Legal

Privacy Policy

Last updated 14 September 2026. Pre-launch version: the company details marked [●] will be completed before HangTing is publicly available.

This policy explains what personal data HangTing collects, why, who we share it with, how long we keep it, and the rights you have. We're based in Kenya, so Kenya's Data Protection Act, 2019 is our baseline; HangTing is available worldwide, and section 10 explains the extra rights you have under the GDPR, US state laws and other laws. We've tried to write it plainly. If anything is unclear, email privacy@hangting.app.

1. Who we are

HangTing is run by [●] Limited, a company registered in Kenya (registration number [●], registered office [●]). We are the data controller for the personal data described here. Our registration number with the Office of the Data Protection Commissioner (ODPC) is [●]. You can reach the person responsible for data protection at privacy@hangting.app.

2. What we collect

When you sign up

Email address, display name and password. Your password is stored only as a salted bcrypt hash — nobody at HangTing can see it.
Date of birth, to confirm you're 18 or over.
Which versions of these Terms and this policy you accepted, and when.

Your profile (you choose what to add)

Photos, bio and interests ("vibes").
Your gender and who you'd like to date. These are sensitive personal data under the Act (they can reveal your sex life or sexual orientation). We only collect them with your explicit consent, you can leave them blank, and you can remove them at any time. They're used to show dating plans to the people they're meant for; hangouts ignore them.

Plans, events and trust

Plans you post or apply to, the messages you send with applications, who you went with, and event tickets.
Your credit balance and history, ratings given and received, attendance reports, verified-meetup counts, flake marks and "bailed" badges.
When you open someone's plan, the host may see that you viewed it (HangTing Plus members can browse privately).

Location

Approximate location from your device when you search or browse the map, used to find plans near you. We use it for that search and don't keep a history of where you've been.
The venue location of plans you post. Other users see only an approximate area until you accept them.
At-venue checks. When you scan a meetup QR code, we record how far your device was from the venue, how accurate the reading was, and whether your phone reported a simulated location — to confirm the meetup was real.
SOS. If you press SOS, we record your location at that moment and send it to your trusted contacts.
Your time zone, so notifications show the right times.

Chats

Messages, photos and voice notes in plan chats. Message text is encrypted in our database. Chat photos and voice notes are private files that only the chat's participants can open, through links that expire after a few minutes.

Photo verification (optional)

If you choose to verify your photos, we take a selfie and compare it with your profile photos using automated face matching (Amazon Rekognition). This is biometric processing and needs your explicit consent. The selfie is deleted as soon as the check finishes. We don't create or keep a face template; we keep only whether the check passed and when. You can use HangTing without verifying.

Safety

Reports you make or that are made about you, blocks, "I left because I felt unsafe" exits, and SOS events.
Trusted contacts — the names and phone numbers of people you choose to alert in an emergency. Please only add people who are happy to be contacted. We encrypt these in our database, use them only for SOS alerts, and delete them when you remove them or delete your account.

Payments

What you bought, the amount, currency, method, date, and the payment provider's reference and receipt number. For M-Pesa we receive the paying phone number; for Paystack we use your email address. We never receive or store your card number or M-Pesa PIN.

Device and technical data

Push-notification token, device platform and app version.
Your IP address and request details, which our servers use for security, rate limiting and fraud prevention.
App usage events (for example "created a plan", "applied", "verified a meetup") linked to your user ID, to understand how the app is used. We don't include message content, photos, contact details or your location in these events.

Support and the website

Anything you tell us in support tickets or emails.
If you join the waitlist on our website, your email address. The website doesn't use advertising or tracking cookies.

