Kapoot

Privacy Policy

Kapoot — Infrastructure Disruption Alerts & Compensation Assistance
Last updated: June 4, 2026 (v1.5-2026-06-04)

Orbit Solutions ("we", "us", "our") operates the Kapoot mobile application and the kapoot.app website (together, the "Service"). This Privacy Policy explains what information we collect, how we use it, and your rights regarding that information.

1. Information We Collect

Mobile App

Device Identifier. We generate an anonymous device identifier using Firebase Installation ID. It is not linked to your name, email, Apple ID, or Google account. It is used solely to associate your subscriptions and deliver push notifications.

Location Subscriptions. When you subscribe to a city, district, or street, we store that subscription on our server linked to your anonymous device identifier.

Push Notification Token. If you enable push notifications, we receive a Firebase Cloud Messaging (FCM) token and store it linked to your anonymous device identifier.

Language Preference. We store your selected language (Croatian or English) to deliver notifications in your preferred language.

Website (kapoot.app)

Functional Cookies. We use two small first-party cookies — kapoot_city (your chosen city) and kapoot_lang (Croatian or English) — to remember your preferences across visits. These are strictly necessary functional cookies under the ePrivacy Directive and do not require consent. They are stored on your own device, never sent to third parties, and expire after one year.

Server Logs. Our hosting provider (Render) records standard HTTP access logs including your IP address. These are used only for operational purposes (debugging, security, abuse prevention) and are retained for a short period.

No analytics, no ad tracking, no third-party scripts. The website does not load Google Analytics, Facebook Pixel, or any tracking code.

2. Information We Do Not Collect

  • We do not collect your name, email address, or phone number.
  • We do not require account creation or login.
  • We do not collect precise GPS coordinates or continuous location tracking.
  • We do not collect browsing history, usage analytics, or behavioral data.
  • We do not collect financial or payment information.
  • We do not use advertising identifiers (IDFA/GAID).
  • We do not track you across other apps or websites.

3. How We Use Your Information

  • Deliver disruption alerts: We match your subscribed locations against scraped infrastructure disruption data from Croatian utility companies and send you relevant push notifications.
  • Maintain your subscriptions: We store your location subscriptions so they persist across app restarts.
  • Deliver localized content: We use your language preference to render the site and send notifications in Croatian or English.

4. Data Sources

The Service displays publicly available infrastructure disruption information scraped from Croatian utility company websites, including:

  • HEP ODS (electricity disruptions)
  • Municipal water utility companies across Croatian cities

We do not modify this information. We reformat and aggregate it for readable consumption.

5. Third-Party Services

Firebase (Google). The mobile app uses Firebase Cloud Messaging for push notification delivery and Firebase Installation ID for anonymous device identification. See Firebase's Privacy Policy.

Render (hosting). Our servers and database are hosted by Render. Standard access logs apply.

We do not use any other third-party analytics, advertising, or tracking services.

6. Data Storage and Security

  • Your data is stored on secure servers hosted by Render (render.com) with a PostgreSQL database.
  • All communication is encrypted using HTTPS/TLS.
  • API access is protected by API key authentication.
  • We retain data only as long as needed. Inactive device tokens are automatically cleaned up when delivery fails.

7. Data Retention and Deletion

  • Your subscriptions and push tokens are retained as long as they are active.
  • You can remove individual subscriptions at any time within the App.
  • You can disable push notifications at any time, which triggers token removal from our server.
  • Uninstalling the App effectively removes your association with our service.
  • To request complete deletion of your data, contact us at the email below.
  • Website cookies can be cleared at any time from your browser settings.

8. Children's Privacy

The Service is not directed at children under the age of 13. Since we do not collect personal information from any users, there is no special risk to children using the Service.

9. Your Rights

Depending on your jurisdiction (including GDPR in the EU), you may have the right to:

  • Access the data we hold about your device identifier
  • Request deletion of your data
  • Withdraw consent for push notifications at any time

To exercise these rights, contact us at the email address below.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision.

