Privacy Policy for Havira
This Privacy Policy works together with our Terms of Service. Please review both documents to understand your rights and obligations.
1. Introduction
Welcome to Havira ("we," "our," or "us"). This Privacy Policy explains how Engin Deniz Usta collects, uses, discloses, and protects your personal information when you use the Havira mobile application and related services (collectively, the "Service").
We are committed to protecting your privacy and ensuring transparency about our data practices. This policy complies with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy laws.
Contact Information:
- Service Provider: Engin Deniz Usta
- Email: support@edusta.dev
- Address: Brennerei 2, 82024, Taufkirchen, Germany
2. Information We Collect
We adhere to the principle of data minimization as required by Article 5(1)(c) GDPR, collecting only the personal information that is necessary for the specific purposes outlined in this Privacy Policy.
2.1 Information You Provide
- Account Information: User ID and authentication credentials (provided through Firebase Authentication)
- Email Address: Email addresses may be collected through Firebase Authentication and are used solely for the purpose of fulfilling data export requests and other account-related communications as necessary for the provision of the Service
- Video Generation Data:
- Text Prompts: Text descriptions you provide for video generation
- Reference Images: Images you upload to guide video generation (maximum 1 image for OpenAI Sora, up to 3 images for Google Veo)
- Processing: Reference images and prompts are processed for video generation and content moderation purposes
- Retention: Reference images are stored temporarily during video generation and are deleted when you delete your account or video request as described in Section 6
- Payment Information: Transaction data processed through RevenueCat (we do not store credit card details)
2.2 Automatically Collected Information
- Usage Data: Information about how you use our Service, including videos generated and features accessed
- Device Information: Device type, operating system, unique device identifiers, and mobile network information
- Log Data: IP address, access times, app crash reports, user identifiers, and other information necessary for operational, security, and compliance purposes
2.3 Information from Third Parties
- Authentication Data: We use Firebase Authentication to manage user accounts
- Payment Data: RevenueCat provides us with transaction information for in-app purchases
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Essential Services (Legal Basis: Contractual Necessity)
- Providing and maintaining the Service
- Processing your video generation requests
- Managing your token balance and transactions
- Authenticating your identity and managing your account
- Processing payments and preventing fraud
3.2 Service Improvement (Legal Basis: Legitimate Interest)
- Collecting anonymized analytics data to analyze usage patterns and improve our Service
- Anonymized analytics are collected automatically and do not include personally identifiable information (PII) or user IDs
- This data helps us develop new features, fix technical issues, and improve the overall user experience
- Anonymized analytics collection cannot be disabled as it is necessary for service improvement under our legitimate interest
3.3 Communications (Legal Basis: Legitimate Interest / Consent)
Push Notifications (Consent-based):
With your explicit consent, we send push notifications about:
- Video generation status updates (completed, failed, processing)
- Important service announcements and updates
You can manage notification permissions through your device settings at any time.
Email Communications (Legitimate Interest):
- Responding to your requests and inquiries
- Sending critical service updates and account-related information
- Data export delivery (as requested by you)
3.4 Analytics (Legal Basis: Consent)
- With your explicit consent, we use Google Analytics with full tracking capabilities, including linking analytics data to your user account
- When consent is granted, analytics data is linked to your account ID for better insights and personalization
- When consent is denied, we still collect anonymized analytics (see Section 3.2) but without linking data to your account
- You can grant or withdraw this consent at any time through the app settings (Settings → Privacy → Analytics & Data Collection)
- Important: Even when you disable the Analytics consent toggle, anonymized analytics collection continues automatically for service improvement purposes (see Section 3.2)
3.5 Legal Compliance and Audit Logging (Legal Basis: Legal Obligation / Legitimate Interest)
- Complying with applicable laws and regulations
- Responding to legal requests and preventing misuse
- Maintaining transaction and security-related audit records as required by law
- Recording security- and compliance‑relevant actions (such as account deletion, data export, and certain admin actions) in append‑only audit logs
