Privacy Policy

Version 1.2 · Last updated 7 October 2026

1.Who we are

EUROLIST is an online classifieds platform operated by:

SIA Trickster
Registration No.: 42403040615
Registered address: Rēzekne, Stacijas iela 18 - 38, LV-4601, Latvia

SIA Trickster is the controller of personal data processed in connection with EUROLIST within the meaning of Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”), unless stated otherwise in this Privacy Policy.

EUROLIST operates through websites including:

  • eurolist.lv
  • eurolist.lt
  • eurolist.ee
  • eurolist24.com

For privacy and data-protection matters:

privacy@eurolist.com

For general customer support:

support@eurolist.com

EUROLIST has not appointed a Data Protection Officer. Data-protection matters are handled internally by SIA Trickster.

2.Scope of this Privacy Policy

This Privacy Policy explains:

  • what personal data EUROLIST collects;
  • where personal data comes from;
  • why personal data is processed;
  • the legal bases for processing;
  • when information becomes public;
  • who may receive personal data;
  • how long information is retained;
  • how cookies, analytics, advertising and third-party services are used;
  • how personal data is protected;
  • what rights individuals have under the GDPR.

This Privacy Policy applies to visitors, registered users, private sellers, business users, company representatives, agents and other natural persons whose personal data is processed through EUROLIST.

3.Our privacy principles

EUROLIST aims to collect and process only personal data that is reasonably necessary to operate, secure and develop the platform.

In particular, EUROLIST does not intend to:

  • require private users to provide a verified legal identity;
  • require private users to use their real name publicly;
  • continuously track the precise physical location of users;
  • maintain a personalised “Recently Viewed” history;
  • build its own long-term behavioural profile of users for personalised listing recommendations;
  • make user e-mail addresses publicly visible in advertisements;
  • require users looking for work to upload CV or résumé documents;
  • intentionally request special-category personal data unless there is a specific lawful reason to do so;
  • sell EUROLIST account databases or user contact information to third parties.

Third-party advertising providers may perform advertising-related processing where the user has provided the required choices or consent through EUROLIST’s consent-management mechanism.

4.Minimum age

EUROLIST accounts are intended only for persons who are at least 18 years old.

By creating an account, a user confirms that they are at least 18.

EUROLIST does not intentionally provide registered-account functionality to children.

If EUROLIST becomes aware that an account has been created by a person under 18, the account may be suspended or deleted, subject to information that EUROLIST is required or lawfully entitled to retain.

5.Personal data we process

5.1.Account and authentication data

When a user creates or uses an EUROLIST account, EUROLIST may process:

  • e-mail address or telephone number;
  • verification status;
  • verification codes where technically necessary;
  • securely hashed password;
  • account ID;
  • account type;
  • account creation date;
  • account status;
  • language and account preferences;
  • acceptance of Terms, policies and the applicable policy version;
  • authentication timestamps;
  • security-related authentication events.

At registration, a private user is not required to provide a verified legal identity.

Verification of an e-mail address or telephone number means only that the user had access to that e-mail address or telephone number at the relevant time.

It does not mean that EUROLIST has verified the person’s identity, legal name or other identity information.

If a user chooses to register, log in or connect their account with Google or Facebook, EUROLIST receives from that provider:

  • the provider’s account identifier for the user;
  • first name and last name;
  • e-mail address, where the provider shares it, and whether the provider has confirmed it.

EUROLIST uses this information only to create, identify or connect the user’s account, and shows the connected e-mail address in the user’s account settings. EUROLIST does not receive the user’s Google or Facebook password and does not post to or access any other information in that account. A telephone number must still be verified before the account can be used.

5.2.Display name and profile information

A private user may provide a name when publishing an advertisement.

EUROLIST does not verify whether the entered name is the user’s legal name.

The field may therefore contain:

  • a first name;
  • a nickname;
  • a business-facing name;
  • another display name chosen by the user.

The name is displayed publicly only where the user chooses to enable the relevant display option.

5.3.Advertisement information

Depending on the advertisement category, EUROLIST may process:

  • advertisement title;
  • description;
  • price;
  • category and subcategory;
  • structured listing attributes and filters;
  • city, region or address;
  • selected map location;
  • photographs;
  • externally hosted video links;
  • seller contact information;
  • vehicle information;
  • optional VIN;
  • property information;
  • employment-related listing information;
  • animal-related listing information;
  • other information voluntarily entered by the user;
  • publication, editing and expiration dates.

Users determine much of the information that becomes part of a public advertisement.

Users should therefore consider carefully what information they publish.

6.Business Accounts

Business and professional accounts may include:

  • company or trading name;
  • registration number;
  • VAT number, where applicable;
  • registered or business address;
  • country;
  • telephone number;
  • e-mail address;
  • website;
  • authorised representatives;
  • agents or contact persons;
  • billing information;
  • subscription or package information;
  • listing information.

