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Privacy in plain language · version 1.0 · 14 August 2026

Private where it should be. Public where you choose.

After Ticket B.V. in the Netherlands operates Wholero and is the data controller. The public contact route at wholero.com/privacy/verzoek also works without an account. We do not sell personal data or use advertising trackers.

01

Data we use

For an account, we use your name, verified email address, account ID, secure session data, notification preference and—if you enter them—a reusable town/area and private postal-code area. For listings, we use your text, product attributes, photos, public display name, town/area, private postal-code area and selected handover preference. For matches, we store conversation text, read status and your optional assessment of the match and outcome, plus necessary safety and moderation data. We do not collect payment details because Wholero does not process payments.

02

What becomes public

Only after your separate publication confirmation do the listing text, public display name, town/area and selected product photo become public. Your email address, full postal code, account ID, product-label photo and damage photo remain private. Do not include people, addresses, documents or serial numbers you do not want to share in a product photo.

03

Why and on what legal basis

Account administration, listings, matching and messages are necessary to provide the service. Public publication, the optional AI scan and optional dictation take place only after your explicit choice. Security, fraud prevention, limited usage measurement and human moderation rely on our legitimate interest in keeping Wholero reliable. Where required, we process data to meet a legal obligation. You may withdraw consent for future use; this does not undo earlier lawful processing.

04

AI and speech

Only when you press analyse do we have selected product photos and the necessary instruction securely processed by an external AI service provider to create a reviewable draft. When you use Dictate, your device records for no more than one minute. After Stop, or automatically when that minute ends, the short recording is securely processed to transcribe it and cautiously improve the transcript's readability. Brands, identifiers, defects, negatives and uncertainty must not be invented or omitted; Wholero uses the literal transcript if a rewrite is unsafe. Wholero does not store the audio; only the text you choose to keep. We use a business API service under which submitted content is not used for model training and may be processed temporarily for security and abuse prevention under the applicable terms. AI publishes nothing and makes no decision with legal or similarly significant effects; you always review and confirm it yourself.

05

Recipients and processing outside Europe

We share only what is necessary with service providers for hosting and storage (Cloudflare), account security (Supabase), account email (Resend), and a specialised AI service provider for AI analysis, speech-to-text and copy editing. They process data on our instructions or under their necessary service terms. Some processing may take place outside the European Economic Area. Where required, we use provider agreements and valid transfer mechanisms such as an adequacy decision or standard contractual clauses. Competent authorities receive data only where required by law.

06

Security, cookies and reports

Essential secure cookies keep you signed in; a language choice and the choice to dismiss an installation card remain on your device. To prevent abuse, we use limited technical signals and pseudonymised rate-limit keys; raw IP addresses are not shown in public profiles or listings. A listing report allows authorised administrators to review the reported listing and related safety information. Wholero does not yet have a separate report function for individual chat messages, so do not share sensitive information and stop the conversation if you feel pressured or harassed.

07

How long we keep data

Confirmation links expire after one hour; temporary registration records are cleaned up during the account process. Account, listing, match and message data remain available while your account or the relevant service relationship is active. Offline or archived does not automatically mean all data and secure backups are immediately erased. Following a verified deletion request, we erase or anonymise data that is no longer needed, except where fraud investigations, disputes, security or a legal duty require longer retention. We normally keep privacy requests and their audit trail for up to two years after closure. Backups expire according to the secure replacement cycle of the relevant service provider.

08

Your rights and contact

After Ticket B.V., the Netherlands-based operator of Wholero, is your point of contact. Through the public form below, with or without an account, you can contact us about access, correction, deletion, restriction, objection, portability, a privacy question or complaint. We first verify your identity and normally respond within one month; if we do not fulfil a request, or only fulfil it in part, we explain why. The form is free and never automatically performs a deletion. You may withdraw consent for future processing. If you are not satisfied, you may lodge a complaint with the Dutch Data Protection Authority or seek a judicial remedy.

Open the public contact and privacy formRead about your rights at the Dutch DPA (opens new tab)