11. Contact Us

If you have questions or wish to request data deletion, contact us at:

Orbit Solutions d.o.o. (Republic of Croatia)
Email: hello@kapoot.app
Supervisory authority: Croatian Personal Data Protection Agency (AZOP) — azop.hr

12. Compensation-Assistance Module (v1.5+)

Starting with version v1.5-2026-06-04, Kapoot includes an optional module that helps Croatian residents file statutory compensation claims with HEP ODS for electricity-supply interruptions, under the legal framework of NN 84/22 (Regulation on quality of supply conditions for electrical energy). When you use this module, we process additional categories of personal data described below. These disclosures supplement §§1–11 above; they apply only when you actively engage the compensation module.

12.1 Additional personal data categories

The compensation module processes:

  • OIB (Croatian personal identification number) — encrypted at rest with AES-GCM.
  • Hand-drawn signature (image bitmap) — encrypted at rest.
  • Electricity-supply contract number (metering point) — encrypted at rest.
  • Full address (street, number, city, postal code) — encrypted at rest.
  • Full name and contact email + phone number — encrypted at rest.
  • Verbatim text of HEP's replies received in response to filed claims — encrypted at rest, kept as a controller record for audit purposes.
  • IBAN and amount of compensation paid — recorded for successful (Paid) claims as part of HEP's reply.

12.2 Legal basis for processing

The compensation module's processing is based on:

  • Art. 6(1)(b) GDPR — performance of contract (we provide assistance filing a claim that you submit in your own name, based on your request and digital consent given in the app).
  • Art. 6(1)(c) GDPR — legal obligation (use of the statutory channel established by NN 84/22).

We do not rely on consent as the legal basis because the processing is required by the statutory framework the service implements.

12.3 Sub-processors (compensation module only)

For the compensation module specifically, we use the following EU-resident sub-processors under signed Data Processing Agreements (Art. 28 GDPR):

  • Hetzner Online GmbH (Germany, EU) — database hosting, outbound SMTP and inbound IMAP for HEP correspondence.
  • Anthropic PBC (United States; DPA + Standard Contractual Clauses in place) — classification of HEP's Croatian-language replies in an advisory capacity. Anthropic never receives OIB, signature, address, IBAN, or compensation amount. A deterministic gating system on the Kapoot side prevents any automated state transition based on potentially hallucinated or incorrect model outputs; every classification must pass deterministic rules before it has any effect on your claim.

12.4 Retention (compensation module)

  • Active claims (Draft, Submitted, Sent, Acknowledged) — kept until claim closure.
  • Closed claims (Paid, Rejected, TimedOut) — personal data retained for up to 5 years from claim closure. A monthly automated deletion sweep (1st of each month at 05:00 UTC) removes:
    • verbatim HEP reply text,
    • IBAN recorded as compensation recipient,
    • PDF documents (claim form, evidence) from disk.
  • Audit-event log — retained beyond personal-data erasure in accordance with the controller's accountability obligation (Art. 5(2) GDPR). The audit log contains only metadata of what happened and when — no personal data in original form.

12.5 Your additional rights (compensation module)

  • Art. 15 GDPR — Right of access: in the mobile app, go to Settings → Privacy → Download my data to receive a ZIP archive with all your data and a manifest (file listing with SHA-256 hashes), including OIB, signature, address, every claim, and every HEP reply.
  • Art. 17 GDPR — Right to erasure: remove your filing profile and signature in the app (Settings → Compensation → Remove profile & signature) to stop filing new claims; existing claims stay in force and are processed as submitted, and personal data is deleted per the retention rules in §12.4.
  • Art. 20 GDPR — Data portability: the same Art. 15 ZIP export is machine-readable (JSON + JSONL + PDF + PNG + EML).
  • Art. 16 / 18 / 21 GDPR — exercisable through the in-app surfaces or by contacting the controller.

The authoritative version of these v1.5 disclosures (in Croatian) is published at /api/legal/privacy/current and is byte-stable: the SHA-256 hash served by the API endpoint matches the on-disk source. If you require the exact bytes that were current at the time you filed your claim, request them via the email above and quote the policy version stamped on your claim record (§policy_version_at_consent).