A Business Account may be used by companies, individual merchants, self-employed persons and other users acting for purposes related to their trade, business, craft or profession.

EUROLIST may distinguish publicly between:

  • Private Seller
  • Business Seller
  • Verified Business

EUROLIST will use a verification indication only where the relevant verification has actually been performed.

EUROLIST may verify business information using official or reliable registers where such functionality is available.

VAT registration is not required merely because a user has a Business Account.

7.Agents and company representatives

Business Accounts may create and assign agents or representatives to individual advertisements.

Information about an agent may include:

  • name;
  • photograph;
  • business telephone number;
  • business e-mail address;
  • position or role;
  • other professional contact information.

The Business Account remains responsible for the advertisement.

The assigned agent does not become the seller merely because the agent appears as the contact person.

Where a business provides personal data relating to an employee, representative or agent, the business must have an appropriate basis for providing that information to EUROLIST and must appropriately inform the individual.

8.Information displayed about Business Sellers

A business advertisement may display:

  • company or trading name;
  • Business Seller status;
  • number of active advertisements;
  • date from which the business has used EUROLIST;
  • assigned agent, where applicable.

Additional company information may be available through the company’s EUROLIST profile.

Where an agent is assigned, the agent’s telephone number may be accessible after an intentional action such as “Show number”.

9.Chat and communications between users

EUROLIST may provide internal chat functionality allowing users to communicate in relation to advertisements.

EUROLIST may process:

  • sender and recipient identifiers;
  • message content;
  • attachments;
  • timestamps;
  • technical delivery information;
  • conversation status;
  • reports relating to a conversation or user.

EUROLIST does not use the content of private chats to build advertising profiles.

Authorised EUROLIST personnel may access relevant chat information where reasonably necessary to:

  • investigate a user report;
  • investigate fraud or abuse;
  • address a security incident;
  • enforce EUROLIST rules;
  • comply with a lawful request;
  • establish, exercise or defend legal claims.

10.Support, reports and moderation

When a person contacts EUROLIST support or submits a report, EUROLIST may process:

  • account details;
  • contact details;
  • listing ID;
  • user ID;
  • message or report content;
  • evidence provided by the reporting person;
  • correspondence;
  • moderation history;
  • moderation decisions;
  • reasons for a decision;
  • appeal information.

EUROLIST may provide separate mechanisms for:

  • reporting violations of EUROLIST rules; and
  • reporting allegedly illegal content.

Reports may concern, among other things:

  • suspected fraud;
  • prohibited goods;
  • fake advertisements;
  • misleading information;
  • harassment;
  • intellectual-property violations;
  • privacy or personal-data violations;
  • illegal content.

When a person or company requests an advertising offer through the Advertising page, EUROLIST processes the company name, contact person, email address, phone number (if provided), chosen placement and the message, in order to prepare the offer and agree the placement (steps taken at the request of the person before entering into a contract).

When a company applies for a partnership through the Partnership page, EUROLIST processes the company name, website (if provided), the contact person's email address, country, chosen partnership area and the message, in order to assess the application and agree the terms of the partnership (steps taken at the request of the person before entering into a contract).

When a person writes to EUROLIST through the contact form, EUROLIST processes the email address, chosen topic, the link to a listing (if provided), the message and any screenshots attached. Screenshots are stored privately, are visible only to EUROLIST staff handling the message, and are used only to answer it.

11.Payments and billing

Users may purchase EUROLIST services such as:

  • paid advertisements;
  • Highlighted advertisements;
  • TOP advertisements;
  • promotional placement;
  • Business Account packages;
  • other paid EUROLIST functionality.

Payments are processed using Montonio and relevant banks, payment institutions or card-payment providers.

EUROLIST may process:

  • user or business ID;
  • order number;
  • invoice number;
  • service purchased;
  • amount;
  • currency;
  • VAT information;
  • billing information;
  • transaction reference;
  • payment status;
  • refund status.

EUROLIST does not intend to store the user’s full payment-card number or CVV.

Montonio, banks and other payment institutions may process personal data independently for payment execution, regulatory compliance, fraud prevention and other payment-related purposes under their own applicable privacy information and legal obligations.

12.Technical and security information

EUROLIST may process technical information including:

  • IP address;
  • registration IP;
  • login timestamps;
  • logout timestamps;
  • browser type;
  • operating system;
  • device category;
  • language information;
  • session identifiers;
  • failed authentication attempts;
  • security events;
  • advertisement publication events;
  • changes to important account settings;
  • anti-fraud and anti-abuse indicators.

The main purposes of this processing are:

  • account security;
  • service security;
  • fraud prevention;
  • spam prevention;
  • protection against bots;
  • protection against scraping;
  • troubleshooting;
  • service reliability.