3. Why we use your data, and our legal basis

To provide HangTing — your account, plans, applications, chat, credits, verification, events and payments. Legal basis: performing our contract with you.
To keep people safe — reviewing reports, acting on SOS alerts, detecting fake accounts, fraud and abuse, and enforcing our Terms. Legal basis: our legitimate interest in a safe service, and in an emergency, protecting someone's vital interests.
Sensitive data — gender, dating preference and face matching. Legal basis: your explicit consent, which you can withdraw at any time in the app.
Security — protecting accounts, preventing attacks, keeping logs. Legal basis: legitimate interest, and our legal duty to keep personal data secure.
Improving HangTing — usage statistics and fixing bugs. Legal basis: legitimate interest. You can switch usage statistics off in Profile → Security → Privacy choices, or object by email (see section 9).
Marketing — news and offers by push or email, only if you opt in (Profile → Security → Privacy choices). You can opt out at any time. Service messages — sign-in codes, plan updates and reminders, the evening "plans near you" digest, and safety alerts — aren't marketing; you can turn push notifications off in your phone's settings.
Legal obligations — tax and accounting records, and responding to lawful requests from authorities.

4. Automated decisions

Some outcomes are decided automatically from what happens in the app: credit rewards and penalties, flake marks and "bailed" badges follow the rules in our Terms, and explicit photos may be removed automatically if detected. These affect how others see your profile. If you think one is wrong, email safety@hangting.app and a person will review it. You have the right not to be subject to a decision based solely on automated processing that significantly affects you, and to ask for human review.

5. Who can see your data

Other users can see your public profile: display name, photos, bio, interests, gender (if you add it), when you joined, and your trust stats (verified meetups, flake marks, badges, rating summary). They see your plans with an approximate area; accepted participants see the venue. People in a plan's chat see messages sent there. If you turn on a public HangTing Record, anyone with the link sees the stats you chose to show — you can switch it off at any time.

Service providers who process data for us under contract and only on our instructions:

Amazon Web Services (Ireland, EU) — hosting, database, file storage, face matching and photo moderation.
Expo, Apple and Google — delivering push notifications.
Apple and Google — in-app purchases made through their stores.
Safaricom (Kenya), Paystack (Kenya/Nigeria) and PayPal — event tickets and direct payments.
Africa's Talking (Kenya) and other SMS carriers — sending SOS text messages.
Google (Gmail) — sending sign-in codes and account emails.
PostHog (EU) — app usage statistics.
Komoot Photon and OpenStreetMap — turning place names into map locations. Only the text you type into a place search is sent.
Formspree — the website waitlist form.

Authorities. We share data with the police or other authorities when the law requires it, when there's a valid court order, or when we believe it's necessary to prevent serious harm to someone — for example, child sexual exploitation, which we always report.

If HangTing is sold or merged, your data may transfer to the new owner, who must respect this policy. We'll tell you first.

We don't sell your personal data, and we don't share it with advertisers.

6. Data sent outside Kenya

Our servers are in the European Union (AWS, Ireland), and some providers above are in the United States and elsewhere. We only transfer data where the Act allows it — to countries or companies with appropriate safeguards, such as contractual data-protection commitments — and we ask for your consent before sensitive data (gender, dating preference, face matching) is processed outside Kenya.

7. How long we keep it

Your account and profile: while your account is open. When you delete your account, your profile, photos, trusted contacts and device tokens are deleted, your name and email are replaced so the record can't identify you, and your sessions are ended.
Chats: closed 7 days after the plan starts; messages, photos and voice notes are then deleted automatically, unless there's an open safety report on that plan, in which case they're kept until the report is resolved. When you delete your account, messages you sent are deleted too, except where a safety report is on file.
Plans, applications, ratings and credit history: kept with your account; after you delete it, kept only in anonymised form so other people's history and trust stats stay accurate.
Safety records (reports, SOS events, blocks, unsafe-exit reports): for as long as your account is open and up to 3 years after the report is closed or the account is deleted, because they may be needed to protect others or answer legal claims.
Payment records: kept for tax and accounting — at least 5 years, as Kenyan tax law requires, even after you delete your account. After 7 years the paying phone number or email is removed; raw payment-provider messages are deleted after 5 years.
In-app notifications: 60 days.
Event images and descriptions: 30 days after the event ends; the record that you attended stays with your account history.
Security logs: up to 30 days.
Photo-verification selfies: deleted as soon as the check finishes.
Waitlist emails: until launch, or until you ask us to remove yours.

