Privacy Policy

The controller

Draft: the legal identification of the controller (name, registered office, company registration number) and the privacy contact address are under legal review and will be added later.

The controller of the Readeld service is the organisation that operates the service.

• Contact: for privacy questions and requests, reach us through the contact page.
• We have not appointed a Data Protection Officer (DPO) at this time.

What data we process, why and on what basis

Draft: the legal bases and retention periods are under legal review and the final text may change.

The list below summarises our processing activities. Reported private messages, contact messages and anonymous usage measurement have their own sections.

• Account and sign-in: email address, password (only as a one-way hash), display name, profile picture, the identifier at the external sign-in provider (Google, Facebook). Purpose: creating the account and identifying you. Legal basis: performance of a contract (GDPR Article 6(1)(b)). Retention: for as long as the account exists; when the account is deleted, the personal fields are anonymised.
• Settings and activity: language, theme, reading and notification settings, the time of last activity (updated at most once a day). Settings are needed to provide the service (performance of a contract); the legal basis for last activity is under legal review (legitimate interest). Retention: for as long as the account exists; last activity is cleared on anonymisation.
• Reading activity: reading history and progress, views, likes, reactions, follows, unlocked chapters. Purpose: continuing where you left off, counters, recommendations and author statistics. Legal basis: performance of a contract. Retention: for as long as the account exists. After the account is anonymised, this data may remain linked to the account's opaque identifier; its legal assessment is under review.
• Reviews and authored content: publicly visible reviews, stories and chapters, linked to the author. Legal basis: performance of a contract. Retention: under legal review; account anonymisation does not delete them.
• Private messages: conversations and messages, read and block status. Legal basis: performance of a contract. Retention: no expiry on an active account; deleted immediately when the account is anonymised.
• Notifications and emails: in-app notifications and a log of transactional emails sent (without the recipient address). Legal basis: performance of a contract. Retention: read notifications are deleted after 90 days and unread ones after 365 days (current setting), immediately on anonymisation.
• Billing and payment: billing name and address, payment transactions, invoices, credit movements, subscription data, the record of the waiver of the right of withdrawal. We do not store bank card data; payment is handled by the payment provider. Legal basis: performance of a contract and the legal obligation of accounting (GDPR Article 6(1)(c)). Retention: for the statutory accounting retention period (the exact period is under legal review). On anonymisation the billing fields are cleared, while transactions and invoices are kept.
• Writer payouts: tax number, bank account number, company tax number, payout requests and invoice data, verification of taxpayer data in the NAV Online Invoicing system. The tax number and bank account number are stored encrypted. Legal basis: performance of a contract and a legal obligation. Retention: for the statutory accounting retention period (under legal review). On anonymisation the tax number, bank account number and company tax number are cleared.
• Blocking and moderation: blocks, reports, suspensions and the log of moderator actions. Legal basis: legitimate interest (GDPR Article 6(1)(f)), legal approval is still pending. Blocks are deleted on anonymisation; the further retention of reports is under legal review.
• Acceptance of the Terms and the Privacy Policy: the accepted version and the time of acceptance. Purpose: being able to prove acceptance. Legal basis and retention period: under legal review.
• 18+ confirmation: the self-declared age confirmation needed to access mature content and the method of confirmation. Retention: for as long as the account exists. Legal basis: under legal review.
• Referral: who invited the user, from which referral campaign, and whether a reward was granted. The inviter sees the invitee's display name, registration time and whether a reward was granted, but not their email address. Legal basis: performance of a contract. Retention: for as long as the account exists.
• Anonymous view counting: for readers who are not signed in, a salted hash that changes daily (from the IP address and browser data). The raw IP address and cookies are not stored. Legal basis: legitimate interest; the retention period is under legal review.
• Logging, error tracking and backups: application logs (with personal data redacted), error reports (after removing the request body, cookies, headers and email patterns, with only the user identifier) and regular database backups. Legal basis: legitimate interest (operation, troubleshooting). Retention: according to log rotation and the backup schedule. After a restore we re-apply deletion requests.
• Copyright notices: the notifier's name, email address and capacity (rights holder or authorised representative), the description of the original work, the declaration, the author's counter-notice (name, contact, explanation) and the event log of the procedure. Purpose: to investigate the notice and run the copyright procedure. Legal basis: legitimate interest and legal obligation (under legal review). We do not disclose the notifier's or the author's contact details to the other party in notification emails. Retention: a notice is a legal record and is not deleted when the account is anonymised; the retention period is under legal review.
• Chapter history: earlier versions (title and text) of writers' chapters, kept so they can be restored. Legal basis: performance of a contract. Retention: the latest 20 versions per chapter; older ones are deleted automatically.

Who may receive your data

Draft: the role of each provider (processor or independent controller) and the status of the data processing agreements are being confirmed.

The providers below may process data on our behalf or as independent controllers.

• Hetzner: hosting and infrastructure.
• Stripe: online payment. The payment provider handles bank card details; we do not store them.
• Számlázz.hu: issuing invoices and verifying writer invoices. NAV Online Invoicing: verification of taxpayer data and invoices.
• Email delivery: Resend (emails sent from the noreply address; the transactional email provider is being switched over, until then Google SMTP may also be in use) and Google (Gmail) for replies to messages received through the contact page.
• Google and Meta (Facebook): external sign-in (OAuth), if you choose it.
• Google: ad display (AdSense) and consent management (CMP), only with your consent. See the cookies section.
• Sentry: error tracking (EU region). Before sending we remove most personal data.
• PostHog: anonymous usage measurement (EU region). See the usage measurement section.

Transfers outside the European Economic Area

Draft: the legal basis of each transfer is being confirmed per provider.

