Privacy Policy

Effective Date: March 1, 2026

Last Updated: March 1, 2026

Holograph Company, Inc. (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. The Company provides services, including a subscription-based platform (the “Platform”) that allows users to create and host a digital storage space (a “Holograph”) where users may upload, store, manage, and share information, documents, and other data (“Holograph Content”), a website (the “Website”), customer service, and mobile applications, among others (the “Services”). This Privacy Policy describes how we collect, use, disclose, and safeguard information you have provided or we have gathered in connection with the Services.

By visiting the Website, creating an account, or accessing or using the Services (collectively, “Users”), Users expressly consent to the use, storage, and processing of their personal information according to this Privacy Policy and our Terms of Service. If you do not agree with our Privacy Policy and Terms of Service, you may not use the Services.

Summary of Our Privacy Model

Company personnel cannot access Holograph Content. User questions submitted to Holly, our AI assistant, are encrypted and not accessed by the Company. Payment information is processed exclusively by a third-party payment processor.

We do not sell or rent users' personal information. We only share users' personal information if the user directs us to do so - for example, if a user requests an attorney referral.

1. Eligibility

The Services are only available to U.S. residents who are 18 years of age or older. We do not knowingly provide Services to children under the age of 18 or to non-U.S. residents.

2. Summary of Our Privacy Model

Users may upload and store personal information in a Holograph. All Holograph Content is encrypted using an encryption key unique to that particular holograph. The Company utilizes encryption in transit (EIT) and encryption at rest (EAR), as well as multiple sites to store information related to a single holograph. Company personnel cannot access Holograph Content. User questions submitted to the Company's AI assistant “Holly” are encrypted and not accessed by the Company. Payment information is processed exclusively by a third-party payment processor. We do not sell or rent users' personal information. We only share users' personal information if the user directs us to do so (for example, if a user requests an attorney referral).

3. Categories of Personal Information We Collect

Personal Information is information that alone, or when used with other information or data, identifies or is connected to a particular household or person who is protected by data protection regulations or laws. It does not include data that is anonymized or de-identified. We collect Personal Information, including information listed in the categories below, to provide our Services, administer our business, and comply with legal obligations.

A. Information You Provide at Account Creation

First and last name
Email address
Password

B. Subscription and Billing Information

Payment information needed to confirm your payment has been processed successfully, subscription status, and certain billing details
Payment details themselves, including full credit card numbers, are processed exclusively by our third-party payment processor and are not stored by the Company
Renewal schedules that enable the Company to inform you of the need to renew and the timing of the process

C. Customer Support Information

Information you provide regarding marketing preferences, including but not limited to type of communication and frequency
Feedback you provide to the Company on our business or Services (excluding questions you provide to Holly)
Information related to any direct communication with any employee, contractor, or agent of the Company, including information related to visits to any of our business sites

D. Third-Party Business Relationship Information

We may collect Personal Information from third-party organizations, including but not limited to businesses, non-profit organizations, regulators, or governments, related to employees, owners, contractors, directors, or officers.

E. Employment-Related Information

For job applicants, the Company collects, uses, and stores Personal Information including but not limited to information provided in a resume, cover letter, contact information, job qualifications, compensation package preferences, criminal record, credit history or related data, and information provided by your references.

4. Information Not Accessible to the Company

Holograph Content is encrypted prior to transfer (during storage) and during transfer. The Company does not possess a mechanism to decrypt the Holograph Content, and, as such, the Company cannot and does not monitor or review Holograph Content for compliance. Furthermore, the Company does not retain questions or prompts submitted by Users to Holly or its responses. Users remain solely responsible for Holograph Content and their activities related to the Services.

Please see the Terms of Service for an explanation of how you may grant visibility or access to your Holograph to other Users.

5. How We Use Personal Information

We collect and use Personal Information:

To create, maintain, and administer accounts
To process subscription payments
To provide customer service and support, including distributing service announcements and responding to your questions and comments
To maintain system security, including protecting the Company from efforts to access the Services without permission
To provide, administer, and improve our Services including platform functionality
To comply with legal obligations; protect and defend our legal or regulatory positions, rights, and property; or in urgent circumstances to protect the health or safety of any person
To enforce our Terms of Service
For any other purpose with your consent

6. Encryption Explanation

The Services employ client-side encryption that occurs before User data is transmitted to Company servers. Your Holograph content is encrypted at rest (EAR) and in transit (EIT). When you upload information to your Holograph, it is already encrypted before it reaches our servers. Our servers store only encrypted data. This means the Company cannot read, view, or access your Holograph Content - even if it wanted to.

