Privacy Policy
Effective Date: October 10, 2025

Introduction

This Privacy Policy (“Privacy Policy”) applies to the personal data processed by Breaking! in connection with the Breaking! application, its websites, software and related services (the “Platform”) that are linked to or refer to this Privacy Policy.

Data Controller: Golden Root Film Kft. (“Service Provider”) is the data controller of the data processed in connection with this Privacy Policy.

What information do we collect?

We collect your data in three ways:
Information you provide,
Information collected automatically,
Information from other sources.

Information you provide

Information provided by users: We collect the data you provide when creating an account, such as date of birth, username, email address and/or phone number, and password. You may also add other information to your profile, such as a biography or profile picture.


User Content. We collect the content you create, import, upload or post on the Platform, such as photos, videos, audio recordings, comments, hashtags, feedback and reviews, as well as related metadata (such as when, where and by whom the content was created). Even if you are not a user, information about you may appear in content created or posted by users on the Platform. We collect User Content through preloading at the time of creation, import or upload, regardless of whether you save or upload the User Content. We also collect content (such as text, images and videos) from your device’s clipboard if you choose to paste content into or from the Platform, or if you share content between the Platform and a third-party platform. In addition, we collect location data if you choose to make your location available to the app.


Contacts and other acquaintances. If you choose to sync your contacts, we collect data from your device’s address book, such as names, phone numbers and email addresses; and we compare this data with the data of users on the Platform. If you choose to search for users based on your social media connections, we collect your public profile information, as well as the names and profiles of your social media contacts. We also collect information about the accounts you follow and the accounts that follow you.


Purchase information. If you make a purchase, initiate a payment or perform another transaction through the Platform, we collect data relating to the transaction, such as card information, billing, shipping and contact details, as well as information about the products you purchased.


Surveys, research and promotions. We collect the data you provide when you choose to participate in a survey, research, promotion, contest, marketing campaign or event conducted or sponsored by us.


Information when you contact us. When you contact us, we collect the information you provide, such as proof of identity or age, feedback or questions regarding your use of the Platform, or information regarding potential violations of our Terms of Service, Community Guidelines, or other policies.


Information from forms and features you use. We also collect data you provide when you fill out a form on the Platform. You may allow Breaking! to auto-fill forms using your account information, such as addresses or payment details.

Information collected automatically

Technical data. When you access the Platform, we collect certain device and network connection information. This includes device model, operating system, keystroke patterns or rhythms, IP address, system language and device settings. We also collect service-related diagnostic and performance data, including crash reports and performance logs. We automatically assign you a device ID and a user ID. If you log in from multiple devices, we use information such as device ID and user ID to identify your activity across devices to provide a seamless login experience and for security purposes.


Location data. We collect data about your approximate location (e.g., country, state or city) based on your technical data (e.g., SIM card and IP address). Furthermore, if you enable location services for the Breaking! app in your device settings, we collect data about your approximate location (e.g., country, state or city) based on your technical data (e.g., SIM card and IP address) in order to provide you with a personalized service.


Usage information. We collect information about how you use the Platform, including the content and ads you view, the duration and frequency of use, your interactions with other users, search history and settings.


Content characteristics and attributes. We detect and collect the characteristics and attributes of your videos, images and audio recordings included in your User Content, such as identifying objects and landscapes, the presence or position of a face or other body parts in an image, and the text of the words you say in your User Content. We do this, for example, to moderate content and to provide special effects (such as filters and avatars) and captions

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Inferred information. Based on the information you provide (age group, gender), we infer your interests. We use these inferences to maintain the safety of the Platform (such as content moderation), to display relevant information to you and — where permitted — to deliver personalized ads based on your interests.


Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language settings, to prevent you from seeing the same video multiple times, and for security purposes. We also use these technologies for marketing purposes.

Information from other sources

Advertisers, survey providers and other partners. Advertisers, survey providers and other partners share information with us about you and your activities outside the Platform, such as activities on other websites, apps and stores, including products or services you purchase online or in person. These partners also share information such as mobile identifiers used for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to identify your activities outside the Platform and your Breaking! account. Some of our advertisers and other partners allow us to collect similar data directly from their websites or apps. These partners must have the necessary rights and permissions to share your data with us before doing so. Certain information received from these partners is processed by us as joint controllers.


Merchants, payment and transaction fulfillment providers. We receive data from merchants and payment or transaction processing providers, such as confirmation data or delivery information relating to products purchased using the shopping features.