EUROLIST does not intend to use IMEI numbers, MAC addresses or similarly intrusive hardware identifiers for ordinary platform operation.

On the log-in, registration and password-reset forms, EUROLIST uses Google reCAPTCHA to tell people apart from automated bots. For this purpose Google may process the IP address, browser and device information, and interaction data on the page.

13.“Show number” activity

Telephone numbers are not intended to be displayed openly before a visitor intentionally chooses to reveal them.

When a visitor uses “Show number” or an equivalent function, EUROLIST may record limited information concerning the event, including:

  • account identifier, where applicable;
  • IP address;
  • listing identifier;
  • timestamp;
  • reveal event.

This processing is used primarily to detect and prevent:

  • telephone-number scraping;
  • automated harvesting;
  • spam;
  • fraud;
  • abusive activity.

EUROLIST does not intend to create a permanent personal history showing every seller whose telephone number a user has viewed.

EUROLIST also counts reveal events as an anonymous daily total for each advertisement and shows that total to the advertiser as part of the statistics about their own advertisements. The total does not identify who revealed the number.

14.Location information

EUROLIST does not currently request or continuously track the precise GPS location of a user’s device.

Users may voluntarily provide or select:

  • country;
  • municipality;
  • city;
  • region;
  • street;
  • address;
  • map position.

Where the user selects a precise map point or enters a precise address, the resulting location may be shown publicly.

For residential property advertisements, EUROLIST does not require the public display of an apartment number.

Users should avoid selecting an exact residential location if they do not want that location to become publicly accessible.

15.Google Maps

EUROLIST uses Google Maps to provide map and location functionality when creating and viewing advertisements.

When Google Maps functionality is loaded or used, Google may process information including:

  • IP address;
  • browser/device information;
  • map interactions;
  • search terms entered into map functionality;
  • location or coordinates provided through the map.

Where required by applicable law, Google Maps is activated in accordance with the user’s relevant consent or privacy choices.

Google may act as an independent controller for certain processing connected with Google Maps.

16.Search activity

EUROLIST may process aggregated or appropriately de-identified information about searches to understand:

  • which categories are used;
  • which searches are popular;
  • how the search system performs;
  • how EUROLIST can improve navigation and search quality.

EUROLIST does not currently intend to maintain a permanent personalised general search-history profile for individual users.

To give advertisers statistics about their own advertisements, EUROLIST counts, for each advertisement and each day:

  • how many visitors were shown it in search and category results;
  • how many visitors added it to a comparison;
  • how many visitors shared it.

Each visitor is counted at most once per advertisement per day. For this, EUROLIST uses a randomly generated visitor identifier stored in a necessary first-party cookie and a short-lived record that expires after 24 hours. Only the daily totals per advertisement are kept. Automated traffic and the advertiser’s own visits are not counted.

17.Favorites and Saved Searches

When a user intentionally uses these functions, EUROLIST may store:

  • Favorite advertisement IDs;
  • Saved Search criteria;
  • alert preferences;
  • notification settings.

Saved Searches may be used to notify the user when new advertisements match the criteria selected by the user.

EUROLIST does not currently maintain a persistent personalised Recently Viewed feature.

18.Saved Search notifications

A user may explicitly request notifications relating to a Saved Search.

For example, a user may choose to receive notifications when new advertisements match:

  • a selected category;
  • a selected model;
  • a selected location;
  • a selected price range;
  • other chosen filters.

Saved Search notifications are treated as user-requested service functionality.

Creating a Saved Search does not constitute consent to receive unrelated EUROLIST marketing.

Saved Search alerts may be disabled separately.

19.Public information

EUROLIST is a public classifieds service.

Information deliberately published in an active advertisement may be accessible to:

  • registered users;
  • visitors who are not registered;
  • search engines;
  • persons receiving a link to the advertisement;
  • third-party services that index publicly accessible webpages.

Public information may include:

  • advertisement title;
  • advertisement description;
  • photographs;
  • price;
  • selected location;
  • listing attributes;
  • vehicle information;
  • optional VIN;
  • business name;
  • seller type;
  • assigned agent;
  • other information intentionally published through the advertisement.

Active advertisements may be indexed by search engines such as Google and Bing.

EUROLIST cannot guarantee the immediate removal of information from third-party search-engine caches or other third-party systems after an advertisement is changed or removed.

20.Telephone numbers and e-mail addresses

A seller’s e-mail address is not intended to be publicly displayed in advertisements.

Telephone numbers are intended to be accessible only after an intentional user action such as “Show number”.

Pardavėjas paskyros nustatymuose gali išjungti savo telefono numerio rodymą savo skelbimuose. Kol tai išjungta, numeris nerodomas tuose skelbimuose ir pokalbiuose.

EUROLIST may implement technical measures intended to reduce automated indexing, scraping or harvesting of telephone numbers.