However, no system can guarantee absolute security. Users are responsible for safeguarding their passwords and account credentials.

7. Legal Bases for Processing (GDPR Disclosure)

Although the Services are limited to U.S. residents, we provide this disclosure for transparency. If GDPR applies, our legal bases for processing include:

Performance of a contract
Legitimate interests in operating and securing the Services
Compliance with legal obligations
Consent (where applicable)

Because we cannot access Holograph Content, we do not process that content within the meaning of GDPR.

8. U.S. Data Privacy Laws and Regulations

A. California - CCPA / CPRA / CalOPPA (California Residents)

Under the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and California Online Privacy Protection Act (CalOPPA), California residents have the right to:

Know what personal information the Company collects
Request deletion of personal information collected and retained by the Company
Correct inaccurate personal information collected and retained by the Company
Opt out of sale or sharing of personal information
Not be subject to discrimination by the Company for asserting your rights
Visit the Services anonymously (except for account-required areas)
Access this Privacy Policy via the Company's website and be made aware of changes via the “Last Updated” date at the top of this document

To exercise these rights, contact: legal@holographcompany.com

However, please note:

Because we can only access encrypted Holograph content and cannot identify particular personal information within it, deletion requests apply only to account-level data we control.
The Company does not sell your personal information to third parties and only shares it at your specific request. Because we do not perform these activities, we do not provide an opt-out request process.
The Company does not use or disclose sensitive personal information for reasons outside of those permitted by the CCPA, so we do not provide the ability to limit how we use or disclose it.

We do not respond to “Do Not Track” signals.

B. Other U.S. State Privacy Laws

Under the privacy laws of other states, you may have rights similar to those listed above, including the right to:

Confirm if your personal information is being processed and access it
Correct inaccuracies in your personal information
Delete personal information whether provided by you or obtained from a third party
Obtain a copy of your personal information in a format that permits transfer to another party

To exercise these rights, contact: legal@holographcompany.com

However, please note:

Because we can only access encrypted Holograph Content, deletion requests apply only to account-level data we can identify and access.
The Company does not sell or license your personal information to third parties. Nevada residents may contact us to submit a request even though we do not engage in such sales: legal@holographcompany.com.
The Company does not engage in targeted advertising or profiling in furtherance of decisions with significant legal effect, so we do not provide an opt-out process for these activities.

You may also have the right to lodge a complaint with your state Attorney General or other regulatory authority.

9. Third-Party Privacy Policies

A. Social Media

The Company uses social media to engage with potential and existing customers. If you communicate with us via social media, those communications are governed by both this Privacy Policy and the privacy policy and terms of use of that platform. Contact us at legal@holographcompany.com with any privacy requests related to social media communications. Note that we may delete social media communications if requested by the social media platform.

B. Links to Third-Party Websites

The Company may occasionally provide links to third-party websites. This Privacy Policy does not apply to those websites or organizations, and by providing any data to them you assume all risk related thereto, including risks related to privacy and security.

C. Video Links

Should you access a link on our website or platform to a video service provider (such as YouTube or Vimeo), you will become subject to that provider's terms and conditions, including its privacy policies. The Company's use of video links does not make it a “video tape service provider” for purposes of the Video Privacy Protection Act (18 U.S. Code § 2710).

10. Data Retention

We retain Personal Information for as long as is needed to provide the Services and fulfill the purposes outlined in this Privacy Policy, after which it is, where permitted by law, anonymized, deleted, or destroyed pursuant to our data retention schedules. Please review the Terms of Service for a description of the process of Holograph content deletion upon the suspension or closure of an account.

The Company does not retain copies of your Holograph other than the encrypted production data used to provide the Services. No unencrypted copy of your Holograph content exists or is retained by the Company at any time. If you delete your account, encrypted Holograph data stored on our servers will be scheduled for deletion in accordance with our data retention schedules.

11. International Data Transfers

The Company and its servers are located in the United States. We do not intentionally transfer personal information internationally. By continuing to provide us with personal information, you acknowledge that your personal information may be transferred to, processed in, and stored in the United States.

12. Security Measures

We implement administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit and at rest for Holograph content, access controls, monitoring, and logging.