- Maintaining operational logs containing user identifiers and system information necessary for security monitoring, debugging, and compliance purposes
4. Third-Party Services
We use the following third-party services to provide and improve our Service:
4.1 OpenAI (Sora and Moderation API)
- Purpose: Video generation from text prompts and reference images (max 1 image); content moderation and safety checks
- Data Shared: User-provided text prompts and reference images (if uploaded)
- Processing: Your prompts and images are sent to OpenAI's API for processing and generation
- Privacy Policy: https://openai.com/policies/privacy-policy
4.2 Google (Veo)
- Purpose: Video generation from text prompts and reference images (up to 3 images)
- Data Shared: User-provided text prompts and reference images (if uploaded)
- Processing: Your prompts and images are sent to Google's API for processing and generation
- Privacy Policy: https://policies.google.com/privacy
4.3 Google Firebase
- Purpose: User authentication and push notifications (FCM)
- Data Shared: User authentication data, device tokens
- Privacy Policy: https://firebase.google.com/support/privacy
4.4 Google Analytics
- Purpose: Usage analytics (optional, requires consent for full tracking with account linking)
- Data Shared:
- When consent is granted: App usage data linked to your account ID
- When consent is denied: Anonymized app usage data without account linkage (see Section 3.2)
- Privacy Policy: https://policies.google.com/privacy
- Control: You can enable or disable full analytics (with account linking) in app settings. Anonymized analytics collection continues automatically regardless of this setting
4.5 RevenueCat
- Purpose: In-app purchase management and subscription processing
- Data Shared: Transaction data, user ID
- Privacy Policy: https://www.revenuecat.com/privacy
4.6 Google Cloud Platform
- Purpose: Storage of generated videos
- Data Shared: Generated video files
- Privacy Policy: https://cloud.google.com/terms/cloud-privacy-notice
4.7 Google AdMob (Future Implementation)
- Purpose: If implemented, for displaying advertisements
- Data Shared: Device identifiers, usage data (with your consent)
- Privacy Policy: https://support.google.com/admob/answer/6128543
- Note: Not currently active; you will be notified and asked for consent before implementation
5. Your Privacy Choices and Rights
5.1 Consent Management
You can control the following consent preferences in the app:
- Required: Terms of Service and Privacy Policy acceptance (required to use the Service - processed under contractual necessity, not consent)
- Analytics: Google Analytics tracking with account linking (optional, requires consent)
- Marketing: Marketing communications and future advertising (optional, requires consent)
Important:
"Required" processing is not based on consent but on contractual necessity under Article 6(1)(b) GDPR. This means we must process certain data to provide the Service you've requested. The Analytics and Marketing categories are genuinely optional and based on your consent, which you can withdraw at any time without affecting the core functionality of the Service.
Note on Anonymized Analytics:
Even if you disable the Analytics consent toggle, we will continue to collect anonymized analytics data for service improvement (see Section 3.2). This anonymized data does not include your user ID or any personally identifiable information. The Analytics toggle controls whether analytics data is linked to your account; it does not stop anonymized analytics collection.
To manage your consent preferences:
- Open the Havira app
- Go to Settings → Privacy & Consents
- Toggle your preferences for Analytics and Marketing
5.2 Your Rights Under GDPR (EU Users)
If you are located in the European Economic Area (EEA), you have the following rights:
- Right of Access: Request a copy of your personal data
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure: Request deletion of your data ("right to be forgotten")
- Right to Restrict Processing: Request limitation of processing
- Right to Data Portability: Receive your data in a machine-readable format
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
5.3 Your Rights Under CCPA (California Users)
If you are a California resident, you have the following rights:
- Right to Know: What personal information we collect, use, and disclose
- Right to Delete: Request deletion of your personal information
- Right to Opt-Out: Opt-out of the sale of personal information (Note: We do not sell personal information)
- Right to Non-Discrimination: Equal service regardless of exercising your rights
5.4 Exercising Your Rights
To exercise any of these rights:
Data Export:
- Open the Havira app
- Go to Settings → Privacy
- Tap "Export My Data"
- You will receive a JSON file containing all your data via the email address associated with your account
Account Deletion:
- Open the Havira app
- Go to Settings → Account
- Tap "Delete Account"
- Confirm the deletion
Alternatively, email us at support@edusta.dev with your request.
