Privacy Policy
Last Updated: July 6, 2026
TL;DR
- We collect only what's necessary to operate HoloArcade
- As between you and HoloArcade, you have rights to your AI-generated content
- Published content operates under the HoloArcade Community License
- We never sell your personal data to third parties
- Personal data is stored in the EU/EEA
- Third-party AI providers receive only anonymized data (no personal identifiers)
- We share data with law enforcement when legally required
- You can access, correct, or delete your personal data anytime
- Your private conversations aren't used for training without explicit consent
1. Introduction
HoloArcade is an AI-powered interactive platform where users create immersive experiences called "holo-simulations" — featuring AI-generated worlds, locations, characters, and interactive narratives.
Our Commitment: We respect your privacy and are committed to protecting your Personal Data while providing an innovative creative platform.
Data Controller
The data controller responsible for the processing described in this policy is:
HoloArcade S.à r.l.-S 6, rue Charles Darwin L-1433 Luxembourg, Luxembourg RCS Luxembourg B307985
Contact: support@holoarcade.ai (see also our Legal Notice)
Our Location and Data Processing
- HoloArcade operates from the European Economic Area (EEA)
- All Personal Data is stored and processed within the EU/EEA
- When using external AI providers outside the EU/EEA, we transmit only anonymized, non-identifiable data (prompts without user information)
- When you access our service from outside the EU/EEA that data gets transferred to servers outside the EU/EEA
Fictional Content Notice
All holo-simulations, universes, characters, and narratives are fictional. AI-generated characters and dialogues do not represent real people.
2. Adults-Only Service
Age Requirements
- Users must be at least 18 years old
- Our Services are strictly restricted to adults and are not intended for anyone under 18
- Accounts created by anyone under 18 will be terminated and associated Personal Data deleted
No Knowing Collection from Minors
We do not knowingly collect Personal Data from anyone under 18.
If you believe a person under 18 has provided us with Personal Data, please contact support@holoarcade.ai immediately, and we will delete it promptly.
3. Information We Collect
We collect the minimum Personal Data necessary to provide and improve HoloArcade. Here's exactly what we collect and why:
3.1 Account Information
What We Collect:
- Email address (required for authentication and account security)
- Display name (optional, for personalization)
- Profile image (optional)
- Birthdate (required to verify age compliance)
- OAuth provider metadata (if you sign in via GitHub, Discord, Reddit, etc.)
Why We Collect It:
- Account creation and authentication
- Age verification and enforcement of our adults-only (18+) access policy
- Account recovery and security notifications
- Service communications
3.2 User Interactions (text)
What We Collect:
- Messages you send to AI characters
- Conversation history with AI agents
- User choices and interaction data
- Feedback and ratings
How We Use It:
- Your private conversations are stored securely
- They remain private and are not shared with third parties
- They are not used for AI model training unless you explicitly consent when we request it
- Used only to provide continuity in your personal experience
3.3 AI-Generated Content (Outputs)
What We Collect:
- AI-generated content (text, images, video, and audio)
- Metadata about Generated Content (creation date, settings, etc.)
How We Use It:
- Used according to the HoloArcade Community License v1
- May be used to improve AI models and services (as granted by the license)
- All content is stored securely
Data Sent to External AI Providers: When generating content through third-party AI models:
- We send only anonymous prompts (no user identifiers)
3.4 Payment and Transaction Information
What We Collect:
- Payment provider transaction IDs (we never store credit card numbers)
- Purchase history and coin package transactions
- Current coin balance
- Refund and billing records
Why We Collect It:
- Process purchases and refunds
- Maintain accurate financial records
- Comply with tax and accounting regulations
- Detect and prevent fraud
3.5 Technical Information
What We Collect:
- IP address and geolocation (country/region level)
- Browser type and version
- Device information (type, operating system)
- Usage analytics (page views, feature usage, session duration)
- Error logs and debugging information
Why We Collect It:
- Ensure service security and prevent fraud
- Troubleshoot technical issues
- Improve performance and user experience
- Anonymous analytics to understand platform usage
Data Minimization:
- IP addresses and detailed logs are anonymized or deleted after processing
- We collect the minimum information necessary for each purpose
3.6 Cookies and Tracking
What We Use:
- Essential cookies: Required for authentication and session management — these are the only cookies we set
- Cookieless analytics: Anonymous usage statistics collected without cookies or cross-site identifiers
- Browser local storage: Some preferences (e.g. music volume, search filters) are saved in your browser's local storage and never leave your device
What We Don't Use:
- Analytics cookies
- Advertising cookies
- Cross-site tracking cookies
Because the only cookies we set are strictly necessary to operate the service, no cookie consent banner is required.
