Terms of Service (EULA)

1. Acceptance of Terms

By accessing or using Virtual Twilight, you agree to be bound by these Terms of Service. If you do not agree to these terms, you may not access or use the service.

2. Age Restriction (18+)

Virtual Twilight contains mature content and is strictly for users aged 18 and older. By creating an account, you certify that you are at least 18 years of age.

Age assurance: Access to mature content requires you to confirm you are 18 or over before entering (18+ content gate). We may additionally use technical signals and, where required by applicable law, a stronger age-verification step. Providing false age information is a breach of these Terms and will result in immediate account termination.

Sensitive content & explicit consent (GDPR Art. 9): Conversations in mature modes may reveal data concerning your sex life or sexual orientation, which is a special category of personal data. By enabling mature content, you give your explicit consent under GDPR Article 9(2)(a) to our processing of such data solely to provide the service. You may withdraw this consent at any time by disabling mature content or deleting your account.

3. User Conduct

You agree not to use the service for any illegal purposes or to harass, threaten, or abuse other users. While interactions with AI NPCs allow for freedom of expression, hate speech and illegal content are prohibited.

4. AI Model Technology & Content Filtering

Virtual Twilight utilizes advanced artificial intelligence language models to power NPC interactions. Depending on your subscription tier and selected mode:

• Safe Neural Interaction (Free & Walker): Powered by Microsoft Azure AI Services with built-in content safety policies. This mode enforces responsible AI guidelines and may moderate certain requests.
• Twilight Core (Prime & Architect): Access to unfiltered AI responses via Mistral-based models hosted on private infrastructure. This mode allows mature content within legal boundaries.

AI Technologies Used: Virtual Twilight may utilize various AI models and services including but not limited to: OpenAI GPT models, Microsoft Azure OpenAI Service, Anthropic Claude, Google Gemini, Mistral AI, and other frontier AI systems. The specific models used may change as technology evolves to provide the best experience.

You acknowledge that AI-generated content may be unpredictable. Virtual Twilight is not responsible for AI responses, though we provide tools to report issues.

AI transparency (EU AI Act, Reg. (EU) 2024/1689, Art. 50): All characters in Virtual Twilight are fictional and powered by artificial intelligence — you are always interacting with an AI system, never a real person. All dialogue, images, and audio are artificially generated. Because the content is evidently fictional and creative, we disclose its AI-generated nature here and through periodic in-experience reminders rather than labelling every individual message.

⚠️ Important: All AI modes prohibit illegal content (child safety violations, terrorism, etc.). Violations will result in immediate account termination and legal reporting where required.

5. Twilight Kredits (TK)

Twilight Kredits (TK) are Virtual Twilight's in-platform virtual currency. You can earn TK through gameplay, achievements, daily bonuses, promotions, and other in-app activities. TK may be used to unlock companions, worlds, cosmetics, tier benefits, and other features inside Virtual Twilight.

• TK have no cash value and are not real money.
• TK cannot be redeemed, exchanged, sold, or converted into money, bank transfers, gift cards, or any other real-world currency or monetary benefit.
• TK are not a financial instrument, store of value, or payment method outside Virtual Twilight.
• Virtual Twilight is not a gambling service. TK are not used for wagering against the house, casino games, lotteries, or any activity where you stake TK or money for a chance to win money or cash-equivalent prizes.
• Unused TK are tied to your account. If your account is closed or terminated, unused TK are forfeited unless mandatory law requires otherwise.
• We may adjust earn rates, prices, or features that use TK at any time. TK balances may be corrected if granted in error or obtained through abuse.

Paid Twilight Kredit packs are sold by Van Mardigain Project Oy through direct OP/SEPA bank-transfer checkout. Card checkout, PayPal, Stripe, and similar third-party payment processors are not used for consumer TK purchases. Seller identity, VAT-inclusive price, currency (EUR) and payment instructions are shown before you confirm an order.

Purchased TK and bank transfers: Where direct purchase of TK is available, the seller, total price, applicable taxes, payment currency and payment instructions are displayed before you confirm an order. Consumer prices displayed at checkout include applicable VAT where VAT is required. For customers within the European Union, the VAT treatment may depend on your country of residence or normal location. Payments made through direct bank-transfer checkout must be sent in the currency specified at checkout, for the exact amount shown, and using the payment reference assigned to that order. Your own bank may charge currency-conversion, transfer, intermediary-bank or other fees — these are not included in the Virtual Twilight purchase price unless expressly stated otherwise. A bank payment does not by itself credit TK; TK are delivered after we have successfully matched and confirmed the payment. If you omit or enter an incorrect payment reference, delivery may be delayed while the payment is identified manually. Pending unpaid orders may expire or be cancelled without affecting your existing account or TK balance.

