1. Introduction

This Privacy Policy defines the rules for processing personal data by the HOMER application (hereinafter: "Application"), available at https://echo-homer2.abacusai.app. HOMER is a privacy-oriented application that implements the "zero-knowledge" and "data minimization" philosophy.

2. Data Controller

The controller of personal data processed in connection with the use of the Application is the HOMER operator.

3. Scope of Processed Data

The Application processes only the minimum necessary data: Encrypted messages (we cannot read them), Technical data (IP address, browser type, timestamps - only for security purposes), Stripe payment data (for PRO purchases), PRO licenses (stored locally in the browser).

4. Purpose of Processing

Data is processed for: Providing messaging services, System security and abuse prevention, Processing PRO payments, Statutory archiving obligations.

5. Legal Basis

Processing is based on: Contract performance (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR), Legal obligations (Art. 6(1)(c) GDPR).

6. Data Retention

Encrypted messages: Maximum 7 days or until first reading, Technical logs: 30 days, Payment data: As required by law (typically 5 years).

7. Data Sharing

We share data only with: Stripe (payment processing), Hosting providers (AWS/Abacus.AI). We do NOT share data with advertising or analytics companies.

8. Cookies

We use only essential functional cookies. Details are in the Cookie Policy.

9. Your Rights

You have the right to: Access your data, Rectify data, Delete data (right to be forgotten), Data portability, Object to processing, Lodge a complaint with a supervisory authority.

10. Data Security

We employ: AES-GCM 256-bit encryption, HTTPS/TLS for all connections, Automatic data deletion, No access to message content (zero-knowledge).