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Privacy Policy

How we collect, use, protect, and handle your personal information.

Effective Date: May 1, 2026

Contents

  1. Introduction
  2. Information We Collect
  3. How We Use Your Information
  4. Data Storage and Security
  5. Third-Party Services
  6. Cookies and Tracking
  7. User Rights (GDPR/CCPA)
  8. Data Retention
  9. Age Verification
  10. Changes to This Policy
  11. Contact Us

1 Introduction

HornyCompanionAI ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you access or use our website at hornycompanionai.com and all associated services, features, and content (collectively, the "Platform"). Please read this Policy carefully. By using the Platform, you agree to the practices described herein.

Our Platform is intended exclusively for adults aged 18 and over. We take privacy seriously in all respects — and we take it especially seriously given the intimate nature of our service. This document is our honest, plain-language commitment to you about how your data is handled. If you have any questions after reading it, please contact us using the details in Section 11.

This Privacy Policy is incorporated into and forms part of our Terms of Service. Terms not defined here have the meanings given to them in the Terms of Service. This Policy applies to all users regardless of location, though certain rights described herein may be jurisdiction-specific.

2 Information We Collect

We collect information in three primary ways: information you provide directly, information collected automatically as you use the Platform, and information we receive from third parties. We are committed to collecting only what is necessary to provide and improve our service.

Information You Provide Directly: When you create an account, you provide an email address and password. If you subscribe to a premium plan, your payment information is collected by our third-party payment processors (we do not receive or store full card numbers). If you complete age verification, identity documents are processed by our third-party verification provider. Any information you voluntarily share in conversations with AI companions is stored to power the persistent memory system.

Information Collected Automatically: When you use the Platform, we automatically collect technical information including your IP address (truncated to protect precise location), browser type and version, operating system, device identifiers, pages visited, time spent on pages, referring URLs, and session timestamps. This data is collected via server logs, cookies, and similar technologies described in Section 6.

Information from Third Parties: If you choose to authenticate using a third-party provider (such as Google), we receive your name and email address from that provider. Payment processors may share transaction status information with us (success or failure) but not raw payment credentials. Age verification providers share a simple pass/fail result — not your underlying identity documents.

3 How We Use Your Information

We use your information only for legitimate purposes directly related to operating and improving the Platform. We do not sell your personal information to third parties. We do not use your conversation content for targeted advertising. We do not build profiles of your behavior to sell to data brokers. The following describes the specific ways we use your data:

  • To create and manage your account and authenticate your identity
  • To power the AI companion persistent memory system that makes your relationships meaningful
  • To process payments and manage subscription billing
  • To verify your age and enforce our 18+ requirement
  • To send transactional communications (receipts, password resets, service notifications)
  • To detect and prevent fraud, abuse, and violations of our Terms of Service
  • To analyze aggregate, anonymized usage patterns to improve Platform features and performance
  • To comply with applicable law and respond to lawful legal process

We do not use the content of your conversations to train AI models without your explicit, opt-in consent. If we introduce an opt-in AI training program in the future, participation will be entirely voluntary, clearly described, and separately consented to. You will never be opted in automatically.

4 Data Storage and Security

Your data is stored on secure servers operated by industry-leading cloud infrastructure providers in data centers located in the United States and the European Union. We use geographic data residency controls to ensure that EU users' data is primarily stored in EU-based infrastructure, in compliance with GDPR transfer requirements.

We implement multiple layers of technical security to protect your information. All data in transit is encrypted using TLS 1.2 or higher. All data at rest — including conversation history — is encrypted using AES-256. Access to production databases is restricted to a small number of vetted engineers and requires multi-factor authentication. We conduct quarterly third-party security audits and penetration tests to proactively identify vulnerabilities.

No system can guarantee perfect security, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. In the event of a data breach that poses a risk to your rights or freedoms, we will notify affected users and relevant regulatory authorities within the timeframes required by applicable law — and in any case no later than 72 hours after we become aware of the breach. We maintain an incident response plan that is reviewed and tested annually.

If you believe you have discovered a security vulnerability in our Platform, please report it responsibly to security@hornycompanionai.com. We operate a responsible disclosure program and will work with you promptly to assess and address any confirmed issues.

5 Third-Party Services

We work with a limited number of carefully selected third-party service providers to operate the Platform. These providers are given access only to the data necessary to perform their specific service, are contractually prohibited from using your data for any other purpose, and are required to maintain security standards at least as stringent as our own. We do not permit our service providers to sell or further disclose your data.

Our primary third-party categories include: payment processors (who handle subscription billing and fraud prevention), cloud infrastructure providers (who host our servers and databases), age verification providers (who confirm users meet our 18+ requirement), email service providers (who send transactional notifications), and anonymized analytics providers (who help us understand aggregate Platform usage). We do not use third-party advertising networks or behavioral tracking services.

Our Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those external sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit through links from our Platform.

6 Cookies and Tracking

We use cookies and similar tracking technologies (such as local storage and session storage) to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, remember your preferences, and understand how the Platform is used. We do not use third-party advertising cookies or cross-site tracking technologies.

