Privacy policy

Draft for legal review. Version [version], effective [date]. [DO POTWIERDZENIA PRZEZ PRAWNIKA: całość]

This policy explains what Huddo keeps about you, why, who sees it and what you can do about it. Huddo is an app for adults who want to stop using vapes or nicotine pouches together with a few friends.

Who is responsible

[Full name or company name of the controller], [postal address], is responsible for your data (the "controller"). Contact for anything about your data: [contact e-mail address].

[Data protection officer or EU / UK representative, if one is required.] [DO POTWIERDZENIA PRZEZ PRAWNIKA]

The short version

Health information

Using Huddo says something about your health: that you use nicotine and want to stop. The following is treated as health information:

InformationWhyWho sees it
Your answer to the evening question, yes or no, and when you gave itto keep or restart the shared timeronly you
Your status for today: in, not yet or slipped, and whether you missed the previous eveningto show your pact who has answeredyou and the members of your pact
Your usual daily spendto count what the pact savesonly you; the pact sees only the total of all members
The times you send an SOS, and the notification it createsto tell your pact and to limit SOS to one every 15 minutesthe members of your pact get the notification
The shared timer, the last restart and the saved amount of your pactthe main screen of the appthe members of your pact
What you want to stop (vapes, pouches or both)to word the first screensonly you; it stays on your phone and is deleted when your pact starts

The legal basis is your explicit consent (GDPR Article 9(2)(a) and Article 6(1)(a)), which the app asks for before your pact starts, with two boxes that are not ticked in advance. The app keeps a record of which version of the consent text you agreed to and when. [DO POTWIERDZENIA PRZEZ PRAWNIKA: podstawa prawna; dowód zgody dziś zostaje na telefonie, patrz release/CONSISTENCY.md C-2]

You can withdraw your consent at any time in Settings, Withdraw consent. Huddo cannot work without this information, so withdrawing deletes your account and your data and takes you out of your pact. Withdrawing does not make earlier processing unlawful.

What the pact can work out. The shared amount grows by the sum of every member's usual daily spend. In a pact of two, the other person can subtract their own spend from the total. In a pact of any size, the amount changes by exactly one person's spend when they join or leave. Your exact spend is never shown to anyone, but the people in your pact can work it out.

Other information Huddo keeps

InformationWhyLegal basisWho sees it
A random account id created when you start or join a pact (no e-mail, no phone number, no password)to know which pact and data are yourscontract (Art. 6(1)(b))nobody but the app
Your display name and the shape you pickedso your friends know who is whocontractthe members of your pact, and anyone who opens a live invite link to your pact
The name of your pactshown on the main screen and on the invite pagecontractthe members, and anyone with a live invite link
Your time zone and currency (set by whoever starts the pact)the day closes at midnight in that time zone; the amount is shown in that currencycontractthe members
A push token for your phoneto send notifications from your pact (Nudge, SOS, the timer restarting). The evening question is scheduled on your phone and needs no tokencontractnobody but the app
The times you nudged someoneto limit Nudge to one per person per hourlegitimate interest in preventing nuisance (Art. 6(1)(f))the nudged person gets the notification
Reports you make or that are made about you: the names at that moment, the reason and an optional noteto keep pacts free of abuselegitimate interest; Google Play rules for user contentthe controller only; nobody in the pact is told
Your purchase: a random billing id, the subscription, its renewal and expiryto know whether the pact is paid forcontract; legal obligation for tax records (Art. 6(1)(c))RevenueCat and Google Play
Anonymous usage counts: which of 14 fixed events happened (for example "pact created", "paywall viewed"), with the app version, phone model and systemto see which parts of the app worklegitimate interest [DO POTWIERDZENIA PRZEZ PRAWNIKA: czy wymagana zgoda (ePrivacy art. 5 ust. 3)]PostHog
Error reports: what failed in the app, the app version, phone model and system, a random id of the installto fix crasheslegitimate interestSentry
Server request logs: time, IP address, device typesecurity and fixing faultslegitimate interestGoogle Cloud

Huddo does not collect your e-mail address, phone number, contacts, location, photos or year of birth. The age question is asked once on the phone; only the fact that you said you are an adult is kept, on the phone.