Third-party platforms and partners. Third-party platforms provide us with information (e.g., your email address, authentication ID and public profile) when you choose to register or log in to the Platform using their login features. We may also receive contact data held by you or about you if you or another user syncs contact information with our Platform. When you interact with a third-party service (such as third-party apps, websites or products) that integrates Breaking! developer tools, we receive the necessary information to provide features such as cross-service authentication or cross-posting.


Additional sources. We may collect or receive information about you from organizations, businesses, individuals and others, including publicly available sources, government authorities, professional organizations and charitable groups. We also collect data about you when you appear in or are mentioned in User Content, messages, complaints, appeals, requests or feedback submitted by a user or a third party, or when your contact information is provided to us by a user.

How do we use this information

We use your data to operate, provide, develop and improve the Platform, including for the following purposes:


• Providing and managing the Platform, such as enabling the creation, sharing and consumption of content, enabling interaction with other users and their content, and providing user support.

• Providing shopping features (such as personalized shopping benefits), and enabling the purchase and delivery of products, goods and services, including sharing your data with merchants, payment and transaction providers, and other providers processing your orders.

• Personalizing and customizing certain features and content. For example, ensuring the proper operation of the Local News service.

• Enforcing our Terms of Service, Community Guidelines and other policies. To protect the safety and well-being of our community, we review User Content and other information using various technological tools (including automated methods).

• Providing certain interactive features, such as allowing your content to be used or reposted by other users in their videos, always with attribution to the original source.


• Recommending your account to other users and recommending others’ accounts to you, to help you connect with other users.


• Providing and improving our advertising services, including displaying ads (including personalized ads, where permitted).


• Preparing analytical reports to help partners, sellers and creators understand how their content, ads or products perform and to better understand their audiences and customers.


• Maintaining and improving the safety, security and stability of the Platform by identifying and addressing technical or security issues or problems (such as glitches, spam accounts, abuse, fraud and illegal activities).


• Reviewing, improving and developing the Platform, including analyzing interactions and usage across devices, analyzing how people use the Platform, and testing, training and improving our technology, including machine-learning models and algorithms.


• Sharing your data with third-party platforms to provide features such as content sharing at your request when linking your Breaking! account with a third-party service.


• Conducting research carried out by independent researchers who meet certain criteria.


• Promoting the Platform or third-party services through marketing communications, contests or promotions.


• Enabling merchants to send you marketing communications through our Platform. In this case, we act as joint controllers with merchants.


• Complying with our legal obligations, or where necessary for reasons of public interest or to protect the vital interests of our users or others.


• Protecting the Platform and safeguarding our legal rights and commercial interests, as well as those of our affiliates, users and the public.

How is this information shared

Service providers

We use service providers who help us operate, support and develop the Platform, as well as understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics and online payments.

Partners

Third-party platforms and partners. We share a limited amount of information you provide with third-party platforms and partners whose platforms or services are integrated with the Platform or with whom we have commercial relationships. We do this to provide a seamless user experience, to enable sharing of your content on other platforms, to allow merchants to view and manage your orders through our shopping features, and to allow third-party platforms and partners to better authenticate users. Examples include when you:


• log in to a third-party platform with your account, in which case we share your basic account information and any other information you provide,


• register or log in to the Platform using account information from a third-party platform (such as Facebook or Google) in such cases we share certain Technical Information to facilitate this,


• share User Content on the Platform that you have published on other social media platforms — in such cases we share your User Content and related information.

Advertisers. We provide advertisers with reports on the performance of their ads and other content on the Platform to help them measure effectiveness and understand their audience. We do not share information that could be used to contact you (such as your name or email address) unless you give permission.

Measurement and data partners. We also share the data you provide, your technical data and usage information with third-party measurement providers who compile reports to help us measure ads displayed on the Platform and help advertisers understand the success of their ads and their audience.

Merchants and their service providers. If you purchase something using the Platform’s shopping features, we share purchase-related transaction data with merchants and the service providers acting on their behalf. This includes information on items ordered and contact and delivery details so that providers can process your order.

Users of our analytics services. We provide aggregated statistics and insights to help individuals and businesses understand how people use the Platform. Creators, advertisers and merchants may receive information on the number of views, likes, comments and shares of their content, as well as aggregated demographic information to understand their followers, customers and viewers.

