: implied consent does not cover any further use of the information beyond managing the invitee list. Any other use requires the guest's explicit consent.

7(c) Information that may be collected

TONIKA permits an organiser to record only the following details regarding a guest without an account:

The minimality principle: personal information shall not be processed in a database other than for the purpose lawfully established for that database. Accordingly, the guest's information shall be used solely for managing the invitee list of that specific event.

7(d) - Restrictions on processing the information

Information about a guest without an account shall not be used for the following purposes:

• Targeted advertising or marketing.
• Transfer to third parties unconnected with the event.
• Building a behavioural profile.
• Sharing with other participants in the event (beyond the invitee list visible to the organiser alone).

7(e) - The duty to inform

An approach to a person to obtain personal information for processing in a database shall be accompanied by a notice stating: the purpose for which the information is sought; the name of the controller of the database and how to contact them; to whom the information will be disclosed and the purposes of disclosure; and the existence of a right of access to the personal information and of a right to request its correction.

Accordingly, TONIKA will take the following steps:

a. Informing the organiser at the point of recording

When recording a guest without an account, a clear notice will be shown to the organiser reading: "You are recording a guest who has no TONIKA account. Their name will be used for managing the invitee list only and will be deleted automatically 90 days after the event ends. Please make sure the guest is aware of this."

b. The option of informing the guest

TONIKA will provide the organiser with the option of sending the guest a message (SMS / WhatsApp) informing them of their being recorded and setting out their rights.

7(f) - Deletion mechanism

Automatic deletion:

A database owner shall operate a mechanism intended to ensure that the database does not hold information that is no longer necessary for the purpose for which it was collected. Where a database owner finds that the database holds information that is unnecessary, they shall delete that information at the earliest possible time.

Accordingly, information about a guest without an account will be deleted automatically:

• 90 days after the date of the event - full automatic deletion.
• Immediately - upon deletion of the event by the organiser.

Deletion on request:

A database owner shall delete information at the written request of the data subject where one of the following applies: the information is no longer necessary for the purposes for which it was created, received, accumulated or collected.

A guest without an account who wishes to delete their information may contact support@tonika.fun with the event details and their name, and TONIKA will act to delete the information within 14 business days.

A database owner shall notify the data subject in writing of their decision on the request, at the earliest time possible in the circumstances.

7(g) - The organiser's responsibility

When recording a guest without an account, the organiser declares and undertakes that:

• They are authorised to record the guest's name for the purpose of managing the event.
• They will inform the guest of the recording at the first opportunity.
• They will not record sensitive information about the guest.
• They understand that a breach of these terms may impose personal liability on them under the Protection of Privacy Law.

8 - Ratings after an event

Definitions

"Rating" - a numerical score and/or tag that a user gives another participant after an event has ended, reflecting the experience of the interaction between them.

"Rated user" - the user who received the rating.

"Rating user" - the user who gave the rating.

"Aggregate score" - the average of the ratings received by the rated user, displayed on their public profile.

8(a) - The nature of the information and the legal basis

A rating a user receives from others constitutes personal information as defined in the Protection of Privacy Law, relating to their personality and personal standing. Processing of this information rests on:

• Explicit consent at registration: on creating their account the user agrees that, following events in which they took part, other participants may rate them. This consent constitutes the principal legal basis for processing rating information.
• The purpose of processing: ratings are intended solely for building trust between members of the community, assisting users in deciding whether to join an event with particular participants, and improving the overall user experience.

8(b) - What is stored and what is displayed

The principle of rater anonymity: the identity of the rating user and the individual score they gave are not disclosed to the rated user or to the public, in order to allow honest and genuine rating and to prevent social pressure. TONIKA nevertheless retains this data internally for the purposes of policy enforcement and preventing misuse.

8(d) - Right of access to ratings

Every person is entitled to inspect, personally or through a representative authorised in writing or through their guardian, the personal information about them held in a database.

Accordingly, every rated user is entitled to access the following information:

Information disclosed to the rated user on request:

• Their aggregate score.
• The number of ratings they have received.
• The aggregated tags selected in respect of them.
• The period of time over which the ratings were collected.

Information that will not be disclosed to the rated user:

• The identity of individual rating users.
• The score given by each rating user separately.

How the right of access is exercised:

• Within the application: through profile settings, "My ratings".
• By direct approach: support@tonika.fun - an answer will be given within 14 business days.

8(e) - Right of correction

A person who has inspected the personal information about them and found it to be incorrect, incomplete, unclear or out of date may approach the controller of the database with a request to correct or delete that personal information.

Where the controller of the database agrees to the request, they shall make the required changes to the information in their possession and notify them to everyone who received the information from them during the period prescribed in the regulations.

Cases in which correction is possible:

• A rating produced as a result of a proven technical fault.
• A rating given by a user who was blocked for breach of the terms of service.
• An error in the calculation of the aggregate score.

Cases in which correction is not possible:

• A valid rating given by an authorised user after an event that took place.
• A request to change an individual score given in good faith.

