Privacy Policy

Last updated: [DATE]

Draft. This document is a working draft and has not yet been reviewed by a lawyer. The effective date will be set when the app launches.

This policy explains what personal data Hahatron (“we”, “us”) collects when you use the Hahatron mobile app, the website and related services (the “Service”), why we use it, who we share it with and the choices you have.

1. Who we are

The Service is operated by Taras Grygorovych Shevchenko, private entrepreneur (FOP), registered in Ukraine, which is the controller of your personal data. Contact us at nrg.ck.ua@gmail.com about anything in this policy.

2. Data we collect

CategoryExamplesSource
AccountEmail address, display name, profile photo, bio; identifiers from Google or Apple if you sign in with themYou, sign-in provider
ContentVideos you upload, captions, likes, follows, reports and blocksYou
Moderation recordsAutomated safety scores of your uploads, moderation decisions and their reasons, strikesUs
Device and usageApp version, device model, operating system, language, crash reports, in-app events (for example views, likes, uploads)Your device
AdvertisingAdvertising identifier and ad interactions, only where you have given consent where requiredYour device
NotificationsPush notification tokenYour device
WaitlistEmail address, language and whether you asked for creator accessYou (website form)

We do not collect your precise location, contacts or photos other than the media you choose to upload.

3. How we use your data and our legal bases

PurposeLegal basis (EEA/UK)
Create and run your account; host, process and show your videos; likes, follows and notificationsPerformance of our contract with you
Keep the community safe: automated and human moderation, handling reports, preventing abuse and fraudLegitimate interests; legal obligations
Fix bugs and improve the Service using crash reports and aggregated usage statisticsLegitimate interests
Personalised advertisingConsent (you can withdraw it at any time in the app)
Non-personalised advertising that funds the free ServiceLegitimate interests
Emails about the launch (waitlist)Consent
Complying with law and responding to lawful requestsLegal obligation

4. Automated moderation

Before a video is published, frames from it are analysed automatically (Google Cloud Vision) to detect content that breaks our Terms. Depending on the result a video may be published, held for human review or rejected. New accounts' first videos are always reviewed by a person. You will be told when your content is removed or restricted and why, and you can ask for a human review by contacting us at nrg.ck.ua@gmail.com.

5. Who we share data with

We do not sell your personal data. We share it only with service providers that process it on our behalf under contract:

Public content (your profile, published videos, likes counts) is visible to other users and may be shared outside the app by them. We may also share published videos on Hahatron's own social media channels, with credit, as described in the Terms. We may disclose data when required by law, to protect users' safety, or in connection with a merger or acquisition.

6. International transfers

Our primary database and file storage are located in the European Union. Some providers may process data in other countries, including the United States. Where this happens we rely on adequacy decisions (including the EU–U.S. Data Privacy Framework) or Standard Contractual Clauses.

7. How long we keep data

8. Your rights

Depending on where you live you may have the right to access, correct, delete or port your data, to object to or restrict processing, to withdraw consent, and to complain to your data protection authority. You can delete your account in the app (see how to delete your account) and manage ad consent in the app's settings. For other requests email nrg.ck.ua@gmail.com; we answer within one month.

California residents

We do not sell personal information. Personalised advertising may count as “sharing” for cross-context behavioural advertising under California law; you can opt out by turning off personalised ads in the app. You have the rights to know, delete and correct your information, and we will not discriminate against you for using them.

9. Children

The Service is not intended for children under 13. In some countries the minimum age is higher (up to 16) unless a parent consents. If we learn that we hold data of a child below the applicable age without such consent, we delete it. Contact us at nrg.ck.ua@gmail.com if you believe this has happened.

10. Security

Data is encrypted in transit, access is limited by strict security rules, and unpublished videos are not publicly listed. No system is completely secure, so please use a strong password and keep your device protected.

11. Changes

We will post any changes on this page and, for material changes, notify you in the app or by email before they take effect.

12. Contact

Taras Grygorovych Shevchenko, private entrepreneur (FOP), registered in Ukraine · nrg.ck.ua@gmail.com