Legal

Privacy Policy

What Torhash collects, why, how long we keep it, and who else processes it.

Last updated: 22 August 2026

1. Who we are

Torhash is operated from Ukraine. For the purposes of this policy we are the data controller for our website and for the accounts of merchants who use Torhash.

For any privacy question or request, write to ivan@torhash.app. Company details are on our company page.

2. What this policy covers

This policy covers two different things, and it is worth keeping them apart:

• Our website, torhash.app — in particular the waitlist form.
• The Torhash product — the Telegram admin bot, the per-shop bots, and the storefront mini apps used by merchants who have been given beta access.

Where a merchant uses Torhash to serve their own customers, the merchant is the controller of their customers' data and we act as their processor. Section 6 explains what that means in practice.

3. The website and the waitlist

What we collect

The only place the website asks you for anything is the waitlist form. When you submit it, we store:

• your email address (required, normalised to lowercase);
• your Telegram handle, if you give one (optional);
• your shop name, if you give one (optional);
• the time of submission;
• a truncated browser user-agent string (the first 200 characters), which we keep to tell real submissions from automated ones.

Entries are written to Google Firestore, a Google Cloud database. We also keep a simple counter of how many people have signed up; that counter holds no personal data.

Why, and on what basis

We use waitlist entries for one purpose only: to contact you about access to the Torhash closed beta, and to gauge how much demand there is. The legal basis is your consent, given by submitting the form, together with taking steps at your request before entering into a contract. We do not sell this data, we do not share it for marketing, and we do not use it to build advertising profiles.

Cookies and tracking

The website does not run an advertising tracker, an analytics tracker, or a third-party marketing pixel, and it sets no cookies for tracking or profiling. The Google Firebase SDK that saves your waitlist entry may store technical data in your browser's local storage in order to manage its own connection to the database; that is not used to track you across sites.

4. Merchant data inside the product

If you are a merchant with beta access, we process the data you need for the platform to work:

• Your Telegram account data as Telegram provides it to a bot you have started — numeric user ID, username, first and last name, language code.
• Your shop configuration — shop name, description, the plain-language instructions you write for the agent, working hours, delivery and payment settings, branding.
• Your catalogue — product names, descriptions, prices, stock, and the photos and voice notes you send us to build product cards from.
• Your orders — order contents, amounts, fulfilment and payment status, and delivery details.
• Your conversations with the agent — the messages you exchange with the Torhash admin bot, kept so the agent has context across a conversation and so we can debug problems you report.
• Credentials for services you connect yourself — for example a Nova Poshta or Prom.ua API key. These are stored encrypted (see section 8) and are never written to logs.

The legal basis is the performance of our contract with you. We also process a limited amount of this data on the basis of our legitimate interest in keeping the service secure, preventing abuse, and fixing defects.

5. Automated processing by the AI agent

Torhash is an agent product, so this deserves to be said plainly. To generate replies, build product cards, and carry out the actions you ask for, the content of the relevant conversation — along with your shop settings and the catalogue and order data needed for the task — is sent to Google Vertex AI and processed by a Gemini model. This includes photos and voice notes you send for a product card, and the messages your shop's customers send to your shop bot.

We use Vertex AI as an enterprise cloud service. We do not use your data or your customers' data to train our own models, and we do not permit it to be used to train third-party models.

The agent does not make decisions that produce legal effects for anyone. Actions that matter — publishing, changing prices, confirming orders — are governed by the per-action permissions you set, and anything you mark as requiring approval is shown to you before it happens.

6. Shop customers' data (where we are a processor)

When a buyer talks to a merchant's shop bot or opens a shop's storefront, we process on the merchant's behalf: the buyer's Telegram identifiers and display name, the messages they send, the contents of their order, and the delivery details they give — typically a name, a phone number, and a Nova Poshta branch or address.

For that data the merchant is the controller and decides why and how it is used; we process it only to run the shop the merchant has set up, and on the merchant's instructions. If you are a buyer and want your data corrected or deleted, contact the shop you bought from first. You may also write to us at ivan@torhash.app and we will route the request to that merchant and support them in answering it.

7. Who else processes the data

We keep the list of third parties short and name every one of them:

• Google Cloud and Firebase (Google Ireland Limited / Google LLC) — hosting, database, storage, queuing and key management. The product backend runs in the europe-central2 region (Warsaw, Poland).
• Google Vertex AI — the Gemini models that power the agent, as described in section 5.
• Telegram (Telegram FZ-LLC) — the messaging platform the product runs on. Every message between a shop and its customers passes through Telegram and is subject to Telegram's own privacy policy. Card payments and Telegram Stars payments are handled by Telegram and its payment providers; we do not receive or store card numbers.
• Nova Poshta — when a merchant issues a shipping label, the recipient's delivery details are sent to Nova Poshta to create it.
• Instagram (Meta) and Prom.ua — only for merchants who connect those accounts themselves, and only to sync the catalogue, posts, or orders that the integration covers.

We do not sell personal data, and we do not share it with advertising networks or data brokers.

8. Security

All traffic to our services is encrypted in transit with TLS. Merchant bot tokens and other sensitive credentials are protected with envelope encryption: a per-record data key wrapped by a master key held in Google Cloud KMS, so a database copy on its own does not reveal them. Tokens and secrets are excluded from application logs and error traces. Access to production data is limited to the people who need it to operate the service.

No system is perfectly secure. If you believe you have found a vulnerability or that data has been exposed, please write to ivan@torhash.app and we will respond.

9. How long we keep data

Torhash is a young product in closed beta, so rather than quote a schedule we have not yet operated, these are the commitments we hold ourselves to:

• Waitlist entries — deleted within 30 days of your request, and in any case no later than 24 months after your last contact with us, or sooner if the beta programme ends.
• Merchant account, catalogue and conversation data — kept while your account is active. If you close your account or leave the beta, we delete or irreversibly anonymise it within 90 days, except where we must keep records for longer to meet a legal obligation.
• Order records — kept for as long as the merchant's own accounting and consumer-protection obligations under Ukrainian law require, and then deleted.
• Operational logs and error traces — kept no longer than 90 days.

You can ask us at any time to delete data earlier than these limits, subject to any legal obligation to retain it.

10. Your rights

You may ask us to: give you a copy of the personal data we hold about you; correct it if it is wrong; delete it; restrict or object to how we use it; or provide it in a portable, machine-readable form. Where we rely on your consent, you can withdraw it at any time — withdrawing consent does not affect processing that already happened.

Send any of these requests to ivan@torhash.app. We will confirm receipt and answer within 30 days. We may need to verify that the request really comes from you before we act on it.

If you are unhappy with how we handled a request, you can complain to a supervisory authority. In Ukraine that is the Ukrainian Parliament Commissioner for Human Rights (the Ombudsman). If you are in the EU or EEA, you may complain to the data protection authority where you live.

11. International transfers

Our backend runs in Google Cloud's europe-central2 region in Warsaw, Poland. Depending on the service, Google may process data in other locations under its own terms, and Telegram operates its own global infrastructure. Where data leaves Ukraine or the EEA, it is transferred under the safeguards our providers put in place, such as the European Commission's standard contractual clauses.

12. Children

Torhash is a business tool and is not directed at children. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, write to ivan@torhash.app and we will delete it.

13. Changes to this policy

If we change this policy we will update the date at the top of this page. If a change materially affects merchants, we will also notify them in the Torhash admin bot before it takes effect.

Коротко українською

Цей розділ — стислий виклад для зручності; повний текст англійською вище є чинною версією. Повний текст українською надсилаємо на запит: ivan@torhash.app.

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See also: Company & contact · Terms of Service