Some providers may process data outside the European Economic Area.

• Sentry and PostHog use an EU region.
• For Google, Meta and Resend, the legal basis of the transfer (for example the EU-US Data Privacy Framework or standard contractual clauses) is being confirmed.
• The region of the hosting provider and the transfer basis of the other providers are being confirmed.

How long we keep data

Draft: the retention periods are under legal review.

Retention periods are listed per activity above. The general principles:

• Data tied to an account is kept for as long as the account exists. When an account is deleted we anonymise the personal identifiers; the account row is not removed, so some data may remain linked to an opaque identifier.
• Accounting documents and the related data are kept for the statutory retention period.
• Scheduled deletion currently runs for expired tokens, notifications, snapshots of closed reports and closed contact messages.

Your rights

Under the GDPR you have the following rights:

• Access: you can ask whether we process personal data about you and request a copy.
• Rectification: you can ask us to correct inaccurate data.
• Erasure: deleting your account is done by anonymisation. Your email address, name, password, profile picture, billing and payout data are deleted or cleared, and your private messages are deleted. Data that must be kept by law (for example invoices) is retained.
• Restriction and objection: you can ask us to restrict processing, and you can object to processing based on legitimate interest.
• Data portability: on request we will provide the data you gave us in a machine-readable format. There is currently no self-service feature for this.
• Withdrawal of consent: you can withdraw consent-based processing (for example the newsletter, advertising cookies) at any time.
• Send your requests through the contact page; we will reply within one month (GDPR Article 12(3)).

Complaints and remedies

If you believe our processing infringes your rights, you can lodge a complaint with the supervisory authority and you can also go to court.

• Hungarian National Authority for Data Protection and Freedom of Information (NAIH): 1055 Budapest, Falk Miksa utca 9-11., ugyfelszolgalat@naih.hu, naih.hu.
• You can also bring a claim against the controller's decision before the court of your place of residence or stay.

Automatic content checks

Draft: this section is under legal review.

Before authored content (stories, chapters) is published, an automatic, rule-based check (automod) runs.

• The check examines the submitted text against rules set by administrators, and also checks whether the text was copied from a watermarked chapter displayed to another reader.
• If a rule matches, the content is not published automatically. The writer can ask for a re-check or a manual (moderator) review, and after several matches in a row the content is escalated to manual review automatically.
• After a successful check, publishing can be automatic depending on the writer's setting.
• The check does not build a profile of the user.

Cookies

Readeld uses the cookies needed for it to work; advertising cookies are placed only with your consent.

• Necessary cookies: the sign-in session (HttpOnly) and the language setting.
• Advertising cookies: Google AdSense, only after prior consent through the consent management platform (CMP). You can change your consent at any time.
• We do not use our own analytics or tracking cookies.

Details on the cookie settings page

Newsletter

The newsletter is based on separate, explicit consent (opt-in).

• Data: email address and the source of the subscription. Subscribers without an account are possible.
• Legal basis: consent (GDPR Article 6(1)(a)), which you can withdraw at any time.
• Unsubscribing: every email contains a one-click unsubscribe link.
• Retention: until you unsubscribe. Deletion or suppression after unsubscribing is under legal review.

Handling of reported private messages

Draft: this section is under legal review and the final text (legal basis, balancing test, retention of the other report data) will be added later.

Private messages are normally visible only to the sender and the recipient. If someone reports a message, a moderator or admin can view it to the extent needed for moderation.

• Data processed: the text and timestamps of the reported message and up to 5 messages before it (the sender is marked only as “reported” or “reporter”, without a user identifier), the report reason and the reporter's optional free-text note. Moderators have no access to the rest of the conversation.
• Purpose and legal basis: handling harassment and spam and protecting users and the service. The legal basis is the controller's legitimate interest (GDPR Article 6(1)(f)).
• Access: admins and users with moderator rights. A non-admin moderator sees only open reports, and nobody sees a report about themselves.
• Retention: the snapshot is deleted automatically 12 months after the report is closed, and kept until closure for an open report. The snapshot remains after the original message or conversation is deleted, until the end of the retention period.
• To exercise your rights (access, rectification, objection) or ask questions, contact us through the contact page.

For questions and requests, contact us: Contact

Contact messages

Retention: a message sent through the contact page is kept until it is closed and is deleted automatically 12 months after it is closed.

Anonymous usage measurement

Draft: this section is under legal review and the final text (legal basis, balancing test, retention period, data processing agreement) will be added later.

At a few key steps Readeld performs anonymous, cookie-free measurement so the service can be improved.

• Data processed: an event name from a fixed list (for example opening the registration form, starting a payment, the chapter unlock dialog, steps in the writer editor) and pre-defined values attached to it (for example account type or error reason). We do not send a user account, email address, amount, page address, referring page, or story or chapter identifier.
• How it works: the measurement does not use cookies, local storage or session storage in your browser. On the server side, the provider computes a salted identifier that changes daily from the request's IP address, browser and hostname; the IP address is not attached to the events. Because the identifier changes daily, the same visitor appears with a different identifier the next day.
• Purpose and legal basis: understanding where registration, purchase and writing flows get stuck so we can improve the service. The legal basis is the controller's legitimate interest (GDPR Article 6(1)(f)).
• Recipient: PostHog (EU region, Frankfurt) as a processor.
• Objection: you can exclude your browser from the measurement at any time on the Cookie settings page. We automatically honour your browser's Do Not Track and Global Privacy Control signals.
• To exercise your rights (access, rectification, objection) or ask questions, contact us through the contact page.

Exclude my browser from the measurement (Cookie settings)