Procedure for submitting a correction request:

A request to correct information shall be submitted by registered letter to the address of the database owner. Where the database owner refuses to correct or delete the information as requested, they shall notify the applicant within 30 days of the date the request was received.

Accordingly, TONIKA will respond to every correction request within 30 days and will give reasons for its decision.

8(f) - Right of deletion

A database owner shall delete information at the written request of the data subject where one of the following applies: the information was created, received, accumulated or collected contrary to the provisions of any law, or its continued use is contrary to the provisions of law; the information is no longer necessary for the purposes for which it was created, received, accumulated or collected.

Cases in which a deletion request will be granted:

• The rating was created contrary to the terms of service (for example, a rating by someone who did not attend the event).
• The rating contains incorrect information that cannot be corrected.
• Deletion of the rated user's account - this will entail deletion of all ratings they received.

Cases in which a deletion request will be refused:

A database owner may refuse a deletion request if they find that the use of the information is for one of the following: exercising freedom of expression, including the public's right to know; protecting a public interest; conducting legal proceedings or collecting debts; preventing fraud, theft, or preventing other acts liable to affect the accuracy or reliability of the information.

Accordingly, TONIKA may refuse to delete a valid rating given in good faith, since its deletion would harm the reliability of the rating system and the public's right to receive trustworthy information about users.

Automatic deletion:

A database owner shall operate a mechanism intended to ensure that the database does not hold information that is no longer necessary for the purpose for which it was collected. Where a database owner finds that the database holds unnecessary information, they shall delete that information at the earliest possible time.

Accordingly, TONIKA will operate an automatic deletion mechanism:

• Ratings given more than 3 years ago will be removed from the visible aggregate score.
• On deletion of an account - all ratings given and received will be deleted within 30 days.

8(g) - Protection against misuse

TONIKA will take measures to prevent distortion of the rating system:

• Blocking self-rating - a user cannot rate themselves.
• One rating per event - each rating user may rate a given user once only per event.
• Attendance verification - only users who attended the event may rate.
• Detection of anomalous ratings - an automated system will flag suspicious ratings for manual review.

9 - Prohibition on impersonation and provision of false details

9.1 - Definitions

"Impersonation" - presenting oneself as another person, living or dead, whether expressly or by implication, including by using their name, their details, their photograph, their identity card number, their email address, or any other identifying information belonging to another person.

"False details" - any incorrect, misleading or incomplete information that a user provides on registration, in using the application, or in any interaction with other users.

"Identifying information" - a name, email address, telephone number, photograph, identity card number, or any other detail enabling a person to be identified.

9.2 - The prohibitions

The user undertakes not to do any of the following:

a. Impersonating another person:

• Not to register with the application in another person's name without their explicit consent.
• Not to present themselves as another person to other users, event organisers, or TONIKA.
• Not to use another person's profile picture without their consent.
• Not to operate an account in another person's name, even if they received their details.

b. Providing false details:

• Not to provide an email address belonging to another person on registration.
• Not to use another person's telephone number for verification.
• Not to provide incorrect details when booking a place at a venue.
• Not to record a guest for an event under a fictitious name that is not the guest's real name.

c. Misuse of others' details:

• Not to use another person's details in order to obtain a service, a benefit, or access to content.
• Not to pass their account sign-in details to another person.
• Not to create multiple accounts for one person.

9.3 - Positive obligations

The user positively undertakes:

• Accuracy of information - to provide accurate, current and complete information on registration and during use.
• Updating changes - to update their details as soon as possible whenever they change.
• Protecting the account - to take reasonable measures to keep their account sign-in details confidential.
• Reporting suspicion - to report to TONIKA any suspicion of impersonation by another user, through the reporting mechanism in the application.

9.4 - The user's liability

a. Civil liability: a user who impersonated another person or provided false details shall bear full liability for any damage caused as a result, including:

• Damage to the person whose details were used.
• Damage to other users who were misled.
• Damage to TONIKA arising from the breach of these terms of service.

b. Criminal liability:

9.5 - TONIKA's powers

Where a suspicion of impersonation or provision of false details comes to light, TONIKA may take one or more of the following steps:

9.6 - Reporting mechanism

Reporting impersonation: any user who believes that another person is impersonating them or using their details without consent may approach TONIKA by means of:

• Within the application: the "Report user" button on the suspected profile.
• Email: abuse@tonika.app
• Online form: [form link]

TONIKA's commitment:

• Reviewing every approach within 48 hours of its receipt.
• Updating the reporter on the results of the review within 7 business days.
• Taking immediate steps in cases of ongoing damage.

9.7 - Protection of the victim of impersonation

A person whose details were used without their consent is entitled:

• To demand immediate deletion of the impersonating account.
• To receive a report on the actions carried out in their name in the application.
• To receive assistance from TONIKA in filing a complaint with the authorities.
• To approach the privacy officer by email at: support@tonika.fun