HumanGate — Personal Data Processing Policy

NOTE
    This is a template. Review it with legal counsel and adapt it to your
    jurisdiction (e.g. GDPR Art. 13/14, Russian Federal Law 152-FZ) before
    relying on it in production.

PURPOSE OF PROCESSING
    Personal data is processed for one purpose only: distinguishing humans from
    automated bots to prevent spam, fraud, and abuse on the integrating service.

CATEGORIES OF DATA SUBJECTS
    End users who open a HumanGate verification page.

CATEGORIES OF PERSONAL DATA
    - Network identifiers: IP address and a keyed (HMAC) hash of it (always
      stored); derived country and ASN.
    - Device / browser data: user-agent (always stored), canvas/WebGL
      fingerprint, screen and viewport metrics, device pixel ratio, color depth,
      platform, hardware concurrency, device memory, touch support, timezone,
      language(s), cookies-enabled.
    - Network quality signals (Network Information API): estimated downlink
      speed, effective connection type, round-trip time, data-saver flag.
    - Page performance signals: time to first byte, DOM-content-loaded and load
      times, transfer size, time to start the challenge.
    - Behavioral signals: challenge duration, pointer/keyboard/focus counts,
      computed risk score.
    - Telegram identity (Mini Apps only): the user id contained in signed
      initData, used to bind the verification to the expected user.

    The IP, user-agent and the device/network/timing signals are disclosed to
    the integrating service with the verification result for its own anti-fraud
    decision.

LEGAL BASIS
    Legitimate interest in the security and integrity of the service, and/or
    consent obtained by the integrating service, as applicable in your
    jurisdiction.

HOW IT IS PROCESSED
    Collection happens in the browser at verification time and on the HumanGate
    server. Data is stored in the operator's database. Secrets and tokens are
    stored only as encrypted values or keyed hashes, never in plain text.
    Processing is automated; no decision producing legal effects is made solely
    by automated means beyond allowing or rejecting the verification attempt.

CROSS-BORDER / THIRD-PARTY TRANSFER
    If an external provider (Cloudflare, Google, Yandex) is configured, the
    challenge token and request metadata are transferred to that provider for
    validation under its own terms. Native captchas involve no transfer.

STORAGE PERIOD
    Data is retained only for as long as necessary for abuse prevention and
    audit, then deleted or anonymized. Per-challenge configuration may limit
    collection (e.g. store only the IP hash, or omit the user-agent).

DATA SUBJECT RIGHTS
    Access, rectification, erasure, restriction, objection, and withdrawal of
    consent, exercised through the integrating service as data controller.

SECURITY MEASURES
    Encryption of secrets at rest (AES-256-GCM), keyed hashing of tokens and
    identifiers, TLS in transit, SSRF-hardened outbound webhooks, and least-
    privilege API scopes.

See also: Privacy Policy · home