Privacy Policy

1. Who we are

Hologen Technologies Ltd, company number 15757704, trading as HoloMatrix, is the controller of personal data described in this policy unless another notice says otherwise.

Email: [email protected]

2. Scope

This Privacy Policy applies to the HoloMatrix mobile app, websites, accounts, creator tools, comments, reports, Watch Together features, purchases, support and related services.

It applies to ordinary users and creators. Creators do not need a separate privacy policy.

3. Personal data we collect

Account and identity data

• email address, account identifier and authentication information;
• username, display name, avatar, channel name and profile information;
• sign-in provider and account security status;
• country or region and language settings where available.

Content and social data

• comments, replies, reactions, favourites, follows, reports, blocks and room interactions;
• content identifiers, channel activity and viewing interactions;
• messages or support communications you send to us;
• uploaded creator video, audio, metadata, thumbnails and rights declarations.

Device, network and usage data

• IP address, device type, operating system, app version and device identifiers;
• dates and times of access, feature use, performance, errors, crash logs and diagnostics;
• security events, login attempts and suspected abuse;
• approximate location derived from IP address, where used for security, content delivery, legal compliance or advertising.

Purchase and subscription data

• product purchased, subscription status, transaction identifier, price, currency and store;
• we generally do not receive full payment card details for app store purchases.

Moderation and legal data

• reports, blocks, moderation decisions, warnings, appeals and account restrictions;
• copyright notices, counter-notices, rights evidence and related correspondence;
• information needed to investigate fraud, safety incidents or legal claims.

4. Age eligibility checks

HoloMatrix is intended for users aged 16 or older.

We may ask for a date of birth through a neutral age screen solely to calculate whether the user meets the minimum age. For the current 16+ service, our intended approach is to discard the entered date of birth after calculation and store only a status such as:

• 16_plus
• under_16
• unknown

We may also store when the status was assessed, its source, such as self-declared or platform supplied, and the policy version. We do not describe a self-declared status as verified age.

Approved creators must be at least 18. We may store an adult eligibility result and may request additional evidence where needed for contracts, payments, rights disputes or legal compliance.

5. Additional creator data

For approved creators, we may collect:

• private legal name, contact details and country;
• public creator name, username, channel, avatar and biography;
• adult eligibility status and, where necessary, identity or authority evidence;
• uploaded Source Media, metadata and HoloMatrix processing information;
• music, copyright, talent, brand and permission declarations;
• licences, releases and other evidence you choose or are required to provide;
• moderation history, copyright warnings, appeals and communications;
• payment, bank, tax or business information if creator monetisation is introduced.

A creator’s full legal name is not displayed publicly unless the creator chooses to display it or a legal requirement applies.

6. Where data comes from

We receive data:

• directly from you when you register, upload, comment, purchase, report or contact us;
• automatically from your device and use of the Service;
• from Apple, Google, sign-in providers and app stores;
• from other users who interact with or report content;
• from rights holders, authorities and service providers where relevant;
• from public sources where needed to investigate impersonation, fraud or rights claims.

7. How and why we use personal data

Where we rely on legitimate interests, these include operating a safe and reliable platform, preventing abuse, understanding use, protecting rights and improving the Service. We consider the impact on users and provide rights where required.

8. Information visible to others

Your username, display name, avatar, profile, channel, comments, reactions and published creator content may be visible to other users or the public depending on the feature.

Do not publish information you want to keep private. Blocking an account may limit future interaction but may not erase information already copied or shared by others.

9. Who we share data with

We may share personal data with:

• Cloud and infrastructure providers, including Cloudflare services used for APIs, databases, security, delivery or hosting;
• Authentication providers, including Firebase Authentication, Apple and Google where enabled;
• App stores and payment platforms, including Apple App Store and Google Play;
• Content delivery, storage, analytics, crash reporting, customer support and moderation providers used to operate the Service;
• Other users and the public where you publish content or profile information;
• Copyright claimants and uploaders where notices or counter-notices must be exchanged;
• Professional advisers, insurers, auditors and prospective business transaction parties under appropriate confidentiality duties;
• Courts, regulators, law enforcement and safety bodies where required or permitted by law, including serious child safety matters.

