Privacy Policy

Last updated: October 20, 2026 · Version 2.4 (replaces version 2.3 of October 20, 2026) Effective: immediately (it completes the information on processing already in place, § 14). Earlier versions are available on request at privacy@hahoowa.app.

Summary (level 1)

• Who processes your data? Hahoowa Medias Services SARL AU (Casablanca, Morocco).
• Where is it? Our database and your files are hosted in the European Union (AWS, Paris region). Some providers located outside the EU process part of it, in particular the video of lives (Section 4).
• Do we sell it? No. Never.
• Advertising? Chosen according to your language, your country and the city in your profile, never according to your behavior or sensitive data, and never targeted at minors (§ 8).
• Do we read your private messages? No — we do not analyze the text of your messages. Only shared images and voice messages are checked against prohibited content.
• In lives? By default, you support discreetly: other viewers see neither your name nor your photo when you send a gift, and your arrival is not announced (§ 2.4).
• Your rights? Access, rectification, erasure, objection, portability — exercisable in one place: privacy@hahoowa.app or Settings → "Export my data" / "Delete my account".
• A question? privacy@hahoowa.app, our data protection contact.

The full details follow (level 2).

1. Who is responsible for your data

Controller:

• Hahoowa Medias Services SARL AU — 7, rue Ahmed Touki, Casablanca, Morocco. Operator of the platform and the entity you contract with.

Formalities with the CNDP (Law 09-08) — in progress; each number will be entered here as soon as it is received:

• declarations of processing: receipt No. … of … ;
• prior authorizations: authorization No. … of … ;
• transfers of data out of Morocco: authorization No. … of … .

Hahoowa Medias Services SARL AU determines the purposes and means of the processing described here. You may exercise your rights via privacy@hahoowa.app.

Representative in the European Union (Art. 27 GDPR): designation in progress — in the meantime, privacy@hahoowa.app is your point of contact and that of the EU authorities; the representative's contact details will be published here as soon as they are designated.

Data protection contact: privacy@hahoowa.app.

Listings between users. When you publish a listing, it may contain personal data (yours, sometimes third parties'). In line with European case law (CJEU, Russmedia, C-492/23, December 2, 2025), we act as joint controller for this data: our prior moderation detects manifestly problematic content, and we offer a fast erasure channel (privacy@hahoowa.app, subject line "Data in a listing"). You remain responsible for what you choose to publish: do not disclose other people's data without a legal basis.

2. What we collect, why, on what basis, and for how long

We process only what the Service needs. The table below cross-references, by purpose: the categories of data, the legal basis (GDPR Art. 6; Moroccan Law 09-08), the retention period, and the recipients (detailed in Section 4).

We do not collect card numbers, or sensitive data (health, religion, opinions, orientation) — unless you voluntarily publish them yourself, in which case you are responsible for it. The periods above are maxima that we commit to respecting, except where the table states that no retention period is applied yet: when they expire, the data is deleted or irreversibly anonymized.

Position of a listing. A listing's page shows only its city and neighbourhood. Its coordinates nevertheless accompany the listing in the data our servers send to apps and browsers, and are used to rank it by distance ("Near me"). To avoid publishing the exact position of a private place, choose the city by hand rather than "Use my location".

2.1 Professional seller file: public display

DSA Art. 30(2) requires us to display professional sellers' information on the platform. Once your file is approved, the following fields are public, on each of your listings and on your storefront: company name, address, city, business phone and email, registration type and number, self-certification date. The form informs you of this before submission. Use business contact details — that is what they are for. Any change to the file suspends the display until re-validation; deleting the account deletes the file.

2.2 Identity verification and bank details

• Why. Before any payout of earnings, we check that you are 18 and that you are the person who will be paid (prevention of fraud and impersonation).
• How. The images of your document and your selfie are kept in private storage, never published. They are viewed only by the team in charge of verifications, through links valid for 5 minutes, and each viewing is logged. The selfie is compared with the document by a person, by eye: no facial recognition or other automated biometric processing is used.
• IBAN. Your IBAN is encrypted; the app only shows its last 4 characters. It is decrypted only to make a transfer, by an authorized person, and each display is logged. The account holder's name is compared with your verified name.
• Retention. See the table above.

2.3 Balance and purchases

Balance purchases are made through the App Store or Google Play: they collect the payment and send us neither your name nor your card data, only the product, the transaction and its status. We link them to your account through a random customer identifier, distinct from your public identifier. Before your first spend on a service performed immediately, your consent to immediate performance is recorded (Terms of Service, Art. 3.4).