Digital delivery and right of withdrawal: Purchased TK are digital content supplied electronically to your account. Before completing a paid TK order you are asked separately to (1) expressly request that delivery begins as soon as payment is received and confirmed, and (2) acknowledge that, where permitted by applicable consumer law, the statutory right of withdrawal is lost once delivery begins. Once payment is confirmed and TK are credited, the purchase is considered delivered. Where the legally required conditions for immediate digital delivery and loss of the withdrawal right have been satisfied, you do not have a change-of-mind right to cancel merely because some or all TK remain unused. This does not affect mandatory rights where payment was received but TK were not delivered, an incorrect quantity was delivered, you were charged incorrectly or more than once, or the digital content does not conform to mandatory consumer-protection requirements. If a refund is legally required after TK have been credited, we may remove the corresponding unused TK from your account; where TK have already been consumed, the matter will be handled in accordance with applicable consumer law.

Purchase confirmation: After a paid TK purchase is confirmed and TK are credited, we provide confirmation in a durable form through your account order receipt / purchase history (and any then-published downloadable receipt), including seller identity, order number, date of purchase, purchased TK and any bonus TK, total amount paid, applicable VAT information, payment reference, confirmation of delivery, your immediate-delivery request and withdrawal acknowledgement, and links to the Terms and Privacy Policy. Email confirmation may be added later; until then the account receipt is the durable confirmation record.

6. Refunds & Digital Content

Consumer TK purchases are paid by direct bank transfer to Van Mardigain Project Oy. There is ordinarily no card/wallet payment processor refund to reverse because Stripe/PayPal consumer checkout is not used. Twilight Kredits earned or granted in-platform are virtual benefits and are generally non-refundable and non-redeemable for money, except where mandatory consumer law requires otherwise for a paid digital purchase.

Where paid TK bank-transfer purchases are available, we may offer a voluntary goodwill refund window (for example within 24 hours of an initial paid purchase with limited usage). Any such policy will be stated at checkout and will not turn TK into cash. This is separate from mandatory statutory consumer rights.

EU/Finnish right of withdrawal & immediate performance: Virtual Twilight is supplied as digital content that becomes available immediately. Where a paid purchase applies, by completing it and starting to use the service you expressly request that performance begins immediately and you acknowledge that you lose the statutory 14-day right of withdrawal once the service has been used, in accordance with Article 16(m) of Directive 2011/83/EU and Chapter 6 of the Finnish Consumer Protection Act. Any goodwill refund measure does not limit mandatory consumer rights that cannot be waived under applicable law.

7. Subscription Tiers & Neural Transmitter

Virtual Twilight offers four access tiers: Free, Walker, Prime, and Architect. Paid tiers may be activated with Twilight Kredits purchased via Van Mardigain Project Oy bank-transfer checkout (or other then-published in-platform methods). Card/PayPal processors are not used for consumer TK sales. Each tier includes a daily message allowance, autonomous NPC actions, and access to the Neural Transmitter system. Listed euro amounts on marketing pages describe the bank-transfer pack prices unless otherwise stated.

Neural Transmitter — How It Works

• Neural Link (free item): Allows an NPC to send you AI-generated proactive messages. Free links compete within your tier's daily cap. The system randomizes which free-linked NPCs send each day.
  Tier caps: Free 1/day · Walker 3/day · Prime 5/day · Architect 8/day.
• Neural Bond (paid item, typically priced in TK): Guarantees delivery. Bonded NPCs always fire their messages regardless of the tier cap, up to 2 messages per bonded NPC per day. Bond messages are not counted against the free-link cap.

All NPC proactive messages are stored in your Chronicles and available in-app. Daily synopsis emails summarizing NPC activity are delivered to all players. You can disable NPC message emails or daily synopsis emails at any time via notification preferences in your account settings.

8. Voice Processing & Consent

Virtual Twilight offers AI-synthesized voice output for NPC dialogue. Two voice tiers are available:

• Standard voices: Included in all tiers at no extra cost. Generated on our own infrastructure. No third-party processing.
• Premium ElevenLabs voices (optional add-on, +€7/mo): Available as a paid add-on for any tier. When you enable this add-on, your NPC dialogue text is transmitted to ElevenLabs Inc. for voice synthesis. ElevenLabs processes the text in real time and returns audio; no conversation content is retained by ElevenLabs beyond transient processing. You may cancel this add-on at any time.

Lawful Basis (GDPR Art. 6): Voice processing is based on your explicit consent given at the point of enabling the premium voices add-on. You may withdraw consent at any time by disabling the add-on in your account settings, which immediately stops all ElevenLabs processing.

No biometric voice data (voice prints, recordings of the user's own voice) is collected or processed. Only NPC dialogue text is sent to ElevenLabs for synthesis.

9. Data Processors & Contracts (DPA)

We engage third-party sub-processors to deliver certain service features. Each sub-processor operates under a Data Processing Agreement (DPA) or equivalent contractual safeguards compliant with GDPR Article 28:

Provider routing depends on tier, enabled features, and active deployment path. Some routes are EU-pinned where supported, while others may involve non-EEA processing with transfer safeguards.