We will respond to your request within:
- GDPR: 30 days (extendable by 60 days for complex requests)
- CCPA: 45 days (extendable by 45 days)
6. Data Retention
6.1 Active Accounts
We retain your personal information for as long as your account is active or as needed to provide you with our Service.
6.2 Account Deletion and Data Anonymization
When you delete your account using the in‑app tools, we:
- Delete your authentication data from Firebase Authentication
- Delete or clear your consent preferences
- Delete your device tokens (including push notification tokens)
- Delete your video requests and all generated content (videos, thumbnails)
- Delete all reference images you uploaded
- Delete all associated media files stored in our infrastructure
- Delete or anonymize related records in our databases where possible
For certain records, instead of full deletion we may anonymize the data by removing or replacing direct identifiers (such as your user ID) while retaining non‑identifiable information (for example, token transaction history or moderation events without a user link). This is necessary to:
- Comply with legal and accounting obligations
- Maintain accurate aggregate statistics about service usage
- Prevent abuse, fraud, and misuse of the Service
6.3 Legal Requirements
We may retain or anonymize certain records for legal and accounting purposes, including:
- Payment transaction data (as required by tax and financial regulations)
- Security and audit logs for fraud prevention and legal compliance
The retention period for such records typically does not exceed 7 years or as required by applicable law.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal information:
- Encryption: Data is encrypted in transit (TLS/SSL) and at rest
- Access Controls: Restricted access to personal data on a need-to-know basis
- Secure Infrastructure: Use of Google Cloud Platform with industry-standard security
- Regular Updates: Security patches and updates are applied promptly
- Authentication: Secure user authentication through Firebase
- Incident Response: We maintain procedures to detect, respond to, and report security incidents
Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours as required by GDPR Article 33. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay as required by GDPR Article 34.
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
8. Children's Privacy
Our Service is not intended for users under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@edusta.dev, and we will delete such information promptly.
9. International Data Transfers
We are based in Germany and process data within the European Economic Area (EEA). However, some of our third-party service providers may process data outside the EEA, including:
- OpenAI (United States): For video generation and content moderation
- Google (United States): For video generation (Veo), cloud infrastructure, and analytics
- RevenueCat (United States): For payment processing
When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions by the European Commission
- EU-U.S. Data Privacy Framework (DPF) for transfers to certified U.S. organizations
- Other appropriate safeguards as required by applicable data protection laws
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:
- Updating the "Last Updated" date at the top of this policy
- Sending you a notification through the app or via email
- For material changes, requesting renewed consent where required
We encourage you to review this Privacy Policy periodically.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Email: support@edusta.dev
Postal Address:
Engin Deniz Usta
Brennerei 2
82024 Taufkirchen
Germany
11.1 For EU Users (GDPR)
As a Germany-based service provider, we serve as the data controller for your personal information. You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your residence, place of work, or place of alleged infringement.
German Data Protection Authority:
Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Website: https://www.bfdi.bund.de
12. Legal Basis Summary
For quick reference, here's how we process your data:
| Purpose | Legal Basis (GDPR Article 6) | Can Opt-Out? | Reference |
|---|---|---|---|
| Account management | Contractual necessity (Art. 6(1)(b)) | No (service won't work) | Section 3.1 |
| Video generation | Contractual necessity (Art. 6(1)(b)) | No (core feature) | Section 3.1 |
| Payment processing | Contractual necessity (Art. 6(1)(b)) | No (required for purchases) | Section 3.1 |
| Service improvement | Legitimate interest (Art. 6(1)(f)) | Limited | Section 3.2 |
| Analytics | Consent (Art. 6(1)(a)) | Yes (in app settings) | Sections 3.4, 5.1 |
| Push notifications | Consent (Art. 6(1)(a)) | Yes (in device settings) | Section 3.3 |
| Marketing (future) | Consent (Art. 6(1)(a)) | Yes (in app settings) | Section 5.1 |
| Legal compliance & audit logs | Legal obligation (Art. 6(1)(c)) / Legitimate interest (Art. 6(1)(f)) | No (required by law) | Section 3.5 |
Note: "Required" functionality in the app settings (Section 5.1) refers to processing based on contractual necessity, not consent.
Thank you for trusting Havira with your personal information. We are committed to protecting your privacy and providing you with transparency and control over your data.