21.Display names

A private seller’s display name is shown publicly only where the seller has chosen to display it.

EUROLIST does not verify that the display name is the user’s legal identity.

Users must not impersonate another person or use another person’s identity unlawfully.

22.User-generated content and personal data of other persons

Users must not publish personal data relating to another person unless they have the right to do so.

Users should in particular avoid unnecessarily publishing:

  • identity documents;
  • private telephone numbers;
  • private e-mail addresses;
  • bank information;
  • private addresses;
  • confidential correspondence;
  • personal records;
  • photographs of identifiable persons without an appropriate reason or permission.

EUROLIST does not automatically blur:

  • faces;
  • vehicle registration plates;
  • other identifying information appearing in uploaded photographs.

Users are responsible for reviewing their photographs and other content before publication.

EUROLIST may remove information that appears to contain unlawfully disclosed personal data.

23.Special categories of personal data

EUROLIST does not intentionally require users to provide special categories of personal data revealing:

  • racial or ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • trade-union membership;
  • genetic data;
  • biometric data used for unique identification;
  • health information;
  • sex-life information;
  • sexual orientation.

Users should avoid including such information in advertisements, profiles or chats unless there is a clear lawful reason for doing so.

EUROLIST may remove unnecessary or unlawfully published sensitive personal information.

Information concerning the health of an animal is not, by itself, special-category health data relating to a natural person.

24.Purposes and legal bases

EUROLIST processes personal data under different legal bases depending on the purpose.

24.1.Performance of a contract — Article 6(1)(b) GDPR

EUROLIST may rely on contractual necessity to:

  • register and administer accounts;
  • authenticate users;
  • publish and manage advertisements;
  • provide Business Account functionality;
  • provide chat functionality;
  • provide Favorites and Saved Searches;
  • provide user-requested notifications;
  • process purchases of EUROLIST services;
  • administer subscriptions and paid features;
  • provide customer support relating to the service.

24.2.Legal obligations — Article 6(1)(c) GDPR

EUROLIST may process personal data where required to:

  • maintain accounting records;
  • comply with tax obligations;
  • comply with regulatory requirements;
  • respond to legally binding requests;
  • comply with court or authority orders;
  • fulfil other obligations imposed on SIA Trickster by applicable law.

24.3.Legitimate interests — Article 6(1)(f) GDPR

Subject to the required balancing of interests and rights, EUROLIST may process personal data to:

  • protect users;
  • prevent fraud;
  • prevent scams;
  • prevent spam;
  • detect bots;
  • prevent scraping;
  • investigate complaints;
  • moderate advertisements;
  • enforce EUROLIST Terms and rules;
  • maintain security;
  • prevent repeat abuse;
  • investigate security incidents;
  • maintain appropriate technical logs;
  • establish, exercise or defend legal claims;
  • provide advertisers with statistics about the performance of their own advertisements;
  • improve service reliability.

24.4.Consent — Article 6(1)(a) GDPR

Where consent is required, EUROLIST may rely on consent for:

  • non-essential analytics;
  • advertising technologies;
  • advertising personalisation;
  • optional cookies or similar technologies;
  • optional third-party media and functionality;
  • direct electronic marketing;
  • other processing expressly presented as optional and consent-based.

Consent may be withdrawn at any time.

Withdrawal does not affect processing lawfully carried out before consent was withdrawn.

25.Cookies, analytics and advertising technologies

EUROLIST uses cookies and similar technologies.

Detailed information about individual technologies, purposes, vendors and available choices is provided through EUROLIST’s Cookie Policy and consent-management interface.

Technologies may be grouped into categories including:

Necessary

Necessary technologies support functions such as:

  • authentication;
  • sessions;
  • security;
  • fraud prevention;
  • network protection;
  • storage of privacy choices;
  • essential platform functionality.

Functional

Functional technologies may support optional third-party functionality including:

  • maps;
  • embedded media;
  • YouTube;
  • other user-requested integrations.

Analytics

EUROLIST currently uses PostHog EU Cloud for analytics.

Analytics may be used to measure:

  • visits;
  • feature usage;
  • categories used;
  • registration conversion;
  • advertisement-publication conversion;
  • platform performance.

EUROLIST does not currently use PostHog Session Replay.

EUROLIST aims not to send passwords, verification codes, full payment-card information, private chat content or unnecessary contact information to PostHog.

Where consent is required, analytics is activated only in accordance with the user’s consent choices.

Advertising

EUROLIST uses advertising technologies including:

  • Google AdSense
  • Google Ads

Advertising and related tracking are controlled through EUROLIST’s consent-management mechanism where required by applicable law.

Users can manage and withdraw optional advertising choices through EUROLIST’s privacy or cookie settings.

