Privacy Policy

1. Information We Collect

When you use Virtual Twilight, we collect the following information:

• Account Information: Email address, username, authentication tokens
• Usage Data: Conversations with NPCs, game progress, player choices, achievements
• Account wallet data: Twilight Kredit (TK) balance and ledger events for in-platform unlocks. TK are virtual currency with no cash value. Paid TK packs are sold by Van Mardigain Project Oy via direct OP/SEPA bank transfer. We do not process consumer card or PayPal checkout, and we do not store payment card numbers.
• Technical Data: IP address, device type, browser information for security and analytics

Payment, purchase and tax information: When you place or complete a paid order, we may process information necessary to create the order, identify the payment, deliver the purchased digital content, maintain accounting records and comply with tax obligations. This may include your account identifier, name and email address, the country you declare for billing or tax purposes, IP address and IP-derived country information, order number and payment reference, purchased product or TK package, transaction amount, currency and date, payment status, payer or bank information made available through our bank, accounting provider or payment reconciliation system, applicable VAT country, VAT rate, taxable amount and VAT amount, information used to resolve conflicting customer-location evidence, timestamps recording acceptance of Terms and Privacy information, timestamps recording any request for immediate digital delivery and acknowledgement concerning the right of withdrawal, and refund, correction or payment-dispute information where applicable. We process this for creating and performing your purchase contract, identifying incoming payments, delivering purchased content, preventing duplicate crediting, fraud and misuse, providing customer support, issuing confirmations, maintaining accounting records, and determining, documenting, reporting and paying VAT and other taxes. Payment and tax records are retained for the periods required by applicable accounting, tax and consumer-protection legislation. We do not store online-banking credentials and do not require access to your personal bank account. When you make a bank transfer, your bank processes the payment independently; we receive only the payment and associated information made available through the banking and reconciliation process. Where we use a tax-compliance, accounting or payment-reconciliation provider, necessary transaction and customer-location information may be disclosed to that provider.

Twilight Kredits (TK)

Twilight Kredits are Virtual Twilight's in-platform virtual currency. We store your TK balance and related ledger events so features can unlock correctly across games and worlds.

• TK are not money and have no cash value.
• TK cannot be redeemed, sold, or converted into real-world currency.
• TK are not used for gambling or for staking toward cash prizes.
• Paid TK packs may be purchased by bank transfer to Van Mardigain Project Oy; TK are also earned and spent inside the product. Consumer card/PayPal checkout is not used.

2. How We Use Your Information

Your data is used to:

• Provide and improve the gaming experience
• Personalize your experience with AI characters
• Manage account tiers and Twilight Kredit balances
• Generate personalized AI responses
• Ensure account security and prevent abuse
• Analyze usage patterns to improve features
• Send important service notifications

3. Data Storage & Security

We use industry-standard security measures:

• Encrypted database connections (PostgreSQL with SSL)
• Secure authentication with JWT tokens and per-user API keys
• Regular security audits and updates
• Access controls limiting employee data access

Your conversations are stored to provide continuity in gameplay and NPC memory features. We do not sell or share this data with third parties for marketing purposes.

4. Lawful Basis for Processing (GDPR Art. 6)

We process your personal data on the following legal bases:

• Contract performance (Art. 6(1)(b)): Processing your account data, conversations, and game state is necessary to provide the Virtual Twilight service as agreed in the Terms of Service.
• Consent (Art. 6(1)(a)): Optional processing such as premium ElevenLabs voice synthesis is performed only with your explicit, freely-given consent. You may withdraw consent at any time by disabling the add-on.
• Legitimate interest (Art. 6(1)(f)): Security logging, fraud prevention, and service analytics are processed under our legitimate interest in maintaining a safe and functional platform.
• Legal obligation (Art. 6(1)(c)): Where applicable, records required by law for paid TK bank-transfer sales (accounting, VAT evidence, order receipts). We do not process consumer card/PayPal payments for Virtual Twilight.

Special-category data (Art. 9): Because Virtual Twilight is an 18+ service, conversations in mature modes may reveal data concerning your sex life or sexual orientation. This is a special category of personal data under GDPR Article 9. We process it only on the basis of your explicit consent (Art. 9(2)(a)), given when you enable mature content, and solely to provide the service. You may withdraw this consent at any time by disabling mature content or deleting your account.

5. AI Model Processing & Sub-Processors

Virtual Twilight uses various AI services to power NPC conversations. Your messages may be processed by the following providers, each operating under a Data Processing Agreement (DPA) compliant with GDPR Article 28:

Provider routing depends on your tier, selected features, and active deployment path. Some routes are configured to EU regions where supported; others may involve processing outside the EEA with contractual transfer safeguards.

• Microsoft Azure AI Services: Primary provider for Safe Neural Interaction mode. GPT-4o-mini used for Free and Walker tiers. Subject to Microsoft Online Services DPA. Region configured by service path (including EU-pinned configurations where supported).
• OpenAI: GPT models may be used for advanced reasoning and content generation. Zero-retention API (no training on inputs). Subject to OpenAI DPA.
• Anthropic Claude: May be used for specific analytical tasks and content moderation. Subject to Anthropic DPA.
• Google Gemini: May be utilized for multimodal features and development purposes. Subject to Google Cloud DPA.
• Mistral AI / Twilight Core: Powers the full-range Twilight Core experience on private infrastructure (RunPod GPU compute). Open-weights models hosted on dedicated instances. Available for Prime and Architect tiers. Conversations are processed in memory and not persisted by the infrastructure provider.
• ElevenLabs Inc. (optional add-on only): Used only when a player enables premium voices as a paid add-on (+€7/mo). NPC dialogue text is transmitted for voice synthesis and returned as audio. No dialogue content is retained by ElevenLabs beyond transient processing. No biometric data (player's own voice) is collected. Subject to ElevenLabs DPA. Processing is based on explicit consent (see Section 4).

