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GDPR

What we keep, and why

Haminja needs your Telegram identity, your location and your album to work. Instead of hiding that, we say it plainly: this page lists every category of data, why we keep it, its legal basis and how long it stays. Every table here maps to one table in our database.

Version 1 · Last updated 5 October 2026

Text inside [[ ]] is replaced with official information before final publication.

Our principle

We keep your real identity, location and photo album because the product needs them: for "people near you", for introductions based on your real life, and so that messages actually reach you. In return we make four promises: we list every piece of data publicly here; we use each piece only for the stated purpose and enforce that in code; we encrypt everything in transit and at rest; and you can export and delete it yourself, without asking anyone.

The data table

This is exactly the table we committed to in the system design.

  • Telegram ID, username, first name, language

    Why we keep it
    Account, login, sending you messages, abuse prevention
    Legal basis
    Contract
    Retention
    Until account deletion (+1 year hashed tombstone)
  • Profile (name, age, gender, prompts, bio, interests, voice)

    Why we keep it
    Showing you to matches, matching
    Legal basis
    Contract / consent for special categories
    Retention
    Until deletion
  • Location (latest point or city)

    Why we keep it
    "People near you", distance display
    Legal basis
    Consent (revocable; city-only fallback)
    Retention
    Latest point only; 30 days after last activity
  • Album photos and derived tags/embeddings

    Why we keep it
    Profile display, finding people with similar life
    Legal basis
    Consent per photo visibility
    Retention
    Until you delete the photo
  • Assistant conversation and memories

    Why we keep it
    Your personal assistant remembers you
    Legal basis
    Contract
    Retention
    90 days (transcript), memories until you delete them
  • Chats with matches

    Why we keep it
    Delivering messages, safety screening
    Legal basis
    Contract
    Retention
    Until either side deletes, max 12 months inactive
  • Reports, blocks, moderation records

    Why we keep it
    Safety, legal obligations
    Legal basis
    Legitimate interest / legal
    Retention
    2 years
  • Verification result (yes/no + vendor reference)

    Why we keep it
    Keeping fake accounts out
    Legal basis
    Legitimate interest
    Retention
    Until deletion; vendor holds documents per its policy
  • Technical logs (IP, device, errors)

    Why we keep it
    Security, debugging
    Legal basis
    Legitimate interest
    Retention
    30 days

Our promises, in plain language

  • 1

    We never publish your data

    Your profile, photos and location are never shown anywhere outside Haminja. No search engines, no social networks, no public pages. Your coordinates are not even given to other users, only a rounded distance.

  • 2

    We never use it for another purpose

    Each piece of data is used only for what the table above says. No advertising, no profiling for resale, no vague "product improvement". This limit is enforced in code and in database roles, not just in this text.

  • 3

    We never train AI on your content

    Your messages, photos and conversations with the companion are not used to train any model, by us or by our AI provider. The companion's knowledge base contains only our own content.

  • 4

    We never sell it

    Not the data, not "aggregated insights", not user lists. Selling data will never be our business model.

Companies we work with

Only three categories of third parties touch any of your data, each for one defined job and under a data processing agreement (DPA).

  • Hetzner Online GmbH

    Role
    Hosting of servers, database and photo storage
    Where
    Germany (Falkenstein / Nuremberg)
    Notes
    All data and backups encrypted and EU-only. [[DPA_LINK]]
  • Veriff OÜ

    Role
    Selfie liveness check and age estimation
    Where
    Estonia (EU)
    Notes
    We keep only a yes/no result and a reference number; no identity documents are stored with us. [[VERIFICATION_VENDOR — being finalised]]
  • Anthropic, PBC

    Role
    Language models behind the companion and message safety screening
    Where
    United States
    Notes
    Content is sent only to generate a reply and is not used for model training. We use zero-data-retention terms for the models where that option exists; transfers are covered by a data processing addendum with EU Standard Contractual Clauses.

Retention, in plain language

The same table as above, as a list:

  • Account data: until you delete your account.
  • Location: only the latest point is kept, no history; deleted 30 days after your last activity.
  • Companion transcript: 90 days. The memories the companion keeps about you are visible to you, and you delete any of them yourself.
  • Conversations with matches: until either side deletes, or 12 months after the last message.
  • Reports and moderation records: 2 years (legal obligation).
  • Internal audit log: 1 year. Technical logs: 30 days.
  • "Delete my account" wipes everything within 24 hours. The only thing that remains is a hashed tombstone of your Telegram ID, kept for 1 year so that a banned person cannot return with a new account. Your identity cannot be reconstructed from it.
  • For users aged 15 to 17 the periods are halved: companion transcript 45 days, conversations 6 months, companion memories 30 days.

Your rights

You do all of this yourself, inside the bot or the Mini App, without writing to anyone. If something does not work, email us.

  • Export

    The /export command in the bot gives you a zip with all your data (JSON + photos). GDPR Articles 15 and 20.

  • Delete everything

    The /wipe command in the bot, or the "Delete account" button in the Mini App. Everything is gone within 24 hours. Article 17.

  • Withdraw location consent

    Switch to city-only or turn location off completely at any moment. The latest point is deleted immediately.

  • Withdraw album consent

    Per photo you choose: visible, visible only after an introduction, or used for matching only. Deleting a photo also deletes its derived tags and embeddings.

  • See and delete companion memories

    Under "Me" you see exactly what the companion remembers about you and delete any item.

  • Complain

    You have the right to lodge a complaint with the data protection authority of your EU country. List of authorities: edpb.europa.eu

Users under 18

In the EU the minimum age is 18 (Telegram's own terms). Outside the EU, users aged 15 to 17 can join, in a fully separate pool, with city-level location only, no precise point stored, and halved retention periods. Details on the Safety page.

Government and law-enforcement requests

We respond only to requests that come from a competent judicial authority in the country where the company is registered ([[ENTITY_COUNTRY]]) and through the official legal channel. Direct requests from other countries, including Iran, are not answered; the requester is told to use international judicial cooperation. Every request is reviewed by a lawyer, we notify the user wherever the law allows, and we publish request statistics here once a year.

Child sexual abuse material is the exception and is reported to NCMEC / IWF or the local authority as the law requires.

Data protection impact assessment (DPIA)

Because we process location, photos and (if you volunteer them) sensitive data, a full DPIA under GDPR Article 35 is maintained and updated with every significant change. You can request a summary by email.

Data requests contact

Haminja's data protection contact. Reply within 30 days at most, usually much sooner.

[[ENTITY]] — [[ENTITY_ADDRESS]]

privacy@haminja.club