26.Google advertising

Where a user provides the applicable consent, Google and advertising technology providers may process information for purposes including:

  • selecting advertisements;
  • measuring advertisements;
  • measuring conversions;
  • managing advertising frequency;
  • preventing advertising fraud;
  • audience measurement;
  • personalised advertising.

EUROLIST does not itself maintain a long-term behavioural profile for personalised classifieds recommendations.

Third-party advertising providers may nevertheless perform advertising-related personalisation where the user has consented to the relevant advertising purposes.

27.Embedded YouTube content

Users may add YouTube links to advertisements.

EUROLIST may display such videos through an embedded YouTube player.

Where technically appropriate, privacy-enhanced YouTube embedding may be used.

Where applicable law requires a privacy choice before a third-party player is activated, EUROLIST will activate the service in accordance with the relevant consent or user action.

After YouTube content is activated, Google/YouTube may process information under its own privacy practices.

28.Marketing communications

EUROLIST may send promotional communications by channels such as:

  • e-mail;
  • SMS;
  • other electronic communication channels implemented in the future.

As EUROLIST’s general approach, direct promotional marketing is based on separate voluntary consent.

Marketing consent:

  • is not required to create an account;
  • is not required to publish an advertisement unless legally necessary for a specific function;
  • is not preselected by default;
  • is separate from acceptance of EUROLIST Terms;
  • may be withdrawn at any time.

Marketing e-mails will include an appropriate unsubscribe method.

Jei naudotojas davė sutikimą gauti rinkodaros pranešimus, EUROLIST gali išsiųsti pardavėjui laišką, kai kuris nors jo skelbimas netrukus baigsis, nurodydama dabartinę jo pakėlimo ar reklamavimo kainą. Šiuose laiškuose nėra trečiųjų šalių reklamos ir yra atsisakymo nuoroda.

EUROLIST will respect valid opt-out requests.

29.Service communications

EUROLIST may send communications that are necessary or directly related to use of the service, including:

  • registration verification;
  • verification codes;
  • password resets;
  • security alerts;
  • payment confirmations;
  • invoices;
  • listing status information;
  • listing expiration notices;
  • moderation decisions;
  • support responses;
  • chat-message notifications;
  • important changes affecting the service or account.
  • a statistics report about the user’s own advertisements, sent every two weeks while the user has published advertisements;
  • savaitės suvestinė apie paties naudotojo skelbimų peržiūras, kontaktų atskleidimus ir naujus pokalbius, siunčiama tik tada, kai naudotojas ją įjungė;

The statistics report is sent in the user’s preferred language and contains only aggregated figures about the user’s own advertisements. Where at least five comparable active advertisements exist, it may also show the median number of views of similar advertisements, which does not identify any other advertiser. The report can be turned off at any time in account settings or through the link included in every report.

Savaitės suvestinę bet kada galima išjungti paskyros nustatymuose arba per nuorodą, esančią kiekvienoje suvestinėje.

These communications are separate from general promotional marketing.

Withdrawing marketing consent therefore does not prevent EUROLIST from sending communications necessary for the operation, security or contractual performance of the service.

30.Service providers and recipients

EUROLIST uses third-party service providers where reasonably necessary to operate the platform.

Current core providers include:

Vercel

Frontend hosting and web infrastructure.

Fly.io

Backend infrastructure and database hosting infrastructure.

EUROLIST’s primary backend and self-hosted PostgreSQL database are configured in the Netherlands.

Tigris Object Storage

Object storage used through EUROLIST’s infrastructure, including storage of user-uploaded photographs.

Cloudflare

DNS, CDN, network and security services.

Resend

Transactional e-mail delivery, including registration, password-reset, notification and other service-related messages.

Text2Reach

SMS delivery, including verification codes and notifications.

PostHog

Analytics services using PostHog EU Cloud.

OpenAI

Skelbimų aprašymų vertimas į kalbas, kurias pardavėjas paliko tuščias: vieną kartą automatiškai, kai skelbimas paskelbiamas arba importuojamas arba pardavėjo prašymu kuriant skelbimą. Taip pat paieška pagal prasmę (paieškos užklausos ir skelbimų tekstas paverčiami skaitiniais atvaizdais). Siunčiamame tekste gali būti viskas, ką pardavėjas parašo aprašyme.

Google

Services including:

  • Google Maps;
  • YouTube;
  • Google AdSense;
  • Google reCAPTCHA;
  • Google Ads.

Montonio and financial institutions

Payment and payment-related services.

Personal data may also be disclosed where appropriate to:

  • accountants;
  • auditors;
  • legal advisers;
  • insurers;
  • technical or security specialists;
  • competent courts;
  • law-enforcement authorities;
  • tax authorities;
  • data-protection authorities;
  • other public authorities where disclosure is required or permitted by law.

Where a provider acts as a processor on behalf of EUROLIST, appropriate data-processing arrangements are used where required.

