Privacy Policy
Last updated: [DATE]
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
| Category | Examples | Source |
|---|---|---|
| Account | Email address, display name, profile photo, bio; identifiers from Google or Apple if you sign in with them | You, sign-in provider |
| Content | Videos you upload, captions, likes, follows, reports and blocks | You |
| Moderation records | Automated safety scores of your uploads, moderation decisions and their reasons, strikes | Us |
| Device and usage | App version, device model, operating system, language, crash reports, in-app events (for example views, likes, uploads) | Your device |
| Advertising | Advertising identifier and ad interactions, only where you have given consent where required | Your device |
| Notifications | Push notification token | Your device |
| Waitlist | Email address, language and whether you asked for creator access | You (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
| Purpose | Legal basis (EEA/UK) |
|---|---|
| Create and run your account; host, process and show your videos; likes, follows and notifications | Performance of our contract with you |
| Keep the community safe: automated and human moderation, handling reports, preventing abuse and fraud | Legitimate interests; legal obligations |
| Fix bugs and improve the Service using crash reports and aggregated usage statistics | Legitimate interests |
| Personalised advertising | Consent (you can withdraw it at any time in the app) |
| Non-personalised advertising that funds the free Service | Legitimate interests |
| Emails about the launch (waitlist) | Consent |
| Complying with law and responding to lawful requests | Legal 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:
- Google LLC / Google Ireland Ltd — Firebase (authentication, database, file storage, cloud functions, analytics, crash reporting, notifications), Google Cloud Vision (content moderation) and Google AdMob (advertising).
- BunnyWay d.o.o. (bunny.net, Slovenia) — video transcoding, storage and delivery.
- Sign-in providers you choose to use (Google, Apple).
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
- Account data and content: while your account exists. When you delete your account or a video, we delete it within 30 days.
- Moderation records and reports: up to 12 months after the decision, longer if needed for legal claims or to prevent repeat abuse.
- Crash reports and analytics: according to our providers' retention settings (up to 14 months).
- Waitlist emails: until launch plus 6 months, or until you unsubscribe.
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