Privacy Policy
Effective date: 2026-05-28 · Last updated: 2026-08-14
This policy explains what personal data Habit Motivator (the "Service", "we", "us") collects when you use our Telegram bot or embedded web mini-app, the legal basis on which we process it, how we use it, who we share it with, how long we keep it, and the rights you have.
1. Data controller
The Service is operated by an individual sole proprietor established in Israel ("the Operator"). The Operator is the controller of personal data processed through the Service within the meaning of Article 4(7) of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the holder of the database under Israeli Privacy Protection Law, 5741-1981 ("PPL").
General contact: support@habit-motivator.com. For privacy and data-protection matters you can also write to admin@habit-motivator.com. The Operator's full legal name and registered address are available on written request to either address.
2. What we collect
We collect only what is necessary to operate the Service:
- From Telegram, on your first interaction: your Telegram numeric ID, username (if set), first name, and language code. We do not receive your phone number or email address from Telegram.
- Habits and progress you create: habit names, descriptions, categories, schedules, completion records, measurable values, and any notes you add.
- Preferences: timezone, week-start day, language preference, notification times, interface theme.
- Donation metadata, only if you choose to send a voluntary donation: provider (Telegram Stars), charge identifier, amount, currency, status, and timestamp. We never see, receive, or store card numbers, CVV codes, or full bank-account details — those are handled exclusively by Telegram. The Service itself is free, so most users never generate any payment data at all.
- Technical data: minimal request logs (timestamps, endpoint, HTTP status code, error stack traces). We do not use advertising trackers, marketing pixels, or third-party analytics scripts.
3. Why we use it and our legal basis
Under GDPR Article 6 and the equivalent provisions of the PPL, we rely on the following legal bases:
- Performance of a contract (Art. 6(1)(b) GDPR) — to provide the habit-tracking features you ask for and deliver the reminders and summaries you configure. Where you send a voluntary donation, we process the donation record to complete that payment and to be able to refund it on request.
- Legitimate interests (Art. 6(1)(f) GDPR) — to diagnose errors, prevent abuse and fraud, monitor service reliability, and keep the Service secure. We balance these interests against your rights and freedoms; you may object as described in §8.
- Legal obligation (Art. 6(1)(c) GDPR) — to retain payment and tax records for as long as required by accounting or tax law.
- Consent (Art. 6(1)(a) GDPR) — where required, for example to send certain notifications. You may withdraw consent at any time without affecting prior processing.
We do not sell personal data, and we do not use it for advertising or for profiling that produces legal or similarly significant effects.
4. Recipients and processors
We share the minimum necessary data with the following providers, who act as our processors (or independent controllers, where indicated):
- Telegram (Telegram FZ-LLC, United Arab Emirates) — bot platform and Telegram Stars donations. Telegram acts as an independent controller for the Telegram account itself. Telegram Privacy Policy.
- Sentry (Functional Software, Inc., United States) — error monitoring. We transmit application stack traces and request metadata with payment fields and sensitive headers scrubbed.
- Hosting — Hetzner Online GmbH (Germany), in EU data centres (Falkenstein / Nuremberg). The PostgreSQL database and the local hourly backups reside on this infrastructure.
- Offsite backup storage — Cloudflare, Inc. (Cloudflare R2), in a bucket placed in Cloudflare's Eastern Europe region. One copy of each hourly database backup is stored here so that a failure of the hosting provider cannot destroy every copy at once. The copies are encrypted on our own server before upload, with a key Cloudflare never receives, so Cloudflare holds ciphertext it cannot read. Cloudflare Privacy Policy.
We have entered into data-processing arrangements with each processor as required by Article 28 GDPR. We do not share habit content with third parties for marketing or for training third-party AI models.
5. Automated processing
The Service does not use artificial-intelligence or machine-learning models to process your content. Habit creation and habit matching are performed by deterministic, rule-based code running on the Operator's own server inside the European Union. Your content is not sent to OpenAI, Anthropic, Google, or any other third-party AI provider, and is not used to train any model.
The Service does not make any decision that produces legal or similarly significant effects on you by solely automated means within the meaning of Article 22 GDPR.
6. International transfers
The live database is stored at rest in the European Union, and the encrypted offsite backups are placed in Cloudflare's Eastern Europe region. Certain data may nevertheless be transferred to or accessed from outside the European Economic Area:
- Telegram FZ-LLC is established in the United Arab Emirates, for which the European Commission has not issued an adequacy decision. Any transfer arising from your use of the Telegram platform relies on appropriate safeguards and/or the derogations in Article 49 GDPR (in particular, transfers necessary for the performance of the contract you have requested). Telegram acts as an independent controller for your Telegram account.