Certain providers, particularly payment, advertising, mapping and media providers, may act as independent controllers in relation to some of their processing.

31.International transfers

EUROLIST’s principal backend and database infrastructure is configured within the European Union.

However, EUROLIST uses international technology providers whose organisations, support operations, subprocessors or infrastructure may process personal data outside the European Economic Area.

EUROLIST therefore does not represent that all personal data is processed exclusively inside the European Union or European Economic Area.

Where personal data is transferred outside the EEA and an international transfer mechanism is required, EUROLIST or the relevant provider may rely on safeguards such as:

  • an adequacy decision of the European Commission;
  • an applicable recognised adequacy framework;
  • Standard Contractual Clauses approved by the European Commission;
  • supplementary technical or organisational safeguards.

Additional information concerning relevant safeguards may be requested from:

privacy@eurolist.com

32.Data retention

EUROLIST does not retain identifiable personal data indefinitely merely because it may be useful in the future.

Retention depends on the purpose for which the information is processed.

32.1.Account data

Account information is retained while the account remains active.

When an account is deleted, ordinary active account information is removed or anonymised without undue delay, except where information must or may lawfully be retained for:

  • accounting;
  • taxation;
  • fraud prevention;
  • security;
  • unresolved complaints;
  • legal claims;
  • chargebacks;
  • regulatory requirements.

Residual copies may remain in protected backup systems for up to 90 days.

32.2.Active and inactive advertisements

Advertisements remain publicly available while active.

After expiration, an advertisement may remain available to the account holder as an inactive advertisement for up to 12 months.

After that period, EUROLIST intends to anonymise the advertisement where reasonably possible.

This may include:

  • deleting photographs;
  • removing telephone numbers;
  • removing contact information;
  • removing names;
  • removing identifying location information;
  • removing other personal identifiers.

Listing text may be retained only where it can reasonably be rendered non-identifying.

If the description itself contains personal data that cannot reliably be anonymised, the relevant information will be removed rather than treated as anonymous.

32.3.User-deleted advertisements

When a user deliberately deletes an advertisement, the advertisement is removed from public availability promptly.

A limited technical copy may be retained for up to 90 days where reasonably necessary for:

  • fraud prevention;
  • security;
  • user complaints;
  • chargebacks;
  • moderation;
  • legal claims.

32.4.Chat messages

Ordinary chat messages and attachments are normally retained for up to 6 months after the last activity in the conversation.

32.5.Reported messages and evidence

Messages and other information relevant to a report, moderation matter or fraud investigation may be retained for up to 24 months after final closure of the case.

Where a legal claim, law-enforcement investigation, chargeback, court proceeding, regulatory investigation or other unresolved dispute remains active, relevant evidence may be retained until the matter has been finally resolved and for any additional period required or permitted by applicable law.

EUROLIST does not retain an entire conversation indefinitely merely because the conversation was reported once.

32.6.Moderation records

Moderation decisions and relevant evidence may normally be retained for up to 24 months.

32.7.Anti-fraud restriction records

Where an account has been suspended for serious or repeated abuse, EUROLIST may retain a minimised anti-fraud record including information such as:

  • account identifier;
  • hashed e-mail identifier;
  • hashed telephone identifier;
  • restriction reason;
  • restriction date.

Such information is normally retained for up to 24 months, unless a documented continuing fraud risk, legal requirement or unresolved claim justifies longer retention.

32.8.Security logs

IP addresses and security logs are normally retained for up to 12 months, unless the information becomes relevant to a specific investigation, security incident or legal matter.

32.9.“Show number” logs

Telephone-reveal and related anti-scraping logs are normally retained for up to 90 days, unless the information is required for investigation of specific abuse.

32.10.Favorites and Saved Searches

Favorites and Saved Searches are retained until:

  • the user deletes them;
  • the related feature is disabled; or
  • the account is deleted.

32.11.Marketing preferences

Marketing preferences remain in effect until changed or withdrawn.

EUROLIST may retain limited evidence of consent and withdrawal where necessary to:

  • demonstrate compliance;
  • document when consent was obtained;
  • ensure that an opt-out continues to be respected.

32.12.Analytics

Identifiable or pseudonymous EUROLIST analytics information should normally be subject to a limited retention period not exceeding 12 months, unless a shorter period is sufficient for the relevant purpose.

Properly anonymised aggregate statistics may be retained for longer where they can no longer reasonably be linked to an identifiable person.

32.13.Accounting, invoices and payment records

EUROLIST retains invoices, transaction records, payment-related records and other accounting documentation for the periods required by Latvian accounting, tax and other applicable legislation.

Under Latvian accounting law, ordinary supporting accounting documents must generally be retained for at least five years.

Certain accounting records are subject to longer mandatory retention periods.