Essential Cookies: Required for the Platform to function. These include authentication tokens (which keep you logged in), session identifiers, and age gate confirmation cookies. You cannot opt out of essential cookies while using the Platform.

Functional Cookies: Remember your preferences such as theme settings, notification preferences, and companion favorites. Disabling these may affect your experience but will not prevent you from using the Platform.

Analytics Cookies: Collect anonymized, aggregate information about how users interact with the Platform (such as which features are most used). This data contains no personally identifiable information. You can opt out of analytics cookies via your account settings or by using standard browser cookie controls.

We do not use tracking pixels, browser fingerprinting, or cross-device tracking. We do not share cookie data with advertising networks. Most browsers allow you to control cookies through their settings. Please note that blocking essential cookies will prevent you from logging in to the Platform.

7 User Rights (GDPR / CCPA)

Depending on your location, you may have specific legal rights regarding your personal data. We honor these rights for all users regardless of jurisdiction, not only those in the EU or California. We believe everyone deserves meaningful control over their data.

  • Right to Access: You can request a copy of all personal data we hold about you, including your account information, payment history, and conversation memory profile.
  • Right to Rectification: You can correct inaccurate personal data directly in your account settings, or request corrections from our support team.
  • Right to Erasure ("Right to be Forgotten"): You can request permanent deletion of your account and all associated data. See Section 8 for retention timelines.
  • Right to Portability: You can request an export of your personal data in a machine-readable format (JSON or CSV).
  • Right to Restrict Processing: You can request that we limit how we use your data in certain circumstances.
  • Right to Object: You can object to certain types of data processing, including any future direct marketing communications.
  • Right to Opt Out of Sale (CCPA): We do not sell personal information. If this ever changes, California residents will be provided a clear opt-out mechanism.

To exercise any of these rights, email privacy@hornycompanionai.com with your request. We will respond within 30 days (or within the timeframe required by applicable law if shorter). We may need to verify your identity before fulfilling a request. There is no charge for exercising your rights.

8 Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Platform's services. The persistent memory system — which is core to the companion relationship — necessarily retains conversation-derived memories for as long as your account exists. You can delete specific memories or your entire memory profile at any time from your account settings without deleting your account.

If you delete your account, we will permanently delete your personal data — including your email address, account details, conversation history, and memory profile — within 30 days of your deletion request. Some aggregate, non-identifiable data derived from your usage may be retained in our anonymized analytics systems indefinitely. Payment transaction records are retained for the period required by applicable tax and financial regulations, typically 7 years, but this data is held by our payment processor and contains no conversation or behavioral data.

We may retain certain limited information beyond these periods if necessary to comply with legal obligations (such as a court order), resolve disputes, enforce our agreements, or protect against fraud. In such cases, the retained information is restricted to what is strictly necessary and is accessed only for the specified purpose.

9 Age Verification

HornyCompanionAI is an adult platform strictly for users aged 18 and over. We take our legal and ethical obligation to prevent underage access extremely seriously. All users must confirm their age at the platform entry gate and at account registration. This self-declaration constitutes a legal attestation that the user meets our minimum age requirement.

For access to higher-tier NSFW content, we utilize an independent third-party age verification provider that may require users to submit government-issued identification documents. We have deliberately structured this process to maximize privacy: the verification provider performs the identity check directly and returns only a pass or fail result to us. We do not receive, view, or store copies of your identification documents. The verification provider's own privacy policy governs their handling of submitted documents.

Age verification data and the results of verification checks are retained only as long as necessary to maintain your access status and to demonstrate compliance with applicable law. If you are found to have provided false age information to gain access to our Platform, your account will be permanently terminated and you may be subject to legal consequences under applicable law.

10 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes — meaning changes that significantly affect how we handle your personal data or reduce your privacy rights — we will notify you proactively. Notification will be provided via email to the address on your account and via a prominent notice on the Platform at least 14 days before the changes take effect.

For non-material changes (such as clarifications, formatting updates, or corrections that do not affect the substance of our data practices), we will update the "Effective Date" at the top of this Policy. We encourage you to review this Policy periodically to stay informed. Your continued use of the Platform after any changes take effect constitutes your acceptance of the updated Policy.

All previous versions of this Privacy Policy are archived and available upon request. If you disagree with a material change to this Policy, your remedy is to delete your account and discontinue use of the Platform before the change takes effect. Contact privacy@hornycompanionai.com if you have questions about any changes.

11 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact our Privacy Team. We take all privacy inquiries seriously and will respond within 5 business days for general questions and within 30 days for formal rights requests.

Privacy Team: privacy@hornycompanionai.com
General Support: support@hornycompanionai.com
Security Disclosures: security@hornycompanionai.com
Postal Address: HornyCompanionAI Inc., Privacy Department, [Address on file with registered agent]

If you are located in the European Union and are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with your local data protection authority. For EU residents, our EU representative contact details are available upon request. If you are located in California and have questions about your CCPA rights, our designated consumer privacy contact is privacy@hornycompanionai.com.

We are committed to working with you to resolve any privacy concerns fairly and promptly. We would much rather address your concerns directly than have you escalate to regulators — and we will always make a genuine effort to do so.

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