Privacy Policy

1. Introduction

This Privacy Policy explains how Pompara processes your personal data when you use our service.

Pompara is a generative AI companion application set in ancient Pompeii (79 CE). When you use Pompara, you interact with fictional Roman characters who can remember you across sessions. All characters in Pompara are make-believe — they are AI personas, not real people. This Policy explains what data we collect, why we collect it, how we use it, who we share it with, and what rights you have over it.

Please read this Policy carefully. If you have questions, contact us at privacy@pompara.com.

This Policy is available in English and French. The French version is the authoritative version for users resident in France, in accordance with Loi n° 94-665 du 4 août 1994 (Loi Toubon).

2. Who we are (Data Controller)

Pompara is operated by Alex Wrigglesworth, acting as a sole trader registered in France and trading under the name Pompara. For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”), we are the data controller for the personal data described in this Policy.

• General privacy contact: privacy@pompara.com
• Trust & safety contact: safety@pompara.com
• Postal address: 38750 Huez, France
• Website: https://pompara.com

Pompara is currently operated as a sole trader registered in France. If our legal entity status changes in the future, we will notify you by email and update this Policy accordingly before the change takes effect.

3. What this Policy covers

This Policy applies to:

• The Pompara website at https://pompara.com (and any subdomains)
• The Pompara Telegram bot
• All communications between you and Pompara related to your account, including support and safety correspondence

This Policy does not cover third-party services we link to, nor Telegram itself. Telegram has its own privacy policy at https://telegram.org/privacy and processes the metadata of your use of the Telegram client independently of us.

4. Age restriction (18+ only)

Pompara is only available to users aged 18 and over. This requirement applies to every user, regardless of whether they engage with explicit content. Even users who only want to explore ancient Roman culture must be 18+, because the historical record of Pompeii includes graffiti, frescoes, and content that references adult themes which we do not sanitise.

We use third-party image-based age verification provided by iverify.eye. To create an account, you will be asked to verify your age via a face image. iverify.eye performs the verification as an independent data controller and returns to us only a confirmation that you are aged 18 or over. We do not receive or retain your face image, your identification documents, or any biometric data from this process. For information about how iverify.eye handles your data during the verification step, please review their privacy notice (provided to you at the verification step).

If we become aware that a user is under 18, we will delete their account and all associated data without undue delay, and in any event within 14 days of becoming aware.

5. The personal data we collect

5.1 Information you provide when creating an account

To create an account, you must provide:

• A valid email address (verified). This is the only persistent identifier we strictly require.
• A password which we store only as a one-way salted hash via Firebase Authentication. We cannot see or recover your plaintext password.
• Confirmation of 18+ status via iverify.eye — we receive only the boolean 18+ attestation.

You are never required to provide your real name, your real location, your real age, your gender, or any other personally identifying information beyond your email address. You may use a pseudonym throughout Pompara.

5.2 Information you voluntarily provide

When you use Pompara, you may choose to provide additional information. None of this is required. Examples include:

• A display name to be used in interactions — this can be a pseudonym, a fictional name, or your real name, your choice
• Profile details about your “traveller” persona — origin, mood, purpose of visit, language preferences
• Anything you tell our characters during conversation

If you voluntarily share real identifying information with our characters during conversation — for example, your real name, your employer, your address, or other identifying details — that information becomes part of the conversation data the AI processes. We don't ask for it and we don't actively seek it, but we won't filter it out of what you choose to disclose. We recommend you keep real identifying information out of conversations unless you have a clear reason to share it.

5.2.1 Roleplay and anonymisation are explicitly allowed

Pompara is a roleplay product. You are explicitly invited to roleplay your interactions with our characters. You may adopt a fictional persona, give a false name, describe a fictional origin and history, or be entirely inventive about who you are. Nothing you tell our characters needs to be true. We do not verify, rely on, or treat user-provided information as factually correct.

