Legal
This policy explains what personal information hugge collects about you, why, who else sees it, and what you can do about it. It is written to be read rather than to be survived. If anything here is unclear, write and ask — one person reads that mailbox and will answer you.
The data controller, in the language of the GDPR, is:
Vladyslav Zakharov
Provst Dreslers Vej 54, 3. tv.
9900 Frederikshavn
Denmark
Email: info.hugge@gmail.com
hugge is run by a private individual, not a company. There is no organisation behind it. When this policy says “we”, it means the person named above. That email address is the route for every question, request and complaint in this document.
It covers the hugge marketing site at hugge.dk and the hugge learning app at app.hugge.dk. It does not cover other sites we link to or embed. In particular, some exercises play videos through YouTube’s own player, and Google’s privacy policy governs what YouTube does when you watch one.
When you create an account. Your email address, and your password — which we never store in readable form. We store only an Argon2id hash, which is a one-way function and cannot be turned back into your password.
If you sign in with Google instead, Google gives us your Google account identifier, your email address, and your first and last name. That is all we receive, and we never see your Google password.
When you complete the setup steps. Your first and last name; your date of birth; your gender, which is optional and has a “prefer not to say” option; the place you live; and your native language, so that translations are shown in a language you read.
The address field suggests places as you type. It is restricted to region-level results — a town, a municipality, a postcode — rather than street addresses, and what we store is the place you picked and Google’s identifier for it.
While you use the app. Which exercises you have opened and how far through each one you got; experience points, your daily goal and your streak; exercises you favourite; vocabulary notes you write, along with the sentence you captured them from and any translation you save with it; the full text of the emails you write in the module-test writing task, and any peer feedback you give or receive; the classes you join, events you register for, and invitations you send or accept; messages you send to support; a profile picture, if you upload one; and your mascot choice.
One thing worth being clear about: in the ordinary dictation exercises, what you type is checked in your browser. The answer itself is never sent to us. All that reaches the server is which part of the exercise you finished.
When you contact support. Along with your message, the app sends a small amount of technical context so we can reproduce the problem: the page you were on (the path only, never the query string), your browser’s user-agent string, your language setting, your time zone and your window size.
If you apply to teach. The teacher application form on the marketing site asks for your full name, your email address, and why you want to teach. You do not need a hugge account to send one, and we keep the application whether or not it is approved.
Automatically. Our servers keep ordinary request logs, which include IP addresses, for security and troubleshooting. The analytics described below records how you move around the app.
Most of what we do with your data is simply running the service you asked for, so the legal basis is performance of a contract: creating and holding your account so you can sign in; showing exercises and keeping your progress, points and streak; placing you on the cohort leaderboard; running classes and events; producing the AI writing feedback and translator responses you asked for; sending service emails such as password resets and invitations; and answering your support messages.
A smaller set rests on our legitimate interest: keeping the service secure, preventing abuse, enforcing the daily usage limits, and understanding how the app is used so it can be improved. We have weighed those interests against your privacy, and you can object to any of them — see your rights, below.
Your gender is optional. You can decline to give it, and you can change or re-answer it in Settings at any time.
Your date of birth is collected because there is a minimum age of 13 for a hugge account.
Parts of hugge are social by design, so it is worth being precise about what other users see.
The cohort leaderboard. hugge puts you in a small group of learners at a similar level and shows a weekly ranking. The other people in that group see your first name, your last name, your profile picture if you have uploaded one, whether you are a student or a teacher, and the experience points you earned that week. They can also open a per-day breakdown of that week’s points. They do not see your email, your date of birth, where you live, your notes, or your answers.
Your teacher. If you join a class, the teacher who owns it sees your first and last name, your profile picture, a partially masked version of your email address, and your progress in the work they set.
Events. If you register for an event, the host and the other registered attendees can see your first and last name and your profile picture on the attendee list.
Peer review. If you invite another learner to review your module-test writing, that person reads the email you wrote and writes feedback on it. Please do not put private information into that text — someone you may not know will read it.
Your profile picture is publicly readable. Uploaded pictures are stored in a cloud storage bucket that is open to the internet. The web address of your picture is hard to guess, but anyone who has that address can open it without signing in. If that is not acceptable to you, do not upload a picture — and if you have already uploaded one, you can remove it in Settings.
Your notes, your support messages, your answers in ordinary exercises and your module-test writing (unless you invite a reviewer) are not shown to other learners.
We do not sell your data and we do not share it for advertising. These are the service providers who handle it on our instructions:
ElevenLabs generates some of the Danish audio you hear, but only from exercise text written by us, and only when an administrator triggers it. No learner data is ever sent to it.
We will also disclose data where the law requires it, such as a valid order from a public authority.
Two parts of hugge send your text to an AI model — Google’s Gemini, running on Google Vertex AI.
