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Privacy Policy

Updated: July 12, 2026

We collect only what HOLD needs to work, and we do not sell your data to anyone. Our core database is in the EU, but some of the processing is performed by our sub-processors outside the EU (in the US). Below, in plain language, we explain exactly what we know about you, how we use it, and what rights you have.

1. Who we are and who is responsible for your data

HOLD is a mobile app (identifier com.holdmemory.app) distributed through Google Play (Android) and the App Store (iOS). Brand site: holdmemory.cc.

The operator (data controller) of HOLD is an individual named Yurii, a resident of Cyprus (EU). Governing law: the law of Cyprus (EU). Put simply: Yurii is the controller of personal data for HOLD.

You can reach us about any data and privacy questions at support@holdmemory.cc.

2. What data we collect

We do not sell your data, and we do not use advertising or tracking cookies.

3. How we use data and on what legal basis

We process data on the bases provided by the GDPR (Art. 6):

We do not share your data with advertising networks.

4. How a card is built (important)

HOLD is a service that builds short summaries, NOT a video downloader. To build a card, HOLD temporarily fetches and processes the video at its source link on our servers (it transcribes speech and reads frames), then discards the original. The original video file is never given to you, never stored after processing, and cannot be downloaded or exported from HOLD. Only a text summary and a small preview thumbnail are kept in your library.

The transcribed text and a description of the video are sent to the AI provider through its API to generate the gist. Only what is needed for processing is sent.

5. Where data is stored and who processes it

HOLD's core database is stored in Supabase in the EU region. Access to the database is restricted: each user sees only their own library and the libraries that have been shared with them. At the same time, it is important to understand: although the core database storage is in the EU, some of the processing is performed by our sub-processors outside the EU (in the US), see below.

To make the service work, we use trusted processors. All of them are bound by data-processing agreements under Art. 28 GDPR, receive only the data needed for their function, and do not use it for their own purposes:

6. International data transfers

Some of our processors are located in the US (Apify, OpenRouter / Google Gemini, RevenueCat, Firebase Cloud Messaging / Google). This means that some of the processing is performed outside the EU. So the statement "data is stored in the EU" should be qualified: the core database storage is in the EU, but some of the processing is performed by processors abroad (in the US).

Such transfers rely on the EU Standard Contractual Clauses (SCC) and/or the EU-US Data Privacy Framework where the processor is certified. You can request a copy of the relevant safeguards at support@holdmemory.cc.

7. How long we keep data

You can delete your account and all related data right in the app: Settings -> Delete account (this takes effect immediately). Without the app, you can request deletion on the page https://holdmemory.cc/delete-account-en.html.

8. Your rights

If you are in the EU, under the GDPR you have the rights to:

To request a copy of your data, its correction or deletion, write to support@holdmemory.cc. You also have the right to lodge a complaint with a supervisory authority: in Cyprus this is the Office of the Commissioner for Personal Data Protection, or the authority in your EU country of residence.

9. Children

HOLD is intended for users aged 16 and over. The app is not designed for younger children, and we do not knowingly collect their personal data. If you believe a child has provided us with data, please write to support@holdmemory.cc and we will delete it.

10. Notifications

Push notifications. To deliver push, we use a Firebase Cloud Messaging token. This is an identifier processed by Google. Permission for push is requested through your operating system's system dialog; you can revoke it and turn notifications off in your operating system settings at any time.

Browser notifications. HOLD may offer to enable notifications in your browser, for example when the AI has finished processing a video. They only work with your explicit consent (opt-in), and it can be withdrawn at any time in your browser settings.

11. Library sharing

By default, your library is visible only to you. If you decide to share it, the person with the email you specify gets access to your saved links, notes and thumbnails. You can revoke access at any time: it is always your decision.

12. Cookies and localStorage

HOLD uses a minimum of technical data in your browser, and it is not intended for tracking:

We have no advertising or tracking cookies. If you clear your browser data, you will simply be signed out, and your library will remain intact.

13. Third-party platforms

When you save a link, you interact with TikTok, Instagram, YouTube, Facebook, Threads, Pinterest, Reddit and other platforms under their own rules. We are not responsible for what data these platforms collect when you follow a link to the original video.

14. Changes to this policy

If this policy changes significantly, we will let you know in the app or by email before the changes take effect.

15. Contact

Questions about data and privacy: support@holdmemory.cc