3.7 Email Communications
What We Do:
- Send essential service communications (security alerts, account notifications, etc.)
What We Don't Do:
- We do not send marketing emails unless you explicitly opt in
- You can unsubscribe from marketing emails at any time via the link in any email
4. How We Use Your Information
4.1 Legal Basis for Processing
We process your Personal Data based on:
- Contract Performance: To provide HoloArcade services you've requested
- Legitimate Interest: For fraud prevention, security, service improvement
- Consent: For optional features like marketing or training data usage
- Legal Obligation: To comply with applicable laws and regulations
4.2 Core Service Functionality
We use your data to:
- Authenticate your account and manage access
- Generate AI content based on your interactions
- Store and display your AI-generated content
- Maintain your holo-simulations, saves, and settings, chat histories
- Process payments for coins
- Send essential notifications (password resets, security alerts, service updates)
4.3 Service Improvement and Operations
We use anonymized or aggregated data to:
- Analyze usage patterns to improve features
- Optimize performance through caching and technical improvements
- Track and fix errors via debugging logs
- Enhance AI models (only with your consent for private conversations)
4.4 Security and Fraud Prevention
We process data to:
- Detect and prevent fraudulent activity
- Protect against security threats and abuse
- Enforce our Terms of Use
- Comply with legal obligations
4.5 What We NEVER Do
We commit to never:
- ❌ Sell your Personal Data to third parties
- ❌ Use your private conversations for AI training without explicit consent
- ❌ Share Personal Data with AI model providers (only anonymous prompts)
- ❌ Send spam or unwanted marketing (unless you opt in)
- ❌ Use your data for purposes beyond those described here without notification
5. Data Sharing and Disclosure
5.1 Third-Party Service Providers
We share limited data with trusted service providers who help us operate HoloArcade:
Categories of Providers:
- Hosting (data storage within EU/EEA)
- Payment processors (transaction processing)
- Email services (transactional emails)
- Analytics providers (anonymized usage data)
5.2 AI Model Providers
When generating content through third-party AI models:
- We transmit only anonymous prompts (without user identifiers)
6. Data Retention
How Long We Keep Your Data
Active Accounts:
- Personal Data is retained as long as your account is active
- Transaction records retained per legal requirements (typically 7-10 years)
Deleted Accounts:
- Personal Data deleted instantly
- Backups can contain traces for up to 60 days
- Legal and financial records retained per regulatory obligations
Anonymous Data:
- Anonymized analytics and aggregated data may be retained indefinitely (it cannot identify you)
Community-Licensed Content:
- AI-generated content published under the Community License persists to maintain platform continuity and honor licenses granted to other users
7. Data Security
How We Protect Your Data
We implement industry-standard security measures:
- Encryption - All data transmitted over HTTPS
- Access controls - Only authorized systems access your data
- Regular updates - We patch security vulnerabilities promptly
Your Responsibilities
- Use a strong, unique password
- Enable two-factor authentication if available
- Keep your login credentials confidential
- Log out on shared devices
- Report suspicious activity immediately to support@holoarcade.ai
No Absolute Security
While we take security seriously, no system is completely secure. We cannot guarantee absolute security but commit to using reasonable measures to protect your data.
8. Your Privacy Rights
Under the GDPR you have the following rights regarding your Personal Data. Exercising them is free of charge, and we respond within one month.
- Access (Art. 15): Ask us to confirm what Personal Data we process about you and receive a copy of it.
