Draft: these documents are not final yet and have not been reviewed by a lawyer.

Privacy Policy

Last updated: 7 October 2026

1. Who is responsible for your data

The controller of your data is [TODO: nazwa firmy], [TODO: numer w rejestrze, np. Companies House / KRS], [TODO: adres siedziby] (“we”, “us”). For anything about personal data, write to pomoc@example.com.

This policy covers the Foocha mobile app and this website. Capitalised terms (such as Listing or Order) have the same meaning as in our Terms of Service.

2. In short

  • We only collect what the App needs: your email address, username, Listings, Orders and messages.
  • We never see your card details. Payments and Seller verification are handled by Stripe.
  • There are no ads, no analytics or tracking tools, and we don’t sell data.
  • Listings and Sellers’ average ratings are public. Proof videos and the chat are visible only to the parties to the Order and to us, unless the Seller allowed the Buyer to share the Proof video.
  • You can delete your account in the App (Profile → Delete account).
Data Why Legal basis (GDPR / UK GDPR)
Account: email address, username, date created signing in with an email code, showing you to others contract (Art. 6(1)(b))
Listings: video (picture and voice), poster (the video’s first frame), title, description, price, currency, status, link code; for an in-person Listing: approximate location (rounded to about 1 km), town and travel distance publishing your offer in the App and on the Listing page (share link) contract (b)
Moderation: transcript of the video’s audio, outcome, category, reasons detecting offers and content that break the law or our Terms legitimate interests: keeping the Platform safe and meeting our obligations on illegal content (f)
Orders: who bought what and when, amount, currency, status, deadlines, Stripe payment, transfer and refund IDs carrying out the Order, accounting contract (b), accounting and tax obligations (c)
Seller payouts: payout account country, Stripe account ID, whether payouts are active, amounts to pay out paying Sellers contract (b), tax obligations (c)
Completion and disputes: Proof video, message to the Buyer, reason for a Dispute, decision and its reasons accepting Tasks, deciding Disputes, responding to chargebacks contract (b), defending legal claims (f)
Chat: messages in an Order, “read up to” marker conversation between the parties, unread counts contract (b)
Ratings: the stars given to a Seller for an Order, the Seller’s average rating and number of ratings showing Buyers how Sellers do their Tasks contract (b), legitimate interests: trust between Users (f)
Feed: which Listings have already been on your screen and when last (on your phone; when you’re signed in, also with us, so that the feed remembers them on another phone) ordering the feed: unseen Listings first legitimate interests: showing you new offers (f)
Technical data: IP address, device and app type, request times, errors security, preventing abuse, fixing bugs legitimate interests (f)
Correspondence with us replying, complaints, content reports legitimate interests (f), legal obligations (c)

The App orders the feed on your phone. It uses the country set on your phone (region) and, if you allow it, the phone’s approximate location or a town you type in. We don’t send the location, town or country to our servers. To show in-person offers, the phone downloads from Cloudflare a file of offers for the area of roughly 20–40 km you are in. The file’s address identifies that area and appears in the provider’s logs together with your IP address.

If digital platform reporting rules require it, we will collect additional information from Sellers (such as a tax identification number) and report it to tax authorities together with their total income (c).

Giving us your data is voluntary, but you can’t create an account without an email address, and you can’t post a Listing without setting up payouts.

4. Data on your phone

  • The App stores your sign-in session and chosen language on your phone. It doesn’t use cookies or advertising identifiers.
  • It asks for access to your camera, microphone and photo library only when you record or choose a video. Videos are compressed on your phone before upload.
  • The App reads the country from your phone’s settings locally: it uses it to suggest your payout account country and to order the feed.
  • The App asks for your approximate location when you want to see in-person offers nearby or post an in-person Listing. Precise location isn’t needed, and you can type a town instead. The App reads the location only while it’s open. You can withdraw permission in your phone’s settings and change the town in your Profile. The lists of towns come from GeoNames (CC BY 4.0 licence).

5. Who can see your data

Other Users and anyone who opens the App (the feed and Listings can be viewed without an account) can see your username and your Listings. For an in-person Listing they also see the town, the travel distance and the approximate distance from them, measured from a point rounded to about 1 km, never the exact place. Anyone with a link to a Listing video can watch it. An active Listing also has a page on our website (the “Share” link) with the video, poster, title, description, price, username and ratings, and for an in-person Listing the town and travel distance; messaging apps show a preview from it (title, price, poster). Listing pages are kept out of search engines. Anyone can share the link and the Listing video with the Foocha banner outside the App; we have no control over such posts (Terms, section 13.5). The other party to an Order can see that Order, the chat and the Proof video. If you allow sharing in an on-video Listing, the Buyer can publish your Proof video (with the Foocha watermark) outside the App once the Order ends, e.g. on social media, where anyone may see it; we have no control over such posts (Terms, section 13.4). The App adds the watermark on the Buyer’s phone. Everyone can see a Seller’s average rating and number of ratings, but a single rating only the Buyer who gave it and we can see.