• Microsoft Azure AI Services — AI model inference (Safe mode). Covered by Microsoft Online Services DPA. Region configured by service path (including EU-pinned configurations where supported).
• ElevenLabs Inc. — Premium voice synthesis (optional add-on only). Covered by ElevenLabs DPA. Data processed transiently; no long-term storage of dialogue text.
• Cloud hosting & edge delivery providers — Application hosting, API routing, and edge delivery (for example Railway and Vercel) under provider contracts and platform security controls.
• RunPod Inc. — GPU compute for Twilight Core AI model hosting. Open-weights models run on dedicated instances; conversation data is processed in memory and not persisted by RunPod.
• OpenAI / Anthropic / Google — May be used for specific AI tasks. Each operates under its respective DPA with zero-retention API agreements where available.

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

10. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure lawful transfer through one or more of:

• EU-U.S. Data Privacy Framework: 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 data protection.

Application hosting, AI inference, and supporting services may route through EU or non-EEA endpoints depending on model, feature, and deployment path.

11. Data Retention & Deletion

We retain your data as follows:

• Conversation logs & game state: Retained while your account is active and for 30 days after deletion (recovery period), then permanently erased.
• Voice audio: Not stored. Standard voices are generated and streamed in real time. ElevenLabs premium audio is synthesized on demand and not retained by us or by ElevenLabs.
• AI provider caches: Third-party AI providers may retain prompt/response data for up to 30 days for abuse monitoring, after which it is deleted. We opt out of training use where the provider offers that option.
• Account & wallet records: Account identifiers and Twilight Kredit ledger entries retained while the account is active and as needed for security, abuse prevention, and any applicable legal obligations. TK are not payment-card data and have no cash value.
• Security logs: IP addresses and access logs retained for up to 90 days for security and fraud prevention.

12. Your Data Rights (DSAR)

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

• Right of Access (Art. 15): Request a copy of all personal data we hold about you, including data held by our sub-processors.
• Right to Rectification (Art. 16): Correct inaccurate personal data.
• Right to Erasure (Art. 17): Delete your account and all associated data. We will also instruct sub-processors (ElevenLabs, AI providers) to delete any data linked to your account.
• Right to Data 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.
• Right to Withdraw Consent: Withdraw consent for optional processing (e.g., premium voice add-on) at any time without affecting the lawfulness of prior processing.
• Right to Object / Restrict (Art. 21/18): Object to processing or request restriction.
• Right to Lodge a Complaint: You may file a complaint with your national Data Protection Authority.

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

When you request erasure, we propagate the deletion to all active sub-processors within 30 days. Records we must keep for security or legal reasons are anonymized rather than deleted where required.

13. Account Termination

You may request account deletion at any time. Upon deletion:

• All personal information will be removed from our systems
• Game progress and conversations will be permanently deleted
• Active paid tiers will be cancelled
• Unused Twilight Kredits are forfeited (they have no cash value and cannot be converted to money)
• Sub-processor data linked to your account is also deleted

14. Email Communications & Consent

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

• Daily Chronicles synopsis: A summary of NPC autonomous actions across your worlds. Delivered daily when activity occurs.
• Neural Transmitter messages: AI-generated messages from NPCs you've granted a Neural Link or Neural Bond item. These are also stored in-app in your Chronicles.
• Account & service notifications: Important account changes, security notices, and service updates. Paid TK purchase confirmation is provided through your account order receipt / purchase history (email confirmation may be added later).

You may manage email preferences at any time in your account settings (notification preferences). You can disable:

• NPC proactive messages (Neural Link/Bond emails)
• Autonomous NPC event digests
• Location and intrusion alerts

Essential account and security emails cannot be disabled while your account is active. Every email includes an unsubscribe link where legally required. Disabling NPC message emails does not affect in-app message delivery.

15. Intellectual Property

All content, characters, and game mechanics are owned by Virtual Twilight. You may not reproduce, distribute, or create derivative works without permission.

16. Service Changes

We reserve the right to modify, suspend, or discontinue any part of the service at any time. We will provide notice of major changes when possible.

17. Disclaimer

Virtual Twilight is an AI-driven entertainment service. Characters are fictional and generated by artificial intelligence. Their responses do not represent the views of the developers.

THE SERVICE IS PROVIDED “AS IS” WITHOUT WARRANTIES OF ANY KIND.

18. Contact

For questions about these terms, contact us at company@virtual-dawn.com or through the in-game feedback system.

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

19. Governing Law & Disputes

These Terms are governed by the laws of Finland, without regard to conflict-of-law rules. If you are a consumer resident in the EU, you also benefit from any mandatory consumer-protection provisions of the country in which you live, and nothing in these Terms limits those rights.

Disputes will be resolved by the competent courts of Finland. EU consumers may also use the European Commission's Online Dispute Resolution platform at ec.europa.eu/consumers/odr, or contact their local consumer-protection authority.