- Rectification (Art. 16): Have inaccurate Personal Data corrected — most profile data (username, email, birthdate) can be edited directly on your account page.
- Erasure (Art. 17): Have your Personal Data deleted. You can delete your account yourself at any time from the account page (email-verified); see Section 6 for what is retained for legal reasons.
- Restriction (Art. 18): Ask us to restrict processing of your Personal Data while a dispute about it (e.g. accuracy or objection) is being resolved.
- Objection (Art. 21): Object to processing based on our legitimate interests; we will stop unless we have compelling legitimate grounds.
- Data portability (Art. 20): Receive the Personal Data you provided to us in a structured, commonly used, machine-readable format (JSON). Use the "Request data export" button on your account page — you'll get a downloadable archive (the link stays valid for 7 days), or email support@holoarcade.ai with the subject line "Privacy Request". Your AI-generated media (images, audio, video) is available for viewing and download at any time on your media page, and is therefore referenced rather than bundled in exports.
- Withdraw consent (Art. 7(3)): Where processing is based on your consent (e.g. optional training-data use), you can withdraw it at any time without affecting past processing.
How to exercise these rights: email support@holoarcade.ai with the subject line "Privacy Request". We may need to verify your identity before acting on a request.
Right to complain (Art. 77): If you believe our processing of your Personal Data violates the GDPR, you have the right to lodge a complaint with a supervisory authority — in particular the CNPD (Commission nationale pour la protection des données), the Luxembourg supervisory authority: cnpd.public.lu, 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg. You can also complain to the authority of your own EU country of residence.
9. AI-Generated Content and Copyright
Provenance Metadata
All media generated on HoloArcade (images, videos, voice, music) carries embedded, machine-readable provenance metadata identifying it as AI-generated: a cryptographically signed C2PA Content Credentials manifest (including the ingredients it was generated from), plus EXIF fields on images. This metadata stays in the files when you download or share them — it is how AI-generated content is transparently labeled across the web, and removing it may violate platform policies of third-party services you share content to.
Content Disclaimers
AI-generated content may:
- Reflect biases present in training data
- Produce unexpected or inappropriate outputs
- Inadvertently resemble existing copyrighted works
We continuously work to improve moderation and reduce harmful outputs.
Reporting Inappropriate Content
If you encounter content that is:
- Inappropriate, offensive, or harmful
- Potentially infringing your copyright
- Violating our Terms of Use
Please email support@holoarcade.ai with details and evidence.
Third-Party Copyright Claims
If you believe content on HoloArcade infringes your copyright:
- Email support@holoarcade.ai with "Copyright Infringement" in the subject
- Provide proof of ownership and identification of infringing content
- Include your contact information
We will:
- Investigate your claim promptly
- Remove infringing content if validated
- Take measures to prevent similar future outputs
- Respond to you about our findings
10. Changes to This Privacy Policy
How We Update This Policy
We may update this Privacy Policy to reflect:
- Changes in data practices
- New features or services
- Legal or regulatory requirements
- User feedback and improvements
Notification of Changes
When we make material changes, we will:
- Update the "Last Updated" date at the top
- Email registered users at their account email address
- Display a prominent notice on HoloArcade
- Provide at least 30 days' notice for significant changes
Your Acceptance
Continued use of HoloArcade after changes take effect constitutes acceptance of the updated Privacy Policy. If you don't agree with changes, you may delete your account before they take effect.
11. Contact Us
Privacy Questions or Concerns
For any privacy-related questions, data access requests, or concerns:
Email: support@holoarcade.ai
Subject Line: "Privacy Request"
12. Transparency and Trust
Our Privacy Commitment
At HoloArcade, we believe:
- Privacy is a fundamental right
- Users deserve clear, honest information about data practices
- Transparency builds trust
- You should have control over your Personal Data
We Welcome Feedback
If you believe we can improve our privacy practices or this policy, please let us know at support@holoarcade.ai.
We wrote this Privacy Policy in plain English because we respect your time and intelligence. We're committed to protecting your privacy while providing an innovative creative platform.