Privacy Policy

Effective Date: November 1, 2025 · Last Updated: September 15, 2026

1. Introduction

Welcome to Holo-Body. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and retain your personal data when you use the Holo-Body app (the “App”) — including within VR or mixed-reality platforms such as Meta Horizon, iOS (Apple), and Android (Google Play) — and when you visit our website, holo-body.com, including our online store for yoga-mat orders and pre-orders (together, the “Service”). It also describes your rights and how you can exercise them — regardless of where you live.

2. What Information We Collect

We may collect the following categories of information:

• Account Information – name, email address, login credentials (including hashed passwords), avatar or profile photo, and other registration details you provide.
• Usage & Interaction Data – how you use the App (e.g., poses completed, modules viewed, session durations).
• Technical & Device Data – device type, OS type/version, unique device IDs, IP address, VR headset model, motion/pose data (if enabled), and diagnostics.
• In-App Purchases – details of subscriptions, entitlements, or digital goods purchased.
• Order & Shipping Information – when you buy or pre-order a mat on our website: your name, billing and shipping address, email address, phone number, the products you ordered, and your order history.
• Unfinished Checkouts – if you start checking out on our website but do not complete your order, the email address and cart contents you entered, kept so we can remind you about that order (see Section 7).
• Payment Information – payments on our website are processed by PayPal (including debit and credit card payments). We receive confirmation of payment and a transaction reference; we never receive or store your full card number.
• Newsletter Sign-up – your email address, if you join our mailing list.
• Website Analytics & Security Data – pages visited and site interactions (Google Analytics, with IP anonymization), anti-fraud and spam-protection signals (Google reCAPTCHA), standard server logs including IP address, and — only if you accept marketing cookies — page views, add-to-cart and purchase events sent to Meta through the Meta Pixel (see Section 6).
• Optional Biometric or Tracking Data – if you explicitly enable hand tracking, body tracking, or avatar motion capture features.
• Camera (Mat Scan) – Only when you choose to scan your mat, the App uses the device's cameras to recognize the printed pattern on the Holo-Body mat and place the character on it. Camera frames are processed in real time and are never stored, uploaded, or shared with us or anyone else. You can deny the camera permission and use the App fully without the mat scan.
• Cookies and Similar Technologies – see our Cookie Policy and Section 6 below.

3. How We Use Your Information

We use your data to:

• Provide, maintain, and improve the Service.
• Manage purchases, subscriptions, and entitlements.
• Process and ship website orders and pre-orders, and send order confirmations and shipping updates.
• Activate app entitlements included with a purchase — for example, a mat order that includes Holo-Body Pro: we use your order’s transaction reference and email address to link the purchase to your Holo-Body account.
• Communicate updates, customer support, and marketing materials (where you have opted in).
• Personalize your experience (where you consent).
• Detect fraud or misuse and ensure infrastructure security.
• Fulfill legal and regulatory obligations.

4. Legal Bases

Where required by law (e.g., GDPR), our processing relies on:

• Consent (for optional features and marketing).
• Performance of Contract (to deliver the Service, fulfil orders, and manage your account).
• Legitimate Interest (for platform security and product improvement).
• Legal Obligation (tax, audit, or law-enforcement requests).

5. Data Sharing and Disclosures

We do not sell your personal data. If you accept marketing cookies on our website, the Meta Pixel shares information about your visit with Meta for advertising purposes (see Section 6) — you can switch this off at any time. Apart from that, we disclose personal data only to trusted service providers who operate under our instructions and data-protection contracts:

• Google Cloud Platform (GCP) – secure cloud hosting, database management, and infrastructure services.
• Unity Technologies – content delivery (CCD) and aggregated performance analytics. Unity acts as a Data Processor; more information: unity.com/legal/privacy-policy.
• Platform Providers (Meta, Apple, Google) – entitlement verification and platform-specific SDK integration.
• PayPal – payment processing for website orders.
• Intuit Mailchimp – newsletter list management and email delivery.
• Google – website analytics (Google Analytics), spam protection (reCAPTCHA), and aggregate ad-conversion measurement.
• Meta Platforms – advertising measurement and ad audiences through the Meta Pixel, only if you accept marketing cookies on our website.
• Hostinger – website hosting. Cloudflare – content delivery and website security.
• Shipping Carriers – your name, address, and phone number, to deliver physical products you ordered.
• Email Service Providers – delivery of transactional emails (receipts, resets, order updates).
• Legal Authorities – only where required by law or to protect user safety and platform integrity.