In particular:

  • inventory lists, accounting registers and accounting-organisation documents are generally retained for 10 years;
  • certain employee payroll and employment-related accounting documents are retained for 10 years, and in specific legally defined historical cases may be subject to even longer retention;
  • annual financial statements are retained for the legally prescribed period, including until the company’s reorganisation or termination where applicable;
  • records connected with an unresolved tax audit, legal claim, investigation, dispute or other proceeding may be retained for longer where this is legally required or necessary.

Accordingly, invoices and transaction records may continue to contain personal data after the related EUROLIST account has been deleted.

Such information is not retained in order to continue operating the deleted account.

It is retained only for the applicable purpose listed below:

  • accounting;
  • taxation;
  • audit;
  • regulatory;
  • legal-compliance;
  • legal-claims

Access to retained accounting information is restricted accordingly.

Where several mandatory retention periods apply to the same information, EUROLIST may retain the information for the longest applicable legally required period.

32.14.Backups

Deleted personal data may temporarily remain in protected backups for up to 90 days.

Backup copies are not intended to be used to restore deleted user information to ordinary production systems unless restoration is necessary in connection with a genuine disaster-recovery or security event.

33.Security

EUROLIST applies technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • unauthorised disclosure;
  • accidental loss;
  • destruction;
  • alteration;
  • misuse.

Measures may include:

  • HTTPS/TLS encryption in transit;
  • infrastructure-level encryption at rest;
  • secure one-way password hashing;
  • role-based access control;
  • restricted production access;
  • administrative access controls;
  • security logging;
  • backup and recovery measures;
  • multi-factor authentication for privileged administrative access;
  • anti-fraud measures;
  • moderation tools.

Access to personal data is granted according to operational need.

For example, a moderator reviewing an advertisement does not automatically require access to detailed payment information or security logs.

No internet-based service can guarantee absolute security.

34.Automated fraud and abuse detection

EUROLIST may use automated technical rules to detect potentially abusive activity, including:

  • unusually high numbers of advertisements;
  • high numbers of telephone-number reveals;
  • automated scraping;
  • repeated account registrations;
  • duplicate advertisements;
  • mass messaging;
  • spam;
  • suspicious authentication activity.

Automated systems may:

  • flag activity;
  • require additional review;
  • temporarily limit functionality;
  • help prioritise moderation.

EUROLIST does not intend to rely solely on automated processing to make a final permanent account-ban decision producing similarly significant effects without meaningful human involvement.

Serious moderation decisions and permanent bans should be capable of human review.

35.Moderation and appeals

EUROLIST may remove, restrict or suspend advertisements or accounts where reasonably necessary to:

  • enforce EUROLIST Terms;
  • enforce listing rules;
  • respond to unlawful content;
  • prevent fraud;
  • protect users;
  • protect EUROLIST;
  • comply with legal obligations.

Where appropriate, EUROLIST will provide the affected user with information about the reason for the decision.

Users may be provided with a mechanism to appeal moderation or account-restriction decisions.

36.No EUROLIST behavioural recommendation profile

EUROLIST does not currently intend to create a persistent behavioural profile based on all advertisements, categories or products viewed by an individual in order to personalise future classifieds recommendations.

Search and listing results may nevertheless depend on factors including:

  • the current search query;
  • filters;
  • selected location;
  • category;
  • relevance;
  • listing publication date;
  • paid promotional features;
  • other disclosed ranking factors.

Advertising providers may perform advertising-related personalisation where the user has consented to the relevant purposes.

37.Legal requests and authorities

EUROLIST may disclose personal data where it receives a legally valid request from:

  • a court;
  • law-enforcement authority;
  • tax authority;
  • data-protection authority;
  • other competent public authority.

EUROLIST aims to disclose only information that is reasonably necessary or legally required for the relevant request.

Where appropriate, EUROLIST records:

  • the request;
  • the legal basis;
  • the information disclosed;
  • the action taken.

38.Account deletion

Users may request account deletion through:

Mano profilis → Nustatymai ir prieiga → Paskyra → Ištrinti paskyrą

or by contacting:

privacy@eurolist.com

Account deletion ordinarily results in:

  • removal of active advertisements from public availability;
  • deletion of Favorites;
  • deletion of Saved Searches;
  • termination of active marketing subscriptions;
  • deletion of applicable notification settings;
  • removal of ordinary public profile information.

Account deletion does not automatically erase information that EUROLIST is required or lawfully entitled to retain for:

  • accounting;
  • taxation;
  • fraud prevention;
  • security;
  • unresolved reports;
  • chargebacks;
  • legal claims;
  • regulatory compliance.

Such information is restricted to the relevant purpose and retained only for the applicable retention period.

Tavo išsiųstos žinutės lieka kito asmens pokalbyje, tačiau be tavo vardo, nuotraukos ir kontaktinių duomenų.

39.Your GDPR rights

Subject to the conditions and limitations provided by applicable law, individuals may have the following rights.