2.4 What others see of you during a live

• Amounts. The public sees no totals: neither what you have spent, nor what a live has received. The supporter ranking shows ranks. The public sees the gift sent, whose price is in the catalogue, and a super-chat shows its tier. The host sees what they receive.
• Name and photo. By default, you support discreetly: other viewers see "A supporter", without your name or photo, and your arrival in a live is not announced. If you turn on "Show my name" (in the gift sheet, or "My name in lives" in Settings → Privacy → Lives), a screen first shows you what everyone will see; then your name and photo accompany your gifts, your position in the ranking and your arrival, visible to all viewers, including those without an account. This display rests on your consent (GDPR Art. 6(1)(a); Law 09-08 Art. 4) and is only available to an account that has attested being 18 or over; each activation and each withdrawal is recorded, with its date, the version of the text shown and the language. You withdraw it at any time in the same place. The setting applies at display time: when you go back to discreet, your past gifts become anonymous again, except an animation already shown and screenshots others may have taken.
• What always remains visible. The host always sees your identity and what you give them (to thank you or block you), as does the Hahoowa team (moderation). Your written messages and your super-chats are always signed with your name: you publish them yourself, and everyone answers for what they write. A super-chat also shows its tier ($1, $5, $25 or $100); it may therefore hint at your position in the ranking.
• Minors. An account declared or found to be a minor's cannot spend anything and always stays discreet (§ 11).
• Data processed. The "Show my name" choice is recorded on your account and in the consent log; it is included in your data export and never shown on your public profile. The live rules prohibit revealing who is behind "A supporter".

3. Deleting your account

When you delete your account (Settings → Account → Delete my account), deletion takes effect immediately:

1. Active systems: your profile is anonymized; your listings, Spots, Drops, posts and comments are removed from public surfaces; your sent messages are emptied of their content; your social graph (follows, blocks, favorites, reactions), your professional seller file, your notification tokens and your personal telemetry are physically deleted; your media files are erased from our servers, including the photos, voice sample and working files of your presenters, and the videos you ordered from the AI studio; your lives are removed, their replays become unreachable and their video recording is deleted at our provider (Mux) — unless a report under review requires it to be kept, in which case it stays unreachable to the public and is kept only for as long as it takes to handle that report; the messages you wrote in live chats are deleted; your payout account is deleted, and the images of your identity verification are erased in the following daily purge; your authentication account is deleted.
2. Backups: technical backup copies permanently expire within 30 days at most.

The right to erasure is offered to all users, not only in the EU. The following survive deletion, in a limited and justified way: financial records (balance ledger, earnings, payouts with the details locked onto each request, giving up of earnings — accounting obligation, 10 years, GDPR Art. 17(3)); moderation records (reports, decisions, sanctions, appeals: 5 years — establishment and defense of legal claims); the order and listing records necessary for the integrity of other users' transactions and for disputes, with your profile anonymized in them and your buyer contact details erased 30 days after the order closes. Not erased today: the cloned voice at WaveSpeed, which offers no technical means of deleting it and which we ask to delete it (§ 2, "Presenters and voices") and the contact requests you have received or sent (§ 2, "Contact requests"). On request, we provide you with a time-stamped proof of erasure.

Money left. The unspent part of your balance is lost (Terms of Service, Art. 3.5): the deletion screen shows its amount and asks you to tick that you accept losing it; this acceptance is recorded. Unwithdrawn creator earnings do not block deletion: you may request their payout, or expressly give them up, at the exact amount shown (Terms of Service, Art. 3.12). Deletion remains impossible while you have orders to fulfil as a seller, a payout in progress or active paying subscribers (Terms of Service, Art. 12.4).

4. Who we share with — our processors and joint controllers

We do not sell your data. We share it only with the providers necessary for the Service, bound by contract (Art. 28 GDPR), and with the services you choose to use (signing in with Google, Apple or Facebook, your phone's location, your browser's notifications), which are responsible for their own part. The up-to-date list is maintained in this policy:

"SCCs or DPF": the European Commission's standard contractual clauses, or the EU–US Data Privacy Framework for companies certified under it (Section 5). MaxMind supplies the IP geolocation database we query on our own servers: it receives no data. A provider removed from the product no longer receives any data (HeyGen, removed in July 2026, is one example). Hahoowa no longer uses any card payment provider: Stripe, used until September 2026, no longer receives any data; the history of those payments (amount, date, last four digits of the card) stays in our billing records (10 years).

