Privacy Policy

Effective date: April 20, 2026   ·   Last updated: April 20, 2026

1. Introduction

This Privacy Policy explains how Holonet d.o.o. ("Holonet", "we", "us") processes personal data in connection with holonet.world and related services.

This Privacy Policy should be read together with the Terms & Conditions and any product-specific privacy disclosures.

2. Controller

Unless otherwise stated, Holonet d.o.o., Berislavićeva ulica 12, 10000 Zagreb, Croatia, acts as the controller of personal data processed in connection with the Platform.

For privacy-related inquiries or rights requests, you may contact: privacy@holonet.world or info@holonet.world.

If Holonet appoints a data protection officer or EU representative where legally required, the relevant contact details may be published on the Platform.

3. Personal Data We Process

Depending on how you use the Platform, we may process the following categories of personal data:

3.1 Identity and Account Data

  • name or display name;
  • username or account identifier;
  • login credentials and authentication-related data;
  • age-range or eligibility-related signals where applicable.

3.2 Contact Data

  • email address;
  • billing address;
  • support or contact details you provide.

3.3 Platform Usage and Interaction Data

  • Worlds visited, created, edited, published, or interacted with;
  • creator actions, moderation interactions, collaboration events, and feature usage;
  • communications, reports, complaints, support interactions, and safety-related submissions;
  • logs relating to account actions and content management.

3.4 Device and Technical Data

  • IP address;
  • browser type, operating system, device identifiers, and language settings;
  • timestamps, crash logs, diagnostic data, latency data, and performance signals;
  • network and technical telemetry reasonably necessary to operate and secure the Platform.

3.5 Payment and Transaction Data

  • subscription status;
  • billing records;
  • payment method metadata provided by payment processors;
  • invoices, tax information, payout-related data, or transaction records where applicable.

Holonet generally does not store full payment card details where payments are handled by external payment providers.

3.6 Content and Communications Data

  • content you upload, create, publish, or store through the Platform;
  • messages or communications sent through platform tools, where applicable;
  • support requests, notices, appeals, and moderation submissions.

3.7 Sensitive Data

Holonet does not request sensitive personal data unless necessary for a lawful and specific purpose. If you voluntarily submit sensitive personal data, we will process it only where an appropriate legal basis exists, including explicit consent where required.

4. Sources of Personal Data

We collect personal data:

  • directly from you;
  • automatically from your use of the Platform;
  • from your organization, team administrator, or collaborators where relevant;
  • from payment processors and service providers;
  • from reports, complaints, rights-holders, or trusted flaggers where relevant to safety and compliance; and
  • from public authorities or other lawful sources where legally required.

5. Purposes of Processing and Legal Bases

We process personal data for the following purposes and on the following legal bases, as applicable:

5.1 To Provide and Operate the Platform

We process data to create and manage accounts, authenticate users, host content, enable Worlds, support creator functionality, provide collaboration features, process subscriptions, and deliver core services.

Legal basis: performance of a contract; legitimate interests in operating and improving the Platform.

5.2 To Maintain Security and Prevent Abuse

We process data to detect fraud, misuse, unauthorized access, malicious behavior, policy violations, and threats to users, the Platform, or third parties.

Legal basis: legitimate interests; compliance with legal obligations.

5.3 To Moderate Content and Enforce Policies

We process relevant data to review reports, assess potential violations, respond to notices, handle appeals, prevent repeated abuse, and document enforcement actions.

Legal basis: legitimate interests; compliance with legal obligations; establishment, exercise, or defense of legal claims.

5.4 To Improve the Platform

We process usage, diagnostic, and behavioral data to analyze performance, improve features, optimize system stability, measure engagement, and enhance product experience.

Legal basis: legitimate interests; consent where required by law.

5.5 To Process Payments and Commercial Transactions

We process billing and transaction-related data to manage paid subscriptions, invoicing, tax treatment, refunds, payouts, and financial compliance.