No method of transmission or storage is completely secure, and we do not guarantee absolute security. We are not responsible for the security of personal information transmitted over networks we do not control (internet networks, wireless networks, etc.), and you provide us with Personal Information at your own risk. We shall not be liable, to the extent permitted by law, for any compromise to the confidentiality, integrity, or security of your Personal Information caused by a third party.

You also play a critical role in the safety of your Personal Information. You are responsible for the security and confidentiality of your credentials, including your password. Contact us immediately if you believe your credentials have been compromised.

You agree that the Company may contact you via email or other electronic means to notify you of any data security incident related to your personal information.

13. Third-Party Service Providers

We use third-party service providers including, among others, attorneys, representatives, payment processors, cloud infrastructure providers, and analytics providers. These providers process information under their own privacy policies and contractual obligations, and are authorized to use your personal information only as required to perform the service for which they are hired. We do not permit any third party to sell or license your personal information to other third parties.

14. User Rights and How to Exercise Them

You may:

Update account information through your dashboard, or by contacting the Company if the dashboard is unavailable
Request deletion of account-level data
Request information regarding collected data

Because we can only access encrypted Holograph content and cannot identify particular personal information within it, requests related to updating, deleting, or accessing data apply only to account-level data the Company can access and control. Only a User with appropriate permissions within a Holograph can make changes to Holograph content.

Contact legal@holographcompany.com with any requests.

15. Children's Privacy

The Services are not intended for children under 18 years of age. We do not knowingly collect information from children under 18 who use the Services. If you believe a child has provided us with information, please have the parent or guardian contact us immediately to have that information removed.

16. Sale or Renting of User Information

The Company may use and disclose without restriction non-personally identifiable aggregated information, such as website analytic data that does not include any personal information or other information that may be used to identify any of our Users.

In an asset sale transaction or other transfer of ownership of the Company, User information is typically one of the business assets that is transferred or acquired by a third party to enable the Services to continue. You acknowledge that such transfers may occur, and that any acquirer may continue to use your personal and non-personal information only as set forth in this Policy.

Otherwise, we will not sell, rent, or license your personal information to anyone. We may disclose your personal information only if you expressly consent to the disclosure.

17. Employment

The Company collects personal information from individuals interested in employment as part of a standard recruitment and talent management process. This personal information can include contact information (name, email address, residential address, telephone number), résumé and cover letter information, job compensation, health data, education, criminal record, credit history, and employment background, as well as information about or by references or other third parties related to your skills, qualifications, or education.

We use this personal information to identify and evaluate applicants, review and verify their qualifications, communicate about the employment process, comply with regulatory and legal requirements, analyze our employment processes, and protect the rights of the Company and others. We may engage third parties in support of our hiring efforts. Personal information shared for this purpose is subject to this Privacy Policy.

18. Your Obligations

The Company only permits you to provide personal information to us if it is accurate and reliable, relevant to the Services, and disclosing it to us does not violate any applicable regulation or law. By using the Services, you agree to this restriction.

You are fully responsible for ensuring you have the right and authority to provide Personal Information submitted to the Company, whether about yourself or a third party. You expressly represent and warrant that the Company's use and processing of that Personal Information does not violate any person's rights, including those related to privacy. You agree to fully and completely indemnify the Company for any claims, damages, or harm that may arise from your violation of this provision. You are prohibited from providing us with “consumer health data” or similar health information.

If any Personal Information you have provided changes - including your name or email - you are obligated to notify the Company by editing your account directly or by emailing legal@holographcompany.com.

19. Changes to This Policy

We may modify this Privacy Policy from time to time. Changes will be reflected in the “Last Updated” date at the top of this document. Continued use of the Service constitutes acceptance of the modified Privacy Policy. We may in our sole discretion communicate with you regarding a change to this Policy, but this does not limit your responsibility to periodically review the Privacy Policy for changes.

20. Limitation of Liability

This Privacy Policy describes our practices but does not create contractual guarantees beyond those required by law. Security measures are designed to reduce risk but cannot eliminate risk. Users are solely and exclusively responsible for safeguarding their account credentials.

21. Access, Questions, and Contact Information

The Company strives to ensure that every person has access to information related to our products and services, including this Policy. Please contact us if you would like this Policy provided in an alternative format.

If you have questions regarding this Privacy Policy, please contact us:

Holograph Company, Inc.
Email: legal@holographcompany.com

In plain English: Your Holograph content is encrypted end-to-end - we can't read it, even if we wanted to. We don't sell your personal information. We share it only when you direct us to. You're in control of your account data and can request deletion at any time. Trust is the foundation of what we do.