Privacy Policy

1. Controller

The controller responsible for the processing of your personal data is Phianeta Consultancy FZCO, IFZA, Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates. You can reach us at info@your-hologram.com. This Privacy Policy applies to our website, our funnel pages and the HOLOGRAM® AI mobile application (together, the “Service”). Although we are established in the United Arab Emirates, we process the personal data of users in the EU and DACH region in line with the principles of the EU General Data Protection Regulation (GDPR).

2. Categories of personal data we process

• Account data: your email address and the login/session information needed to give you access.
• Birth data for your Blueprint: date of birth and, where you provide them, time and place of birth. These are used to generate your personalised Soul Blueprint and to personalise the AI conversation.
• Questionnaire and Blueprint data: answers you give in onboarding or questionnaires and the resulting Blueprint document.
• Chat content: the messages you send to and receive from the AI, including any personal information you choose to share in the conversation.
• Purchase and subscription data: products purchased, subscription status, transaction references and billing metadata (card and payment-account details are handled by our payment providers, not stored by us).
• Push tokens: device push-notification tokens, where you enable notifications.
• Usage events: technical and usage information such as app events, feature usage, device and log data needed to operate, secure and improve the Service.

3. How and why we use your chats

Your conversations with HOLOGRAM® AI are stored persistently and processed for the following purposes:

• (i) Conversation continuity: to save your history so you can continue previous conversations and so the AI can refer to what was said before.
• (ii) Personalisation: to tailor the AI’s responses to you, including by using your Blueprint and questionnaire data as context for the conversation.
• (iii) Support: to respond to your requests and resolve problems you report.
• (iv) Quality improvement: to monitor, debug, evaluate and improve the quality, safety and reliability of the Service.
• (v) Legal obligations: to comply with legal requirements and to establish, exercise or defend legal claims.

The legal bases for this processing are the performance of our contract with you (providing the Service), your consent where you voluntarily share sensitive information in a chat, and our legitimate interest in operating, securing and improving the Service, as well as compliance with legal obligations.

4. Processors and recipients

We use carefully selected service providers who process personal data on our behalf under data-processing agreements and only according to our instructions:

• Anthropic (United States) — provides the AI models that generate chat responses; chat content is processed to produce replies.
• Railway — application hosting and database infrastructure.
• Hetzner (Germany/EU) — server and infrastructure hosting for our website and back-end.
• Mailgun — sending transactional and account-related emails.
• Stripe — payment processing.
• PayPal — payment processing.
• Expo — mobile application delivery and push-notification infrastructure.

We do not sell your personal data. We disclose data to public authorities only where we are legally required to do so.

5. Retention

We retain your account data, chats, Blueprint and questionnaire data for as long as your account exists, so that you can continue your conversations and use your Blueprint. When you delete your account or request erasure, we delete or anonymise your personal data, unless we are required to keep certain records (for example, transaction records for tax and accounting purposes) for the periods prescribed by law. Backups are overwritten on a rolling basis.

6. International transfers

Because some of our processors are located outside the EU/EEA (in particular in the United States), your data may be transferred internationally. Where this is the case, we rely on appropriate safeguards such as the EU Standard Contractual Clauses or an equivalent recognised transfer mechanism to protect your data.

7. Payment processing

Payments are processed by Stripe and PayPal. The data required to complete a payment is transmitted to and handled by these providers under their own privacy terms. We receive confirmation of the transaction and a reference, but not your full payment-instrument details.

8. Cookies and tracking

Our mobile application does not use advertising cookies. Our website uses only cookies that are technically necessary to operate the ordering process and to remember your cookie preferences. Analytics and marketing tools (Meta Pixel, Google Analytics 4) are loaded only if you actively consent through the cookie banner on our website; without your consent these tools are not loaded and no related cookies are set. You can withdraw your consent at any time. Our current landing pages do not set analytics or marketing cookies unless such consent has been given.

9. Your rights

Subject to applicable law, you have the right to access the personal data we hold about you, to have it corrected or deleted, to restrict or object to its processing, and to receive a copy of your data in a portable format (data export). Where processing is based on consent, you may withdraw it at any time with effect for the future. To exercise any of these rights, contact us at info@your-hologram.com. If you are in the EU/EEA, you also have the right to lodge a complaint with your local data-protection supervisory authority.

10. Data security

We use technical and organisational measures to protect your data, including encryption of data in transit (TLS), access controls and regular backups. Further information is available in our Data Processing Information and Security Information.

11. Changes to this Policy

We may update this Privacy Policy from time to time. The current version is always available within the Service, and the date of the latest update is shown at the top of this page.

12. Contact

For any privacy question or request, contact us at info@your-hologram.com. Controller: Phianeta Consultancy FZCO, IFZA, Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.