Others

We also share your data in other limited cases as follows:

Users and the public. Depending on your privacy settings, your information, including your Account Information, User Content and Usage Data, may be visible to other users and the public, for example if you have a public account and have not restricted the visibility of your posts. Depending on your privacy settings, your Account Information and User Content may also appear in search engines, content aggregators and news sites.

Independent researchers. We share your data with independent researchers to enable research that meets certain criteria.

Corporate transactions. Your data may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of leadership, or acquisition of all or part of our business.

Legal obligations and rights. We may access, retain and share your data with law enforcement, authorities, researchers, copyright holders or other third parties if we in good faith believe this is necessary to:


• comply with applicable laws, legal processes or governmental requests according to internationally recognized standards,


• protect the rights, property and safety of our users, copyright holders and others, including protection of life or prevention of imminent bodily harm. For example, in an emergency where someone’s life or safety is at risk, we may provide information (such as your IP address) to law enforcement,


• investigate and enforce potential violations of our Terms, Guidelines or any other applicable terms, policies or standards, or


• detect, investigate, prevent or address misleading activities, copyright infringement or other illegal activities.

Our Legal Bases for processing data

We may only use your data if we have a “legal basis” for doing so. We rely on different legal bases depending on why we are using your data (in other words, the “purpose” of the processing). These legal bases include contractual necessity, legitimate interests (ours, yours, or those of another party), consent, compliance with legal obligations, the performance of a task carried out in the public interest, and the protection of vital interests.

Below we describe the legal bases on which we rely when processing your data. This section also explains why we use your data, how we process it, which categories of data are involved, and the associated rights (which always include your right to access your data).

Contractual Necessity

We use your data to perform the contract you enter into with us when you register for, access, or use the Platform. This means we use your data to:

Provide the Platform to you. We use your data to enable you to access and use the Platform, including creating, sharing and consuming content, interacting with others, using community features, and providing any products or services you purchase.


Personalize features and content. We personalize certain features and content, showing you videos and recommending accounts we believe may interest you.


Enforce our terms, policies, or guidelines. We use your data to enforce our Terms, Policies, and guidelines (including through automated tools and human moderation). This may include age-rating or removing content, or suspending or disabling your account if we believe you are violating our Terms or Policies.


Manage the Platform. We use the information available to us to manage the Platform, including communicating with you about service-related matters, sharing updates, or providing support related to any purchase you make on the Platform, as well as responding to your questions, claims, or disputes, and processing them (including when you report a problem or request a copy of your data).

Your rights: When we use your data because it is necessary for our contract with you.

Legitimate Interests

We use your data when this is necessary to pursue our legitimate interests — or those of a third party — provided these interests are not overridden by your interests or fundamental rights and freedoms. We use the information we collect to:

Recommend your account to other users.

• We may recommend your account to other users, including when someone chooses to sync their contacts with the Platform.

Legitimate interest relied on: Helping users quickly and effectively find and connect with others.

Provide general advertisements to all users.

• We show general advertisements to all users, including those who choose not to receive personalized ads.

Legitimate interest relied on: Showing general ads helps keep the Platform free. We process limited categories of your data to ensure our advertising services are useful to advertisers (for example, showing ads to users located in a specific country or speaking a specific language).

Provide measurement and analytics services.

• We help creators, merchants, and advertisers measure the performance and reach of the ads and other content they view on the Platform.

Legitimate interest relied on: Allowing creators, merchants, and advertisers to understand how their ads or content perform and the audience that views or interacts with them. This helps ensure that the ads and content we show users remain relevant and helps keep the Platform free for all users.

Ensure the safety and well-being of our community.

• We use your data to help keep our community safe, including reviewing User Content (and, where permitted by law, Messages and related metadata) for violations of our Terms, Policies, or other guidelines. We also infer your age and may ask you to verify it in certain cases.

Legitimate interest relied on: Maintaining community safety, ensuring compliance with our Policies, and identifying misuse of the Platform.

Ensure the security and stability of the Platform.

• We use your data to maintain and improve the Platform’s security and stability, including identifying and addressing technical or security issues (such as technical errors, spam accounts, abuse, fraud, and illegal activities).

Legitimate interest relied on: Ensuring continual stability, security, availability, and functionality of the Platform.

Audit, improve, promote, and develop the Platform.