Data Retention by Providers: AI providers may temporarily cache prompt/response data for up to 30 days for abuse monitoring. We opt out of training use on all providers that offer that option.

A current list of sub-processors is maintained and available on request at company@virtual-dawn.com.

6. Voice Processing

Virtual Twilight offers two voice tiers:

• Standard voices: Generated on our own infrastructure. No third-party processing. Included in all tiers.
• Premium ElevenLabs voices: Optional paid add-on (+€7/mo) for any tier. When enabled, NPC dialogue text is sent to ElevenLabs for synthesis. Audio is streamed in real time and not stored by either party.

You control this processing entirely: enable or disable the add-on at any time in account settings. Disabling immediately stops all ElevenLabs processing.

7. International Data Transfers

Virtual Twilight runs on managed cloud infrastructure and AI providers. Depending on the active provider route, processing may occur within or outside the EEA. We ensure lawful transfer through:

• EU-U.S. Data Privacy Framework (DPF): For US-based processors certified under the DPF (for example ElevenLabs, OpenAI, Anthropic, Google, where applicable).
• Standard Contractual Clauses (SCCs): Where the DPF does not apply, we rely on EU-approved SCCs (Commission Decision 2021/914) incorporated into our DPAs.
• Adequacy decisions: For transfers to countries recognized by the European Commission as providing adequate protection.

8. Third-Party Services

We use the following trusted third-party services:

• Cloud hosting & edge delivery providers: Application hosting, API routing, and edge delivery are provided through managed cloud infrastructure partners (for example Railway and Vercel), with security controls managed under provider contracts and platform configuration.
• Google OAuth: Optional authentication provider. We only receive basic profile information (name, email) necessary for account creation.
• RunPod: GPU infrastructure for Twilight Core AI model hosting. Dedicated instances; data is processed in memory and not persisted.

Consumer TK purchases use direct bank transfer to Van Mardigain Project Oy. Stripe, PayPal, and similar card/wallet processors are not used for consumer Virtual Twilight checkout. Twilight Kredits cannot be cashed out.

9. Cookies & Local Storage

We use essential cookies and browser local storage for:

• Session authentication and login persistence
• Remembering user preferences and settings
• Security and fraud prevention
• Age compliance verification (18+ content gate)

We do not use third-party advertising cookies or sell tracking data.

10. Your Data Rights (DSAR)

Under GDPR, you have the following rights. We respond within 30 days:

• Access (Art. 15): Request a copy of all personal data we hold, including data held by sub-processors.
• Rectification (Art. 16): Correct inaccurate personal data.
• Erasure (Art. 17): Delete your account and all associated data. Deletion is propagated to all active sub-processors (ElevenLabs, AI providers, and other processors then in use).
• Portability (Art. 20): Where applicable, you may request eligible personal data in a structured, commonly used and machine-readable format. This does not include our internal AI representations, embeddings, model state, or derived system data.
• Withdraw Consent: Withdraw consent for optional processing (e.g., premium voices) at any time without affecting prior lawful processing.
• Object / Restrict (Art. 21/18): Object to processing or request restriction.
• Complaint: File a complaint with your national Data Protection Authority.

To exercise your data protection rights, contact company@virtual-dawn.com. Where self-service controls are available, they may also be used through your account settings.

11. Data Retention & Deletion

We retain your data as follows:

• Account & game state: While your account is active and for 30 days after deletion (recovery period).
• Voice audio: Not stored. Generated and streamed in real time (both standard and ElevenLabs).
• AI provider caches: Up to 30 days (abuse monitoring), then deleted. We opt out of training use.
• Twilight Kredit ledger: Balance and transaction history while the account is active. TK have no cash value and cannot be converted to money.
• Security logs: IP addresses and access logs retained for up to 90 days.

When you request erasure, deletion is propagated to all active sub-processors within 30 days. Records we must keep for security or legal reasons are anonymized where required. Paid TK bank-transfer order and VAT records are retained for the periods required by accounting and tax law.

12. Email Communications

By creating an account, you consent to receive service-related emails including:

• Daily Chronicles synopsis: Summary of NPC autonomous actions and world events.
• Neural Transmitter messages: AI-generated NPC messages (when you've granted Neural Link or Neural Bond items). Also available in-app via Chronicles.
• Account notifications: Important account and service changes. Paid TK purchase confirmation is provided through account order receipts (email confirmation may be added later).

You may disable NPC messages, autonomous event digests, and location alerts at any time via notification preferences in your account settings. Every email includes an unsubscribe link where required. Essential account and security emails may remain active while your account is open. Disabling email notifications does not affect in-app message delivery.

13. Age Verification

Virtual Twilight is for users 18 and older. We do not knowingly collect data from minors. If we discover a user is underage, their account will be immediately terminated and data deleted.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Major changes will be announced through the game interface. Continued use after changes constitutes acceptance of the updated policy.

15. Data Controller & Contact

Data Controller: Virtual Twilight (Van Mardigain Project Oy), Business ID (Y-tunnus) 3131429-9, Tampere, Finland.

For privacy-related questions, data subject access requests (DSAR), or to exercise any of your rights, contact us at company@virtual-dawn.com or through the in-game feedback system.