8. How we protect it

All connections to HangTing are encrypted (HTTPS/TLS). Passwords are hashed with bcrypt. Chat text and trusted contacts are encrypted in our database. Private media is only reachable through short-lived signed links. Sign-in always needs a second step (an email code, or an authenticator app if you turn one on), sessions can be ended from the app, and staff access to data is limited to what's needed. No system is perfectly secure; if a breach puts your data at risk, we'll notify the ODPC within 72 hours of becoming aware of it and tell you without undue delay if it's likely to affect you, with advice on what to do.

9. Your rights

Under the Data Protection Act, 2019 (and the laws in section 10) you have the right to:

be informed about how your data is used (this policy);
access the personal data we hold about you;
correct data that's wrong or out of date — most of it you can edit in the app;
delete your data — Profile → Security → Delete account does this immediately;
object to processing based on our legitimate interests, and to direct marketing;
withdraw consent at any time, for example by removing your gender or dating preference, or by not using photo verification;
data portability — a copy of the data you gave us in a common machine-readable format;
not be subject to decisions based solely on automated processing that significantly affect you (see section 4).

To use any of these rights, email privacy@hangting.app from the email address on your account. We'll respond within the time the law requires. We may need to confirm it's you first.

If you're unhappy with how we've handled your data, please tell us — and you can also complain to the Office of the Data Protection Commissioner (odpc.go.ke).

10. Where you live

HangTing is available worldwide. We apply the protections in this policy to everyone, and where the law of your country gives you more, you get that too.

European Union, EEA and United Kingdom (GDPR / UK GDPR)

Our legal bases are those in section 3: contract (Art. 6(1)(b)), legitimate interests (Art. 6(1)(f)), consent (Art. 6(1)(a)), legal obligation (Art. 6(1)(c)), and, for sensitive data, explicit consent (Art. 9(2)(a)).
Our representative in the EU is [●], and in the UK [●] (Article 27). You can contact them instead of us.
When your data goes to Kenya, the United States or other countries without an adequacy decision, we protect it with the European Commission's Standard Contractual Clauses (and the UK Addendum or IDTA). You can ask us for a copy at privacy@hangting.app.
You also have the right to restrict processing, and to complain to the data protection authority where you live or work (in the UK, the ICO).

United States

We don't sell your personal information and we don't "share" it for cross-context behavioural advertising. We don't use sensitive personal information (such as your dating preference or face data) to infer characteristics about you or for any purpose beyond providing the features you asked for.
Depending on your state (for example California, Colorado, Connecticut, Virginia, Texas), you have the right to know what we collect, get a copy, correct it, delete it, and opt out of sale, sharing and targeted advertising (we don't do these). Email privacy@hangting.app; you can use an authorised agent, and we won't treat you differently for using your rights. If we refuse a request, you can appeal by replying to our decision.
The categories of personal information we collect are those in section 2, from you and your device, for the purposes in section 3, shared with the service providers in section 5, and kept for the periods in section 7.

Biometric data (including Illinois, Texas and Washington residents)

If you choose photo verification, we collect a face geometry comparison of your selfie and profile photos for one purpose: to confirm the photos are of you. We ask for your written (in-app) consent first.
The selfie is deleted as soon as the check finishes, and no face template or biometric identifier is stored afterwards — only the result. We never sell, lease, trade or otherwise profit from biometric data, and we don't disclose it except to Amazon Web Services, which performs the comparison for us.
This is our public retention and destruction policy for biometric data: destroyed immediately after the check, and in any case within 24 hours.

Other countries

We also honour the rights given by other privacy laws — for example Brazil's LGPD, South Africa's POPIA, Nigeria's NDPA, India's DPDP Act, Canada's PIPEDA and Australia's Privacy Act. Email privacy@hangting.app to use them.

11. Age

HangTing is only for people aged 18 and over. We don't knowingly collect data from anyone younger. If we learn an account belongs to someone under 18, we suspend it and delete the data, except what we must keep to protect them or others.

12. Changes

When we change this policy in a way that matters, we'll tell you in the app and ask you to review it before you continue. The date at the top shows when it last changed.

13. Contact

Privacy questions and requests: privacy@hangting.app
Safety: safety@hangting.app
Post: [●] Limited, [registered office address], Kenya