If our business is merged or acquired, your data may be transferred under the same privacy protections.

6. Cookies, Consent & Website Tracking

Our website uses cookies and similar technologies. Where consent is required, a consent banner lets you accept, deny, or fine-tune categories (functional, preferences, statistics, marketing), and we automatically honor Global Privacy Control (GPC) and Do Not Track browser signals as an opt-out.

We use Google Analytics (with IP anonymization) to understand site usage, Google reCAPTCHA to protect checkout and forms from abuse, and a Google ads conversion tag to measure — in aggregate — whether our ads lead to orders. Payment pages load PayPal technology to process your payment securely.

If you accept marketing cookies, we also use the Meta Pixel. It tells Meta which pages of our website you view and whether you add items to your cart or complete a purchase, so we can measure our ads and show them to people who have visited us. The Meta Pixel does not load if you deny marketing cookies or if your browser sends a Global Privacy Control or Do Not Track signal, and you can switch it off later in Cookie Settings. Meta’s own use of this information is described in Meta’s Privacy Policy.

For the full list of cookies and their purposes, see our Cookie Policy. You can change your choices anytime via Cookie Settings, and you can also disable cookies in your browser settings, though some features may be limited.

7. Marketing and Communications

You may opt in to receive newsletters and marketing communications — for example, our pre-launch list, which may include a discount code delivered by email.

• Choice and Control: you can opt out of marketing emails at any time by clicking the Unsubscribe link here or at the bottom of our emails, or by contacting us.
• Checkout Reminders: if you enter your email address at checkout and leave without finishing your order, we may send you a few reminder emails about the items in your cart. The checkout page lets you opt out before any reminder is sent, and every reminder includes an unsubscribe link.
• Transactional Emails: even if you opt out of marketing, you will still receive essential service-related emails (e.g., password resets, purchase receipts, or shipping updates).

8. Data Deletion and Account Termination

We provide a standardized way for users to delete their personal data, consistent with Apple and Google Play requirements:

• How to Delete: request account and data deletion directly within the App Settings, or email privacy@holobody.app with the subject “Data Deletion Request.”
• Unity Player Accounts: for Unity player-account privacy requests, contact unity-player-login-privacy@unity3d.com or delete your Unity player account at player-account.unity.com.
• Retention: upon deletion, we remove your personal identifier data from our active databases, except where retention is required by law (e.g., financial and order records).

9. Platform-Specific Compliance

Meta Horizon Platform

We comply with Meta’s Developer Data Use Policy and VRC requirements, ensuring data minimization and transparency regarding VR headset interactions.

Apple App Store (iOS)

In accordance with Apple’s requirements, we maintain a Privacy Manifest disclosing all data collection. We respect App Tracking Transparency (ATT) settings.

Google Play Store (Android)

Our Data Safety disclosures reflect the exact types of data collected, including hashed credentials for account security.

10. International Transfers

Data may be processed in or transferred to the United States, Europe, or other regions where our service providers operate. We use legally recognized safeguards, such as Standard Contractual Clauses (SCCs), to protect your information under GDPR and CCPA/CPRA standards.

11. Your Rights

Every user, regardless of location, has the right to:

• Access your personal data.
• Rectify inaccurate or incomplete data.
• Delete your data (“Right to Erasure”) — available to all users worldwide.
• Restrict or object to processing.
• Withdraw consent at any time (for optional features).
• Data portability, where applicable.

We do not limit or deny deletion requests based on jurisdiction, and we will never discriminate against you for exercising a privacy right. California residents may exercise these rights under the CCPA/CPRA. To exercise any right, contact us at privacy@holobody.app.

12. Children’s Privacy

The Service is not directed to children under 13, or below the minimum age of consent in your region. If we discover that we’ve collected information from a child without verified parental consent, we will delete it immediately. For parent-managed Meta accounts (ages 10–12), parental consent and Meta’s supervision tools are required.

13. Data Security

We use technical and organizational safeguards (encryption, access controls, monitoring) to protect your data, though no system is entirely immune from risk.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be announced via email or in-app notice. Continued use after updates constitutes acceptance. The “Last Updated” date reflects the latest revision.

15. Contact Us

Holo-Body LLC
Email: privacy@holobody.app
Phone: +1-949-609-9491