39.1.Right of access

You may ask EUROLIST to confirm whether your personal data is being processed and request access to relevant personal data and processing information.

39.2.Right to rectification

You may request correction of inaccurate personal data and completion of incomplete information.

Where possible, EUROLIST allows users to update information directly through their account.

39.3.Right to erasure

You may request deletion of personal data where the conditions of Article 17 GDPR are met.

The right to erasure is not absolute.

For example, EUROLIST is not required to delete information that must continue to be retained because of a legal obligation or an applicable legal claim.

39.4.Right to restriction

You may request restriction of processing in the circumstances provided by the GDPR.

39.5.Right to data portability

Where the legal requirements are satisfied, you may request certain personal data that you provided to EUROLIST in a structured, commonly used and machine-readable format.

39.6.Right to object

Where EUROLIST processes personal data on the basis of legitimate interests, you may object to the processing in the circumstances provided by Article 21 GDPR.

39.7.Right to withdraw consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

39.8.Right to object to direct marketing

You may object to direct marketing at any time.

When a valid objection to direct marketing is received, EUROLIST will stop using the relevant personal data for that marketing.

39.9.Right to complain

You have the right to lodge a complaint with a competent data-protection supervisory authority.

SIA Trickster is established in Latvia.

The Latvian supervisory authority is:

Datu valsts inspekcija
Elijas iela 17
Rīga, LV-1050
Latvia
E-mail: pasts@dvi.gov.lv

Depending on the circumstances, you may also have the right to lodge a complaint with the supervisory authority in the EU/EEA Member State of your habitual residence, place of work or place of the alleged infringement.

40.Privacy & Data controls

EUROLIST intends to provide privacy controls through:

Profile → Settings → Privacy & Data

Depending on the available functionality, this section may include:

  • Download my data;
  • Delete account;
  • Cookie preferences;
  • Marketing preferences;
  • Notification preferences.

Requests that cannot reasonably be handled through self-service functionality may be submitted to:

privacy@eurolist.com

41.Downloading your data

EUROLIST may provide an account-data export containing applicable information such as:

  • account information;
  • advertisements;
  • user-uploaded media;
  • Favorites;
  • Saved Searches;
  • notification preferences;
  • consent information;
  • order/payment history;
  • chat information that remains within the applicable retention period.

The exact content of an export depends on:

  • what information EUROLIST holds;
  • the nature of the request;
  • the applicable GDPR right;
  • the rights and freedoms of other persons.

Information relating to other individuals may be redacted or limited where necessary to protect their rights.

42.Verification of privacy requests

EUROLIST must take reasonable steps to ensure that personal data is not disclosed, changed or deleted in response to a fraudulent request.

EUROLIST may therefore verify the identity or account control of a requester.

Where reasonably possible, proportionate verification methods will be used, including:

  • authenticated account access;
  • password re-authentication;
  • e-mail verification;
  • SMS verification.

EUROLIST does not require a passport or identity-document copy by default.

Additional information will be requested only where reasonably necessary to confirm the identity of the requester.

43.Response time for GDPR requests

EUROLIST responds to valid GDPR rights requests without undue delay and ordinarily no later than one month after receipt.

Where permitted by the GDPR, this period may be extended by up to two additional months where necessary because of the complexity or number of requests.

Where an extension is required, EUROLIST will inform the requester within the initial one-month period and explain the reason for the extension.

EUROLIST aims to resolve ordinary requests sooner where reasonably possible.

44.Withdrawal of consent

Where processing is based on consent, withdrawing consent should be as easy as providing it.

Relevant preferences may be managed through functions such as:

  • Cookie Settings;
  • Privacy Settings;
  • Marketing Settings.

Withdrawal of marketing, analytics or advertising consent does not:

  • delete the EUROLIST account;
  • prevent necessary security processing;
  • prevent password-reset messages;
  • prevent transactional messages;
  • prevent communications required to provide the service;
  • affect processing lawfully carried out before withdrawal.

45.Changes to this Privacy Policy

EUROLIST may update this Privacy Policy where necessary because of:

  • changes to EUROLIST functionality;
  • new service providers;
  • changes in processing practices;
  • legal or regulatory changes;
  • security developments;
  • changes to EUROLIST’s business model.

The current version will be published on EUROLIST together with its latest-update date.

Where a change materially affects users’ privacy rights or the manner in which their personal data is processed, EUROLIST will provide an additional notice where required.

New processing that legally requires consent will not become authorised merely because this Privacy Policy has been changed.

46.Contact us

For questions about personal data, privacy or GDPR rights:

privacy@eurolist.com

For general customer-support questions:

support@eurolist.com

Data Controller

SIA Trickster
Registration No.: 42403040615
Rēzekne, Stacijas iela 18 - 38, LV-4601
Latvia

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