DRAFT — not legal advice, needs counsel review

Privacy Policy

Effective {{EFFECTIVE_DATE}}

The short version

1. Who we are

Breaker is provided by {{OPERATOR_LEGAL_NAME}} (“TechFusion”, “we”, “us”), a limited liability company registered in Vietnam, with its address at {{OPERATOR_ADDRESS}}. We decide how and why your personal data is processed, and we're responsible for it.

Because we're a Vietnamese company, Vietnamese law applies to how we handle personal data, including the Law on Personal Data Protection (Law No. 91/2025/QH15) and Decree No. 356/2025/ND-CP. You may also have rights under the law where you live (section 9).

This policy covers the Breaker app and this website. Breaker is offered in the United States, Canada, Australia and New Zealand.

2. What we collect and why

WhatWhy
Account: a random account ID, the display name and emoji you choose, the account's status and when it was created.To run your account and show your group who's talking.
Age check result: that you passed the 18+ check, how (Apple's age range or your own declaration) and when. Never your birth year or date of birth.To keep Breaker for adults only.
Device keys: the public keys of your device and of your backup key, your device model and platform, and when it was last online. The private keys stay on your devices.To sign you in without a password, list your devices and let you remove them.
Apple device checks: an App Attest key ID and counter, which show the app is a genuine Breaker build on a real Apple device, and DeviceCheck flags that Apple stores for us for each device.To block fake apps and bots, and to make bans stick.
Push-to-talk details: your device's push token, its channel ID and the group it's tuned to.To wake your phone when someone in your group talks.
Groups: name, type, emoji, owner, time zone (taken from the creator's phone), members and their roles, and invites (code, who created it, expiry and number of uses).To run groups and invites.
Talk metadata: who talked in which group, when, and for how long. No audio.To manage whose turn it is, look into abuse reports and keep the service reliable.
Talk-time totals: seconds of talk per group per day, not per person.Plan limits and service statistics.
Purchases: the Apple transaction ID, product, status and expiry date. We never see your payment card or Apple ID details.To give your groups Group Pass benefits.
Reports and blocks: who reported or blocked whom, in which group, the reason, and any clip you attach (section 4).To keep people safe and enforce our Terms.
Technical data: your IP address and the country it maps to when your device connects; error reports and performance numbers from the app, such as device model, system and app version, crash details and connection timings.Security, rate limiting, making sure Breaker is only used where it's offered, and fixing bugs.
Messages to support: your email address and what you write, if you contact us.To answer you.

We ask for your consent when you first open the app. You can withdraw it at any time by deleting your account (section 9).

3. What we don't collect

4. Your voice and report clips

When you talk, your audio goes through our server to the other members of the group in real time. The server holds each transmission in memory only while it's being delivered, so a phone that's just been woken up can catch up, and never writes audio to disk. We don't listen to, analyse or store your conversations.

To make reporting possible, the app keeps the last 5 minutes of audio you've received in your phone's memory only. It isn't saved to your phone's storage and isn't sent to us. If you report a member, you can choose to attach the most recent clip you received from them. That clip is uploaded to us, reviewed by our moderators and deleted after 90 days.

Anything you say in a group is heard by every member who's tuned in, and any member who receives it can attach it to a report. We can't stop someone recording with another device.

5. How long we keep it

DataKept
Account, device and group dataUntil you delete your account, remove the device, leave the group or the group is deleted.
Talk metadata7 days.
Talk-time totals per groupWhile the group exists.
Report clips90 days.
Reports and blocksWhile needed to deal with the report and with repeat abuse. Reports you made are anonymised when you delete your account.
Purchase recordsWhile the subscription is active, then as long as Vietnamese accounting and tax law requires.
Server logs and error reports{{LOG_RETENTION_DAYS}} days.
BackupsOverwritten after {{BACKUP_RETENTION_DAYS}} days, so deleted data can remain in a backup until then.
DeviceCheck ban flagIf a device is banned, the flag stays with the device after the account is deleted, so the ban sticks.
Support emailsAs long as needed to handle your request.

6. Who we share it with

We don't sell your personal information, and we don't share it for cross-context behavioural advertising.

7. Ads

Breaker doesn't show ads at launch. We may later add optional rewarded ads from Google AdMob on the free plan, where you choose to watch an ad to add talk time for your group. Before that happens we'll update this policy, and the app will ask your permission before any personalised ads or tracking. Groups covered by a Group Pass won't see ad prompts.

8. International transfers

We're based in Vietnam, our servers are in {{SERVER_REGION}}, and our providers operate in other countries, including the United States. Your data is therefore transferred to, stored in and accessed from countries other than the one you live in, including Vietnam, where privacy laws may differ from yours. We choose providers that commit to protecting it, use contract terms that require them to, and document these transfers as Vietnamese law requires.

9. Your rights and choices

US residents, including California residents, have the right to know what we collect, to have it deleted or corrected, and not to be treated differently for using these rights. We don't sell or share personal information as those laws define it.

10. Adults only

Breaker is only for people aged 18 or over. The app checks your age when you first open it, and we don't knowingly collect data from anyone younger. If we learn that an account belongs to someone under 18, we delete it.

11. Security

Your device signs in with a key held in its secure hardware, so there's no password to steal, and our server stores only public keys. All connections are encrypted, and access to our systems is limited to the people who need it. If a breach affects your data, we'll tell you and the authorities as the law requires.

12. Changes to this policy

We'll update the date at the top when we change this policy, and tell you in the app before important changes take effect.

13. Contact

Email support@breakerapp.xyz, or write to {{OPERATOR_LEGAL_NAME}}, {{OPERATOR_ADDRESS}}. The person responsible for personal data is {{PRIVACY_CONTACT_NAME}}.