We have access to the data needed to run the Platform. We look at chats and Proof videos when handling a Dispute, a report of a violation or a chargeback, or when the law requires it.

Providers who process data on our behalf and on our instructions:

  • Supabase (database, sign-in, server functions). Data is stored on servers in Frankfurt (EU).
  • OpenRouter and the model providers it routes requests to (Listing moderation). We send them the video file to turn its audio into text and to assess its picture, and the title, description and transcript for assessment. We only use providers that don’t keep this data to train models.
  • Google LLC (Gmail) (sending sign-in code emails).
  • Cloudflare (storing and delivering videos, hosting this website). Videos are stored on servers in Europe.
  • Sentry (error and crash reports from the App and server functions: the error, phone model and system, App version and account ID, without email or content). Data is stored on servers in Germany (EU).
  • Expo (delivering App updates; push notifications, once we turn them on and you allow them).

Stripe handles payments and payouts. Payment details (such as your card) and the information Sellers give when setting up payouts (identity, date of birth, address, bank account, documents) are collected and processed by Stripe as a separate controller, under the Stripe Privacy Policy. We share Order details with Stripe, and in a chargeback also the Proof video and the chat.

Apple and Google distribute the App through their stores as separate controllers.

Public authorities, where the law requires it, such as tax or law enforcement authorities.

6. Transfers outside the EEA and the UK

Some providers (Stripe, OpenRouter and model providers, Google, Expo, Cloudflare, and Supabase and Sentry for technical support) are based in or operate from the United States. We transfer data on the basis of adequacy decisions (the EU-US Data Privacy Framework and its UK Extension) or standard contractual clauses. You can ask for a copy of these safeguards at pomoc@example.com.

7. How long we keep data

  • Account, Listings, moderation, viewing history: until you delete your account. When a Listing is deleted, its moderation results are deleted with it.
  • Chat, Proof videos and Disputes: 12 months after the Order ends (card chargeback deadlines, and they are our evidence), then we delete them.
  • Accounting data (Orders, amounts, payment IDs): [TODO: period required by accounting law, e.g. 6 years in the UK, 5 years in Poland].
  • After you delete your account, Orders, Disputes, the chat, Proof videos, ratings and the titles of Listings someone bought remain, because the other party can see them and we need them for accounting and chargebacks, for the periods above. Instead of your name they show “Deleted account”, and your email address is replaced with a hash it can’t be read from. Details: Delete your account.
  • Technical data: logs for a few days, depending on our providers’ settings; error reports in Sentry for 30 days.
  • Correspondence: until the matter is resolved and any related claims are time-barred.

8. Your rights

You have the right to:

  • access your data and get a copy of it,
  • correct your data (you can change your username in your Profile),
  • have your data erased (Profile → Delete account, or email us),
  • restrict processing,
  • data portability for data you gave us under our contract,
  • object to processing based on legitimate interests, including ordering the feed by viewing history.

Write to pomoc@example.com from your account’s email address. We will reply within one month.

You can complain to a supervisory authority: in the UK the Information Commissioner’s Office, in Poland the President of the Personal Data Protection Office (UODO), or the authority in the country where you live or work.

9. Automated decisions

Before publication, every Listing is assessed automatically by an artificial intelligence model (section 7 of our Terms). It may reject a Listing without human involvement when it clearly offers something prohibited. You have the right to express your point of view, contest the decision and ask for a review by a person: write to pomoc@example.com.

The order of the feed depends on what has already been on your screen, on the country set on your phone and on the distance to in-person offers. The feed doesn’t show in-person offers beyond the Seller’s travel distance. This doesn’t affect your rights.

10. Security

Connections to the App are encrypted. Access to data in our database is limited by rules that check who is a party to an Order. Proof videos are kept in private storage and open through links valid for one hour. Card data is processed by Stripe in line with the PCI DSS standard.

11. Children

The App is for people aged 18 and over. If we learn that someone younger has created an account, we will delete it.

12. This website

This website doesn’t use cookies or analytics and doesn’t load anything from third-party services. Listing pages show the video and poster from our video storage, also run by Cloudflare. Our hosting provider records IP addresses and browser data in server logs to deliver the site and protect it from attacks.

13. Changes

We will tell you about important changes to this policy in the App or by email. The date of the last change is shown at the top of this page.