5. Where your data resides, and international transfers

Storage. Database, media and caches are hosted with AWS in the European Union (Paris). We keep no second copy of this database outside the EU.

Two flows leave the EU:

1. Administration from Morocco. The platform is operated from Casablanca; its operator administers the systems from there (including the review of identity documents and the execution of transfers). Hahoowa applies the GDPR to this data, wherever it is accessed: encryption at rest and in transit, least-privilege access, logging of sensitive access.
2. Processors. Those in Section 4 located outside the EU receive only the data described; they are covered by the European Commission's standard contractual clauses or by the EU–US Data Privacy Framework, for companies certified under it.

Morocco → abroad direction. Moroccan Law 09-08 governs transfers of data out of Morocco (prior authorization by the CNDP towards a country that does not ensure adequate protection). These formalities are in progress; their reference numbers will appear in Section 1 as soon as they are received. You can obtain a copy of the applicable safeguards at privacy@hahoowa.app.

6. Automated analysis of content (moderation) and of messages

Public content. Every piece of content you publish — including your display name, your bio, your profile and cover photos, and your storefront images — is automatically analyzed (by Google Gemini and our systems) to detect what is prohibited (see the Community Guidelines). This analysis rests on our legitimate interest in offering a safe and lawful service. No decision producing significant legal effects is taken in a fully automated way without the possibility of human recourse: sensitive cases (defamation, impersonation, dangerous false information, political advertising) are always decided by a human, and you can challenge any decision (Terms of Service, Art. 9; DSA Arts. 20-22; GDPR Art. 22).

Lives. During a live, our servers take about one frame per minute, from the host as from the guest on screen, and have it analyzed automatically. The frame is not kept; only the verdict is. A live that breaks the rules can be stopped automatically: its replay is removed and its author cannot start a live for 24 hours; a guest who breaks the rules is removed from the screen. Chat messages, super-chats included, are analyzed just after they are posted; a rejected super-chat is removed and refunded (Terms of Service, Art. 3.6.2). An "immediate danger" report alerts our team as a priority. For lives broadcast from software, a system locates the person in the picture (a simple box, with no identification) to place the animations; these positions are not kept.

Orders and support. When you reply in free text to the WhatsApp message confirming an order and our system does not understand the reply, Gemini reads it to work out what you mean; in case of doubt, nothing is confirmed or cancelled: the order goes back to the seller. When automatic triage is turned on, Gemini also reads your help requests to determine their language, topic and urgency; a member of our team handles them. The shopping assistant answers your questions about a listing from the listing alone, and refers you to the seller for anything else.

Private messages. We do not analyze the text of your private messages, and we never use them for advertising or profiling purposes. Images and voice messages shared in private messages are automatically checked against the prohibited categories (protection of users and minors, legitimate interest); only the verdict is kept in the moderation logs. To alert you to a new message, the notification shows the sender's name and the beginning of the message (140 characters at most); this text goes through Expo, then Apple or Google, or through your browser's notification service (§ 4). A voice message, a photo or a document is announced only by its type.

7. Recommender systems

The "For You" feed, the "Live" directory, search and suggestions are ranked by automated systems whose main parameters are described in the Terms of Service (Art. 7). You can influence this ranking and disable personalization when logged out (see Section 9, hahoowa_did identifier). We never base a recommendation on sensitive data. A live's supporter ranking is calculated from the gifts and super-chats received in that live; it is used for nothing else.

8. Advertising

An ad is shown to you if you match the criteria chosen by the advertiser, among: the app's language, the country estimated from your IP address (failing that, your account's country), the city declared in your profile (one city, a list of cities, a region or a radius around a city) and your account's use (creator or buyer). A visitor without an account is targeted only by their language and country. Your history, your taste profile, your interests and your age are not used to choose ads. A sponsored post that is selected then takes its place in the feed among the other content, at a position calculated like the rest of the feed (§ 7). We practice no targeting based on sensitive data, and no advertising targeted at minors (DSA Arts. 26(3) and 28(2)). If you tap "I'm interested" on an ad, your account's name, email and phone are passed on to the advertiser, who may get back to you. Every ad is labeled "Sponsored", including a live promoted for payment. Impressions and clicks are counted to bill the advertiser and to limit how often the same ad is shown; they are kept for 13 months (§ 2). Paid political advertising is prohibited (Terms of Service, Art. 6.2).