• We use the information available to us to understand how people use the Platform and to develop, test, and improve it, including enhancing our technologies such as machine learning models and algorithms. We also use this information to better understand and promote the Platform, trending topics, emerging trends, and certain personalized features. We may also review customer support communications to develop technologies supporting these features.

Legitimate interest relied on: Auditing, improving, promoting, and developing the Platform in an informed way.

Enable independent research.

• We share your data with independent researchers to enable research under specific conditions, including when the researchers demonstrate relevant experience and expertise in their field.

Legitimate interest relied on: Facilitating independent research aimed at developing society’s collective knowledge, including misinformation, violence, cybercrime, and social trends.

Share your data with third parties.

• We share your data with third parties whose platforms or services are integrated with or otherwise accessible through the Platform.

Legitimate interest relied on: Optimizing your experience, enabling you to share content across platforms, allowing third parties to authenticate users, and fulfilling commercial agreements.

Protect the Platform and defend legal rights.

• We may use your data in connection with preparing, filing, or defending actual or anticipated legal claims or proceedings (including investigating potential claims we become aware of).

Legitimate interest relied on: Protecting the Platform and defending our lawful rights and commercial interests, as well as those of our affiliates, users, and the public.

Marketing communications.

• We may send you marketing messages about the Platform and third-party products and services we think may interest you. Where required, we obtain your consent to send you such messages.
Legitimate interest relied on: Promoting the Platform and third-party products and services.

Your rights: Whenever we use your data based on our legitimate interests, you may object to and restrict such use.

Your Consent

We will ask for your consent to use your data for certain purposes. If we do so, you will always have the ability to withdraw your consent through your device permissions or the app settings.

Personalized advertising.

• With your consent, we show you personalized advertising based on your activity on and off the Platform. Click here to learn more.

Device permissions.

• We collect information that you allow us to access through your device-based settings (such as camera, photos, and location services), and we use this information for the purposes described in this Privacy Notice.

Your rights: You may withdraw your consent at any time when we process your data based on consent. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. You also have the right to data portability for data collected on the basis of consent.

Compliance with Legal Requirements

We may use your data when necessary to comply with legal obligations. This includes situations where we must communicate with you, take measures to ensure the safety of others, or comply with a valid legal request from supervisory authorities, law enforcement agencies, or courts.

Performance of a Task Carried Out in Public Interest

We may use your data when necessary to perform a task carried out in the public interest, including conducting research, preventing or detecting crime, protecting children, and improving public safety and integrity in accordance with applicable laws.

Your rights: When we use your data because it is needed to perform a task in the public interest, you have the right to object to or restrict such use.

Protection of Others’ Vital Interests

We may use the information you provide to preserve the life, physical health, or safety of other people, if necessary. This may include providing your data to law enforcement or emergency service providers to protect health or life.

Access to Your Data. You may request at any time, free of charge, that we confirm the data we process about you, provide information on such processing, and request a copy of your data.

Deletion of Your Data. You may delete or request that we delete some or all of your data.

Correction of Your Data. You may change, or ask us to change or correct, data that is inaccurate. Most of your data can be changed or corrected in the app and in the settings.

Portability of Your Data. You also have the right to data portability when we rely on our contractual obligation or on your consent. This means you have the right to receive your data in a structured, commonly used, and machine-readable format and to share it with a third party.

Objection to the Processing of Your Data. In certain circumstances, you also have the right to object to the processing of your data.

Restriction of Processing. You have the right to request the restriction of the processing of your data if (a) you contest the accuracy of the data; (b) the processing was unlawful, but you object to the deletion of the data; (c) you need the data to be retained for the establishment, exercise, or defense of legal claims; or (d) you have objected to the processing and are awaiting the result of your objection request.

In addition to these rights, you also manage your account’s privacy settings.

Data Protection and Retention

The security of your data is important to us. We maintain appropriate technical, administrative, and physical security measures designed to protect your data from unauthorized access, theft, disclosure, alteration, or loss. We regularly review our security measures to take into account new technologies and methods.

We retain data for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Notice. We also retain data where required to comply with contractual and legal obligations, where we have a legitimate business interest (for example, to improve and develop the Platform, and to enhance safety, security, and stability), and for the establishment or defense of legal claims.

Retention periods vary depending on the type of information and the purpose for which it is used. For example, when we process your data to provide the Platform to you, we retain such data for as long as you have an account.

Updating the Privacy Notice

From time to time, we may modify or update this Privacy Notice. We will notify you of any material changes to this policy through the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such changes.

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