Legal basis: performance of a contract; legal obligations.

5.6 To Communicate With You

We process contact data and account data to send service communications, transactional notices, security alerts, legal notices, support responses, and product messages.

Legal basis: performance of a contract; legitimate interests; consent where required for marketing communications.

5.7 To Comply With Law and Defend Legal Rights

We may process personal data to comply with legal obligations, respond to lawful requests, cooperate with authorities, protect rights, or defend legal claims.

Legal basis: legal obligations; legitimate interests; legal claims.

6. Cookies and Similar Technologies

We may use cookies, local storage, SDKs, pixels, or similar technologies for:

  • authentication and session management;
  • security and fraud prevention;
  • remembering settings and preferences;
  • analytics and service improvement; and
  • features requiring device-side storage.

Where required by law, we will request consent before using non-essential cookies or similar technologies.

Further information may be provided in a separate Cookie Notice or consent tool.

7. Sharing of Personal Data

We may share personal data with the following categories of recipients where necessary:

7.1 Service Providers

Hosting providers, infrastructure vendors, analytics providers, communication providers, payment processors, moderation tooling providers, fraud-prevention services, customer support vendors, or other processors acting on our instructions.

7.2 Other Users and Public Visibility

If you publish Worlds, profiles, comments, creator assets, or other content with public or shared visibility settings, certain information may be visible to other users or the public in accordance with your settings and product design.

7.3 Team or Organization Administrators

If you access the Platform through a team, enterprise, school, or organization account, certain information may be visible to administrators consistent with the applicable service configuration and organizational relationship.

7.4 Legal and Regulatory Recipients

Courts, regulators, law enforcement, tax authorities, rights-holders, complainants, or other third parties where disclosure is required or justified by law or necessary to establish, exercise, or defend legal claims.

7.5 Corporate Transactions

Actual or prospective buyers, investors, lenders, auditors, or advisers in connection with a financing, merger, acquisition, reorganization, asset sale, or similar transaction, subject to confidentiality obligations where appropriate.

8. International Transfers

Personal data may be processed in countries other than the country in which you reside.

Where personal data is transferred outside the European Economic Area or another jurisdiction requiring safeguards, Holonet will use appropriate legal mechanisms, such as adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms.

9. Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

  • provide the Platform;
  • maintain security and integrity;
  • comply with legal, accounting, and tax obligations;
  • resolve disputes;
  • enforce agreements; and
  • preserve records relevant to safety, fraud prevention, or legal claims.

Retention periods may vary depending on the type of data, the nature of the service, applicable legal obligations, whether an account remains active, and whether data is required for legitimate operational needs.

When data is no longer required, it may be deleted, anonymized, aggregated, or otherwise irreversibly de-identified.

10. Your Rights

Subject to applicable law, you may have the right to:

  • request access to your personal data;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of personal data;
  • request restriction of processing;
  • object to certain processing;
  • request data portability;
  • withdraw consent where processing is based on consent; and
  • lodge a complaint with a competent supervisory authority.

You may exercise rights by contacting privacy@holonet.world. We may need to verify your identity before acting on a request.

11. Children and Age-Sensitive Data

The Platform is not directed to children below the minimum age permitted under applicable law for the relevant service, except where expressly supported with appropriate safeguards.

If Holonet learns that personal data has been collected from a child in violation of applicable law, Holonet may delete the data, disable the account, or take other appropriate action.

12. Security

Holonet uses appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no security measure is perfect, and Holonet cannot guarantee absolute security.

13. Automated Processing

Holonet may use automated systems to support security, fraud prevention, abuse detection, moderation triage, content review assistance, and service optimization.

Where legally required, users may request human review of decisions producing significant effects, as further described in the Trust & Safety / Moderation Policy or applicable product processes.

14. Changes to This Privacy Policy

Holonet may update this Privacy Policy from time to time. Material changes will be communicated where required by law.

The "Last updated" date above indicates when this Privacy Policy was most recently revised.

15. Contact