9. Cookies and storage on your device (web and app)

Hahoowa loads no third-party tracker: no advertising pixel, no audience-analytics suite, no session recorder. What we store:

We ask for your consent before creating the personalization identifier. "Decline" is as simple and visible as "Accept" (no dark patterns). If you decline, the identifier is not created — and any existing identifier is deleted. The question is asked again at least every 13 months. You can change your choice at any time via the "Cookies" link in the footer.

In the mobile app. The app includes no third-party advertising or audience-measurement tool; it reports its crashes to Sentry (Section 4). It keeps on your phone your session, your language, for a visitor the answer to the lives age question, and the invitation link opened before you sign up (30 days at most, like hw_ref). The web rule applies to the device identifier hahoowa_did, which personalizes the feed when you are logged out: it is sent to our servers only with your consent; without consent, the app works without it.

10. Your rights

You may at any time: access your data, rectify it, erase it (subject to the legal retentions of Section 3), object to a processing operation (e.g. marketing or audience measurement), restrict its processing, exercise portability (machine-readable export — Settings → "Export my data"), and withdraw any consent, including the display of your name in lives.

These rights are open to you whether you are in the EU (GDPR), in Morocco (Law 09-08), in California (CCPA) or elsewhere. Contact: privacy@hahoowa.app from your account's address, or directly in the Settings. We respond within 30 days (rectifications within 10 business days for Moroccan residents, in line with CNDP practice). A penalized account keeps access to its rights: the "Account Status" page, export and deletion remain accessible.

You can lodge a complaint with your authority: CNDP (Morocco), CNIL (France) or the authority of your Member State, your State Attorney General (USA), etc.

11. Minors

• Accounts: 18 and over. Accounts are reserved for people aged 18 or over, who attest to it at sign-up (Terms of Service, Art. 4).
• Watching lives without an account: 13 and over. A visitor gives their month and year of birth; the answer stays on their device and no age data is sent to us. Under 13, lives are not shown.
• Money: 18 and over. Buying balance, gifts, super-chats, promoting a live and any other spending are reserved for accounts that have attested being 18 or over. A visitor can buy or send nothing.
• A minor's account. An account declared to be a minor's, or that we learn is held by a minor, is restricted at once: no spending, no broadcasting, supports always discreet. It is closed 14 days later, using the deletion procedure of Section 3; we notify it in the app and by email, with the date. Until then, it can export its data, and the closure is cancelled if the declaration was a mistake corrected through support. If its balance holds purchases, they are not lost: support helps get them refunded by the store before the closure. We do not knowingly collect other data about minors.
• Advertising. A visitor without an account is targeted only by their language and country; no ad targets minors (§ 8).
• Parents. The device's parental controls (Screen Time and "Ask to Buy" on Apple, Family Link and purchase approvals on Google) can block in-app purchases. If your child under 18 has created an account, write to privacy@hahoowa.app.

12. Provenance of AI-generated content

The videos and images produced by Hahoowa's AI studios carry a visible "AI-generated" label and are recorded in an internal provenance registry that allows them to be identified on all the surfaces where they circulate — this is our implementation of synthetic-content transparency (AI Act, Art. 50). This marking is not personal data about you; it identifies the synthetic origin of the content.

13. Security

TLS encryption in transit; encryption at rest for databases and media (AWS); additional encryption of IBANs with a dedicated key (AWS KMS); private storage of identity documents; passwords stored only as hashes; least-privilege role-based access control; logging of sensitive administrative actions (including viewing an identity document or an IBAN). No system is perfectly secure: use a strong, unique password, and notify us at privacy@hahoowa.app of any suspected incident.

14. Changes

Changes that extend a processing operation or reduce your rights are notified in the app and by email at least 30 days before they take effect. Those that strengthen your protection (for example a more discreet default setting), or that complete the information on processing already in place, apply as soon as they are published, with notice. Earlier versions are available on request at privacy@hahoowa.app.

15. Contact

• Data protection contact: privacy@hahoowa.app
• EU representative (Art. 27 GDPR): designation in progress — interim contact privacy@hahoowa.app
• Supervisory authorities: CNDP (Morocco), CNIL (France) or your national authority
• Postal address: see Art. 20 of the Terms of Service