Privacy Policy
1. Who we are
This service is run by Hyperion S.r.l., Piazza Santo Stefano 6, 20122 Milano (MI), Italy, VAT no. IT14450290961 ("Hyperion", "we"). Hyperion is the data controller for the personal data described here. Contact: privacy@hyperionsrl.cloud.
2. What Naughty or Nice does
Someone (the "link owner") enters a first name or nickname and gets a personal link. Friends who open it vote "Nice" or "Naughty" anonymously and may add a short written reason. The link owner sees the score and the certificate for free and can pay to read the written reasons. Voting closes on 24 December 2026.
We designed it so that nobody, including us, can tell the link owner who voted or who wrote which reason: reasons are shown only once there are at least 3 votes, in random order and without dates.
3. Data we collect and why
| Who | Data | Why | Legal basis |
|---|---|---|---|
| Link owner | The first name or nickname you type (visible to anyone who has your link), the link ID, creation date, browser language, and a random secret key stored in your browser that proves you own the link (we keep only a hash of it) | To run your link and show you your score | Performance of the contract with you (GDPR art. 6(1)(b)) |
| Voter | Your vote (Nice/Naughty), the optional reason you write, the date, a hash of a random identifier stored in your browser and a hash of your IP address. The hashes are computed with a secret key and cannot be reversed into your IP or identifier. | To count one vote per person, limit abuse (max votes per network and per hour) and show reasons to the link owner | Our legitimate interest in running a fair, abuse-resistant vote (art. 6(1)(f)); the reason you write is published to the link owner at your choice |
| Link owner (if you pay) | Payment handled by Stripe: card or wallet details are entered on Stripe's pages and never reach us. We receive the payment ID, amount, currency, the link ID and, from Stripe, your email and billing country if you provide them. | To unlock the file you bought, issue receipts, prevent fraud and keep accounting records | Contract (art. 6(1)(b)) and legal obligations such as tax records (art. 6(1)(c)) |
| Anyone | Reports you send about a link or a reason (category, optional note) and a hash of your IP address | To review abuse and remove content | Legitimate interest in keeping the service safe (art. 6(1)(f)) |
| Anyone | Advertising cookies and similar identifiers from Meta (Facebook/Instagram) and TikTok, plus the pages you view and buttons you click | To measure and improve our ads | Your consent through the cookie banner (art. 6(1)(a) GDPR and art. 122 of the Italian Privacy Code). Nothing is loaded if you reject. |
| Anyone | Technical data such as IP address, kept briefly in server logs by our hosting provider; anonymous page-view and click counts without cookies or identifiers | To run the website securely and understand what people use | Legitimate interest (art. 6(1)(f)) |
| Pre-launch pages (Noble Pets, Recapp) | Email address you type in, which product and button, the campaign link (UTM), browser language, date | To email you when that product launches | Your consent (art. 6(1)(a)); withdraw any time |
We do not ask for, and you should not write, other people's personal information in a reason. Reasons containing links, contact details, @mentions or insults are rejected automatically, and the link owner can hide any reason.
4. Written reasons and content rules
Every reason goes through an automatic filter (a word list plus Azure AI Content Safety, a Microsoft service that scores text for hate, harassment, sexual content, violence and self-harm). The text of the reason is sent to Microsoft only for this check and is not stored by Microsoft. Reasons that fail are rejected and never saved.
Anyone can report a link or a reason. A reported reason is hidden immediately and reviewed by us. If a link is about you and you did not create it, or you believe someone is using it to bully or harass, write to us or use "Report this link": we will remove it. The link owner can delete the link and all its votes at any time from their result page.
5. Cookies
Naughty or Nice needs your browser's local storage to work: it stores your secret owner key for links you created, a random voter identifier (so you can't vote twice on the same person) and your cookie choice (key lt_consent). These are strictly necessary and are not shared with anyone.
We only set advertising cookies after you click Accept in the cookie banner. You can change your choice at any time with the Cookie settings link at the bottom of each page.
| Provider | Cookies / tools | Purpose | Duration |
|---|---|---|---|
| Meta Platforms Ireland Ltd. | Meta Pixel (_fbp, fr) | Ad measurement and optimisation | Up to 90 days |
| TikTok Technology Ltd. | TikTok Pixel (_ttp) | Ad measurement and optimisation | Up to 13 months |
| Stripe Payments Europe Ltd. | Stripe's own cookies on the checkout page (__stripe_mid, __stripe_sid) | Fraud prevention during payment (strictly necessary) | Up to 1 year |
For data collected through the Meta Pixel, Hyperion and Meta are joint controllers for the collection and transmission of the data to Meta. Meta's own processing is described in its privacy policy.
6. Who receives your data
- Microsoft Ireland Operations Ltd. (Azure) hosts the website, runs the content filter and stores links, votes and reasons as our processor. Data is stored in the EU (North Europe region); parts of the website run in Microsoft's US region.
- Stripe Payments Europe Ltd. processes payments as an independent controller for the payment itself and as our processor for order data. See Stripe's privacy policy.
- Meta and TikTok, only if you accept cookies.
- Authorities, when the law requires it, for example in case of a credible report of harassment or a threat.
We do not sell your data. Some of these providers may transfer data outside the EU/UK (for example to the US). They do so under the EU–US Data Privacy Framework or the European Commission's standard contractual clauses.
7. How long we keep it
- Links, votes and reasons: until 31 January 2027, then deleted. A link owner can delete their link earlier at any time.
- Hashed IP counters used for rate limits: 48 hours.
- Reports: 12 months, so we can act on repeated abuse.
- Payment records: 10 years, as required by Italian tax law (without card details, which we never have).
- Pre-launch sign-up emails: until the product launches and launch emails have been sent, and no longer than 12 months.
8. Your rights
You can ask us to access, correct, delete or export your data, to restrict or object to its use, and to withdraw consent at any time (this does not affect anything done before). Write to the contact address above. Because votes are anonymous by design, we cannot identify which vote is yours: if you want a vote deleted, tell us the link and we will explain what we can do. You can also complain to a data protection authority, such as the Italian Garante per la protezione dei dati personali, the UK ICO, or the authority where you live.
California and other US states: we do not sell personal information and do not share it for cross-context behavioural advertising beyond the Meta and TikTok measurement you can refuse in the cookie banner. You can ask to know, correct or delete your information using the same contact address.
9. Age
This service is for people aged 18 or over. Do not create a link for, or vote about, anyone under 18. If we learn that a link concerns or was created by someone under 18, we delete it.
10. Changes
If we change this policy, we will update the date at the top. Material changes will be announced on the site.