- Cloudflare, Inc. is established in the United States. Our bucket carries an Eastern Europe location hint rather than a binding jurisdiction restriction, so we do not warrant that the encrypted copies never leave the EEA. Any such transfer relies on the EU-U.S. Data Privacy Framework (where the recipient is certified) and/or Standard Contractual Clauses; and the copies are encrypted before they leave our server, with no key held by Cloudflare.
- Sentry may process data in the United States. Such transfers rely on the EU-U.S. Data Privacy Framework (where the recipient is certified) and/or the European Commission's Standard Contractual Clauses under Implementing Decision (EU) 2021/914.
You may request a copy of the relevant transfer mechanism from the contact address above.
7. Retention
We keep personal data only for as long as needed for the purposes set out in §3:
- Habit, preference, and account data — for as long as your account is active, and deleted within 30 days of an account-deletion request (subject to the legal-obligation exception below).
- Inactive accounts — if you do not interact with the bot for 24 consecutive months, we may delete or anonymise habit data after sending a notice to the bot. Note: blocking or deleting the bot inside Telegram does not, by itself, signal account closure to us, because Telegram does not push an account-deletion event for bot blocks. If you wish your data to be deleted immediately, please email us as described in §8.
- Database backups — taken hourly. Copies on the hosting server are retained for 30 days on a rolling basis; the encrypted offsite copies are retained for 7 days. Both are deleted automatically after that.
- Donation records — retained for the period required by Israeli and EU tax/accounting law (typically up to 7 years from the end of the relevant fiscal year), even after account deletion. This is a legal-obligation retention we cannot shorten on request; it covers only the payment metadata listed in §2, never habit content.
- Error logs in Sentry — retained for 30 days.
8. Your rights
Subject to applicable law, you have the right to:
- Access — obtain confirmation of and a copy of your personal data (GDPR Art. 15; PPL §13).
- Rectification — correct inaccurate or incomplete data (Art. 16; PPL §14).
- Erasure — request deletion of your account and associated data, subject to records we must retain by law (Art. 17).
- Restriction — ask us to limit how we use your data while a request is being resolved (Art. 18).
- Portability — receive your habit data in a structured, commonly used, machine-readable format (Art. 20). On request we will provide an export of your habits, schedules, completion records, and notes as a JSON or CSV file delivered to you within the response window stated below.
- Object — object to processing based on our legitimate interests (Art. 21).
- Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing.
- Not be subject to solely automated decision-making producing legal effects (Art. 22). We do not engage in such decision-making.
To exercise any of these rights, email admin@habit-motivator.com and include your Telegram numeric ID or username (we use that, not email, to identify your account). We will respond within one month of receiving your request. Where the request is complex or where we receive a large number of requests, we may extend this period by a further two months, in which case we will inform you within the first month and explain the reason.
9. Right to lodge a complaint
If you believe our processing of your personal data infringes applicable law, you have the right to lodge a complaint with a supervisory authority:
We would, however, appreciate the chance to address your concern first — please contact us before doing so.
10. Children
The Service is not directed at children under 13, and we do not knowingly collect data from them. Within the European Union, the minimum age is 16 unless the Member State you reside in has set a lower digital-consent age between 13 and 16, in which case that lower age applies. If you become aware that a child has provided us data without the consent of a holder of parental responsibility, please contact us and we will delete it without undue delay.
11. Security
We protect personal data using industry-standard technical and organisational measures: TLS for all data in transit, password-protected database with network isolation, scoped credentials, JWT-based authentication, and a documented backup and restore procedure. No security measure is perfect; you use the Service at your own risk.
12. Cookies and local storage
The web mini-app uses your browser's localStorage to remember non-sensitive preferences (sort order, theme, language). It does not set tracking cookies. Authentication tokens are held in memory for the duration of the session and not persisted to disk. The mini-app is launched from inside Telegram and inherits its sandbox.
13. Changes to this policy
If we make material changes, we will revise the "Last updated" date above and, where appropriate, notify you in the bot at least 14 days before the change takes effect. Continued use of the Service after the changes take effect constitutes acceptance. If you do not agree, you may stop using the Service and request account deletion.
14. Contact
Questions, requests, or complaints: admin@habit-motivator.com.
The Service is operated from Israel. Processing complies with the Israeli Privacy Protection Law, 5741-1981, and, in respect of users in the European Economic Area or the United Kingdom, with the EU General Data Protection Regulation (Regulation (EU) 2016/679) and the UK GDPR.