Your health information is never put in notifications, analytics events, error reports, purchase records, store product names or logs.

What others can see without opening the app

Who processes your data for us

CompanyWhat forWhereSafeguard for transfers
Google (Firebase, Google Cloud)database, sign-in, server functions, web pages, logsEuropean Union (Firestore eur3, functions europe-west1); some Firebase services are globalGoogle Cloud data processing terms; standard contractual clauses / EU-US Data Privacy Framework [DO POTWIERDZENIA]
Google (Firebase Cloud Messaging)delivering notificationsglobalas above
RevenueCat, Inc.checking purchases and renewalsUnited StatesRevenueCat DPA with standard contractual clauses [DO POTWIERDZENIA]
PostHog Inc. (PostHog Cloud EU)anonymous usage countsEuropean Union (Germany)PostHog DPA [DO POTWIERDZENIA]
Functional Software, Inc. (Sentry, EU data storage)error reportsEuropean Union (Germany)Sentry DPA [DO POTWIERDZENIA]

Full list with contacts: [https://domain/privacy#processors] (legal/subprocessors.md).

Payments are made through Google Play. Google is responsible for its own processing of your payment and your Google account under the Google Privacy Policy.

Huddo does not sell your personal information and does not share it for advertising. The app contains no advertising and no advertising id.

How long

InformationKept
Your account, name, shape, push tokenuntil you delete your account
Your status, answers and daily spenduntil you leave the pact or delete your account
Pact name, timer and saved amountuntil the last member leaves; the saved amount stays in the pact, with no name on it, after you leave
Notifications waiting to be sent7 days
Invite links7 days
Reports[period, for example 12 months after the report is closed] [DO POTWIERDZENIA PRZEZ PRAWNIKA]
Purchase records[period required by tax law] [DO POTWIERDZENIA PRZEZ PRAWNIKA]
Error reports[Sentry retention, 90 days on the current plan] [DO POTWIERDZENIA]
Usage counts[PostHog retention] [DO POTWIERDZENIA]
Server request logs30 days [DO POTWIERDZENIA]

Deleting your account

In the app: Settings, Delete account. This deletes, at once, your sign-in account, your name, shape, answers, daily spend, status, push token and the notifications to or from you, and takes you out of your pact. Without the app, use [https://domain/delete-account] or write to [contact e-mail address]; we answer within one month.

What stays after deletion: the money your pact has saved stays in its jar as a number with no name; the pact's timer stays as it is; reports you made stay without your id; reports about you stay for the period above as a safety record; purchase records stay for the period tax law requires. Deleting your account does not cancel a subscription. Cancel it in Google Play, under Payments and subscriptions.

Your rights

You can ask for access to your data and a copy of it, correction, deletion, restriction, portability, and you can object to processing based on legitimate interest. Write to [contact e-mail address]. We answer within one month. You can complain to a data protection authority, in Poland the President of the Personal Data Protection Office (UODO, uodo.gov.pl), or the authority where you live. [DO POTWIERDZENIA PRZEZ PRAWNIKA]

Adults only

Huddo is only for people aged 18 or over. The app asks for your year of birth before anything else and does not keep it. If we learn that someone under 18 uses Huddo, we delete their account.

Security

All traffic between the app and our services is encrypted (HTTPS / TLS). Data at rest on Google Cloud is encrypted by Google. The database refuses every write from the app except your own push token; every other change goes through server functions that check who you are and that you are in the pact. Only the people who run Huddo can open the database console, with two-step verification. [DO POTWIERDZENIA: kto ma dostęp]

If a breach puts your data at risk, we tell the supervisory authority within 72 hours and tell you without undue delay.