Module-test writing feedback. The subject and body of the email you wrote are sent to the model, which checks them against the task’s requirements and returns a structured list of comments. Those comments are stored with your attempt, and they quote fragments of your own writing back to you.
The mascot translator. What you type into the translator is sent to the model to be translated, together with a code for the language you want it in. The response is handed straight back to you and is not stored.
In neither case do we send your name, your email address, or your account identifier. We keep a per-day counter of how many times each account has used these features, so the daily limits can be enforced — that counter is a number, not a copy of what you wrote.
The model can be wrong. Its feedback is practice material, not a verdict from a teacher. Please do not type personal or sensitive information into either feature.
Cookies you cannot turn off. When you sign in we set cookies that keep you signed in. The app does not function without them.
Analytics. We use PostHog, on its EU cloud, to understand how the app is used. It only starts once you are signed in — it never runs on the marketing site, the sign-in page, the sign-up page or the password-reset page, and it does not run in the admin panel at all. PostHog stores identifiers in your browser’s local storage and in cookies.
We have deliberately narrowed what it can see. Automatic capture of page content is switched off, so the Danish sentences you are practising and the answers you type are not collected as events. The identifier PostHog holds for you is your app session identifier, and the only profile details attached to it are whether you are a student or a teacher, your native and translation language settings, and the date you signed up. We do not send it your email address, your name, your date of birth, where you live, or anything you typed.
Session replay. PostHog also records sessions — a reconstruction of how you moved through the app. It is configured to mask all form inputs and all text before the recording leaves your browser, which is intended to mean that what is recorded is the shape of the page and your interactions with it rather than the words on it. We describe that as masking rather than as a guarantee: it is a client-side setting, and a misconfiguration or a gap in the masking rules would show up in a recording. Session replay is nonetheless a materially heavier form of processing than counting events, which is why it has its own paragraph here.
If you would rather we did not record how you use the app, write to info.hugge@gmail.com and we will exclude your account.
You will have noticed the pattern in the processor list: almost everything is hosted in the United States, and the AI endpoint is not pinned to any region at all. Your personal data therefore leaves the European Economic Area as a matter of routine, not as an exception.
Transfers of this kind need a lawful transfer mechanism under Chapter V of the GDPR — typically the European Commission’s Standard Contractual Clauses, or a provider’s certification under the EU–US Data Privacy Framework. We are in the process of confirming and documenting which mechanism applies to each of the providers above. If that matters to your decision to use hugge, write to info.hugge@gmail.com and ask where we have got to; you will get a straight answer.
We keep your account and everything attached to it for as long as your account exists. There is no automatic clock: we do not delete inactive accounts, because a learner who comes back after a year should find their progress where they left it.
When you ask us to delete your account, your data goes with it — progress, notes, module-test submissions and the feedback on them, support conversations, AI usage counters, and your uploaded picture.
One honest limitation. When you start a support conversation, a short extract of your message is emailed to us as a notification. Copies sitting in that mailbox are not touched by deleting your account. Say the word and we will clear them out by hand.
Server logs are kept for a short period for security and troubleshooting. Analytics data is kept for whatever retention period is configured in PostHog.
Under the GDPR you can:
You also have the right not to be subject to a decision based solely on automated processing that has legal or similarly significant effects on you. hugge does not make any such decision. The AI writing feedback is commentary on a practice exercise; it does not gate your account, your progress or anything else, and no part of hugge decides anything about you automatically.
To exercise any of these, email info.hugge@gmail.com. We will respond within one month of receiving your request, as the GDPR requires. If the request is complicated we may need longer, in which case we will tell you inside that first month and explain why. We may ask you to confirm your identity first, so that nobody else can make a request about your data.
Being straight with you: there is no delete button in the app yet. Account deletion is done by hand. Email info.hugge@gmail.com from the address you signed up with, say you want your account deleted, and we will do it and confirm when it is done. This is a gap we intend to close.
If you are unhappy with how we have handled your data, please tell us first — but you are entitled to go straight to the Danish supervisory authority, and you can complain to them whatever we say:
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
datatilsynet.dk
hugge is not intended for anyone under 13, and the Terms of Service set 13 as the minimum age. If you are under 13, please do not create an account. If we find that we are holding data about a child under 13, we will delete it.
Passwords are hashed with Argon2id and never stored in readable form. All traffic is over HTTPS. The cookies that keep you signed in cannot be read by JavaScript on the page, and they expire and rotate. Access to the database is restricted.
The exception, stated plainly because it is the one thing here that is open by design: the storage bucket holding profile pictures and exercise audio is publicly readable.
No system is perfectly secure. If you think someone else has been in your account, write to info.hugge@gmail.com immediately.
If we change this policy we will update the date at the top. Where a change materially affects what we do with your data, we will tell you in the app or by email before it takes effect.
Anything at all, about this policy or about your data: info.hugge@gmail.com