Service providers may process data only for agreed purposes and under contractual or legal safeguards.

10. Advertising, analytics and tracking

The free version of HoloMatrix may show advertising. Advertising partners may receive device identifiers, approximate location, consent choices and ad interaction data where enabled.

Where law or platform rules require consent for personalised advertising or tracking, we will request it before that processing. You may be able to change choices through the app, device settings, Apple tracking controls, Google settings or a consent screen.

We do not sell personal data for money. Some laws use broader definitions of “sale” or “sharing” for targeted advertising. Where those laws apply, we will provide the required notice and choice.

Our websites may use essential cookies and, with consent where required, analytics or advertising cookies. Refusing non-essential cookies should not prevent access to basic legal pages.

11. International transfers

Hologen is based in the United Kingdom, but service providers and users may be located in other countries. Personal data may therefore be processed outside the UK or European Economic Area.

Where required, we use recognised safeguards such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to standard contractual clauses, European standard contractual clauses, or another lawful transfer mechanism. You may contact us for more information about relevant safeguards.

12. How long we keep data

We keep personal data only for as long as reasonably necessary for the purpose collected, including to provide the Service, maintain security, resolve disputes, enforce agreements and comply with law.

Our retention criteria include:

• account and profile data is generally kept while the account is active and for a limited period after deletion to complete closure and prevent abuse;
• public content is kept until deleted, removed or the account is closed, subject to backups and legal preservation;
• technical logs are kept for periods proportionate to security, troubleshooting and fraud prevention needs;
• purchase and accounting records are kept for legally required tax and financial periods;
• moderation, copyright, complaint and enforcement records may be kept after account closure where needed to prevent repeat abuse, respond to claims or demonstrate compliance;
• backup copies are deleted or overwritten under our backup cycle unless a legal hold applies.

When data is no longer needed, we delete, anonymise or securely isolate it.

13. Security

We use technical and organisational measures intended to protect personal data, including access controls, authentication, encryption in transit where appropriate, logging, backups and provider security controls.

No online service is completely secure. You are responsible for choosing secure credentials and protecting access to your device and account.

14. Your privacy rights

Depending on where you live and the legal basis used, you may have rights to:

• access personal data;
• correct inaccurate data;
• request deletion;
• restrict processing;
• object to processing based on legitimate interests or direct marketing;
• receive portable data in certain cases;
• withdraw consent without affecting earlier lawful processing;
• complain to a data protection authority.

To exercise a right, email [email protected]. We may need information to verify identity and protect the account. Some rights are subject to exemptions.

Users in certain US states may also have rights to know, delete, correct, opt out of targeted advertising or certain sharing, and not be discriminated against for exercising rights, where those laws apply.

15. Users under 16

The current Service is not intended for children under 16. A person who indicates that they are under 16 should not be permitted to create or continue an account.

If you believe we hold personal data from a child under 16 contrary to this policy, contact us. We will investigate and take appropriate action.

If HoloMatrix later introduces a younger user experience, we will update this policy and implement the age appropriate protections and permissions required at that time.

16. Automated tools

We may use automated tools to detect spam, security threats, duplicate files, prohibited material or policy risks. Automated signals may assist human moderation.

We do not intend to make a solely automated decision that produces a legal or similarly significant effect on you without safeguards required by applicable law.

17. External links and third party content

The Service may link to third party sites or services. Their privacy practices are controlled by them. Review their policies before providing personal data.

18. Changes to this policy

We may update this policy as the Service, providers or law changes. We will change the effective date and provide additional notice where required.

19. Contact and complaints

Email: [email protected]

If you are in the UK, you may complain to the Information Commissioner’s Office. We would appreciate the opportunity to address your concern first, but you do not have to contact us before approaching the regulator.

ICO information: ico.org.uk/make-a-complaint