Consumer health data privacy policy (Washington and other US states)

This section is the consumer health data privacy policy required by the Washington My Health My Data Act (RCW 19.373) and similar laws in other US states. [DO POTWIERDZENIA PRZEZ PRAWNIKA: Nevada SB 370, Connecticut]

Categories of consumer health data we collect, and why. Your daily yes or no answer about staying within your own limit; your status for the day (in, not yet, slipped) and missed evenings; your usual daily spend; the times you send an SOS; the shared timer and its restarts; what you want to stop (kept on your phone only); and the fact that you use an app about stopping nicotine, which can be inferred from your account, push token and purchase. We use it only to run the shared timer, show your pact who has answered, count what the pact saves, and send the notifications you expect.

Sources. You, through the app. Your pact members' actions change shared data (the timer, the saved amount).

Categories of consumer health data we share. Your status for the day, the shared timer and the saved amount are shown to the members of your pact, which you choose to join. The notification that you asked for support is sent to them. We do not sell consumer health data.

Third parties and affiliates we share it with. Members of your pact (other users you invited or who invited you). Processors acting on our behalf: Google (Firebase, Google Cloud, Firebase Cloud Messaging). No other third parties and no affiliates. RevenueCat, PostHog and Sentry do not receive consumer health data, apart from the fact that you use the app.

Your rights. You can confirm whether we collect your consumer health data, access it, see the list of third parties above, withdraw consent, and have it deleted: in the app (Settings, Delete account) or by writing to [contact e-mail address]. We answer within 45 days. If we refuse, you can appeal by replying to our answer; if the appeal is refused you can contact the Washington State Attorney General (https://www.atg.wa.gov/file-complaint). [DO POTWIERDZENIA PRZEZ PRAWNIKA]

Changes

When this policy changes, the new version is published here with a new date. If a change affects what you agreed to, the app asks you to agree again before you continue.

Processors (subprocessors)

Draft, 13.10.2026. Derived from package.json and the services in src/services/ and functions/. Contract status: none of these contracts has been accepted yet; the owner accepts them when creating each account. [DO POTWIERDZENIA PRZEZ PRAWNIKA: każdy wiersz]

ProcessorServiceDataHealth dataLocationContract to acceptTransfer safeguard
Google Ireland Ltd / Google LLCFirebase Authentication, Cloud Firestore, Cloud Functions, Cloud Scheduler, Secret Manager, Cloud Logging, Firebase Hostingeverything stored for the app (legal/data-map.md section 1)yesEU: Firestore eur3, functions europe-west1; Authentication is globalGoogle Cloud Data Processing Addendum (accepted in the Cloud console, Privacy & Security)SCC / EU-US Data Privacy Framework [DO POTWIERDZENIA]
GoogleFirebase Cloud Messagingpush token, notification title with a display nameyes (an SOS notification)globalas above (Firebase terms)as above
RevenueCat, Inc. (USA)purchase validationrandom billing id, purchase tokens, app and OS versionno; the RevenueCat DPA forbids Art. 9 data, and the app sends noneUSARevenueCat DPA, https://www.revenuecat.com/dpa/SCC
PostHog Inc. (PostHog Cloud EU)product analyticsevent names from a closed list, random id, device and app defaultsnoEU (Frankfurt)PostHog DPA (in the PostHog account)not needed for EU hosting; PostHog's own subprocessors [DO POTWIERDZENIA]
Functional Software, Inc. (Sentry), EU data storageerror reportserror stack, device and app data, random install idnoEU (Germany)Sentry DPA (in the Sentry organisation settings)SCC for support access from the USA [DO POTWIERDZENIA]
650 Industries, Inc. (Expo)EAS Buildsource code at build time; no user datanoUSAExpo terms and DPA [DO POTWIERDZENIA]SCC / DPF [DO POTWIERDZENIA]

Independent controllers (not processors): Google Play / Google Commerce (store, payments, install referrer), the user's own Google account backup (see release/CONSISTENCY.md C-1).

When a processor is added or changed: update this file, legal/data-map.md, the privacy policy table "Who processes your data for us", and the Data safety answers in release/app-content.md.