1. Who is the controller
This service (MAS, on holomer.space and its subdomains) is operated by an individual developer acting as the personal information handler. It is not a company.
- Controller: [TBD: operator name]
- Privacy contact: privacy@holomer.space
- Legal and contracts: legal@holomer.space
- Address: [TBD: city and a deliverable address]
We do not appoint a separate data protection officer. Requests sent to the addresses above are answered within 7 working days.
2. What we collect
- Account: email, display name, sign-in identifiers (Clerk), and the tenant ID created on first sign-in.
- Content you provide: messages, uploaded files, prompts, skills and agent configs.
- Runtime data: model calls (input/output, tokens, latency), sandbox commands and exit codes, error logs.
- Billing and quota: token usage aggregated per tenant per day.
- Access logs: IP, User-Agent, request path and time, for security and debugging.
We do not collect contacts, precise location, biometrics or card details (the service takes no payments).
3. Purposes and legal bases
- Providing the service (contract): authentication, model routing, sandboxes, storing sessions.
- Security and abuse prevention (legitimate interest / legal obligation): rate limits, auditing, blocking abusive accounts.
- Improving the product (legitimate interest): aggregate metrics only; never used to train models.
- Compliance records (legal obligation): consent records, audit logs.
We do not train models on your conversations and we do not sell personal data.
6. Cross-border transfer
Most processors are outside mainland China (US, Singapore, EU). When you use a foreign model provider, your prompts and context are transferred to and processed in that provider’s jurisdiction.
Under Article 39 of China’s PIPL we ask for separate consent for cross-border processing at sign-up — a standalone checkbox, not bundled with other terms. You may withdraw at any time; we then stop sending data to providers you have not selected, without affecting processing that already occurred.
7. Retention
| Data | Retention | Notes |
|---|---|---|
| Sessions, messages, event streams, previews | 30 days | Deleted from the live database; preview files go with them |
| Raw model requests/responses (code and prompts) | 7 days | Deleted outright, never archived |
| Audit logs (who did what) | 180 days | Security traceability only; no conversation content |
| Usage ledger (token counts) | 90 days | Daily aggregates are kept long-term as the billing basis |
| Object-storage backups | 7 days | After deletion, recoverable from backup for up to 7 days, then gone |
Account deletion starts a 30-day cooling-off period during which it can be cancelled. After that we hard-delete across the database, local uploads and previews, the object store (uploaded/preview/export files and skill bundles), sandboxes, Redis keys and backup indexes.
8. Your rights
- Access and portability: export sessions (JSONL) and files from the app.
- Rectification: profile data is edited at the identity provider; other configs are self-service.
- Erasure: deleting a session takes effect immediately; account deletion is described above.
- Withdraw consent: clear the cross-border consent or the analytics identifier (clear localStorage).
- Complaint: write to privacy@holomer.space; we reply within 7 working days. You may also complain to a competent regulator.
9. Security measures
- Tenant isolation: every business table carries tenant_id with row-level security enforced in the database.
- Secrets: model keys and MCP tokens are envelope-encrypted (per-record DEK, rotatable KEK); the API returns masks only.
- Auditing: administrative and cross-tenant access is logged for 180 days.
- Least privilege: separate database roles for app, migrations and operations.
In the event of a personal data breach we notify affected users by email and on-site notice within 72 hours of confirmation, describing scope and remediation.
10. Minors
The service is for developers aged 18 or over. Age is confirmed at sign-up; accounts found to belong to minors are disabled and their data deleted.
11. Changes
Current version: 2026-11-10. Material changes are announced in the changelog 7 days in advance and require re-consent at next sign-in; editorial changes only update the version and date.
12. Contact
Privacy: privacy@holomer.space. Contracts and legal: legal@holomer.space.
This page forms part of the contract text; the signed PDF prevails in case of conflict.