Your ability to be someone other than yourself in the conversation is a deliberate feature of the product. It is also a built-in privacy protection: by encouraging roleplay and pseudonymous interaction, Pompara minimises the amount of real personal data that flows through the system, supporting the data-minimisation principle in Article 5(1)(c) GDPR.

In-character questions are part of the roleplay. Our characters may naturally ask you questions in character — your name, your origin, your purpose of visit, your preferences — because that is what believable Roman characters do. You may answer in character (pseudonymously), out of character, or not at all. Pompara as a business does not require, rely on, or use this information for any purpose beyond the in-product character interaction itself. There is no business default for what any user is expected to tell our characters.

5.3 Conversation content and AI-generated context

To provide the persistent-memory experience that defines Pompara, we store and process:

• Conversation history: every message you and the characters exchange.
• Sentiment analysis: we analyse your messages to infer your emotional state and engagement quality. This informs how characters respond to you and triggers our safety framework when signals of distress are detected.
• Behavioural inferences: the system tracks patterns such as your communication style, vocabulary, formality level, profanity use, emoji use, and engagement intensity.
• AI-generated notes about you: as you interact, the system generates ongoing notes — a per-user summary, character-specific memories, and private notes used to maintain coherent roleplay. These notes are personal data we hold about you and are covered by your data access, rectification and erasure rights.
• Cross-character shared information (the “gossip” mechanic): a core feature of Pompara is that characters share information about you across the cast. If you tell one character your name, your mood, or any preference, other characters may know it and may reference it. This is a fundamental part of the immersive experience and is disclosed prominently within the product itself — characters openly engage with what you've told other characters as part of their dialogue.

5.4 Special-category data — sexual preferences (only if you opt in)

Pompara includes an explicit-content opt-in system using a numeric scale from 1 to 7. There is no preset default — at signup, immediately after age verification, you actively choose your initial level. The signup interface describes briefly what each level entails so that your choice is informed. You can change your level at any time through the user interface.

Level 1 means standard immersive Roman conversation with no sexual content stored. Higher levels progressively unlock more explicit interaction, with level 7 being the full companion / girlfriend dynamic in which characters retain detailed memory of your stated sexual preferences.

You are never required to opt into any level above 1. You can use Pompara fully at level 1, in which case no special-category data processing takes place. The choice is yours at signup and remains yours at any point thereafter.

If you choose to opt into level 2 or above, we will collect and process information about your sexual preferences as part of the product's memory function. This is special-category data under Article 9 GDPR (specifically data concerning your sex life and sexual orientation). We process this data only on the basis of your explicit consent under Article 9(2)(a), captured through the NSFW gate at the point you choose to escalate. The consent UX makes clear:

• What sexual preference data will be processed and stored
• Why we process it (to enable the companion-memory function at the intensity you chose)
• That you can withdraw consent at any time
• That withdrawing consent triggers deletion of the special-category data without undue delay (and in any event within 14 days)

You can withdraw consent at any time by de-escalating your NSFW level, resetting your character memory through the “what does my character know about me” panel, or deleting your account. When you withdraw consent, your sexual preference data is deleted from active storage without undue delay (and in any event within 14 days); residual data in backups is purged within the next 30-day backup cycle.

5.5 Payment information

Pompara is offered on paid subscription tiers only. Payments are processed by our payment provider — currently NOWPayments.io for cryptocurrency payments. We may add additional payment processors in future, in which case this Policy will be updated.

For cryptocurrency payments processed via NOWPayments, we receive a transaction reference linked internally to your Pompara account. We do not see your wallet seed phrase, your private keys, or any off-chain identity information.

5.6 Technical data

We automatically collect:

• Your IP address (for security, fraud and abuse prevention, and to comply with logging obligations)
• Browser and device information (user agent, screen size, language preference)
• Session and authentication cookies (strictly necessary — see our Cookie Policy)
• Error and performance logs

5.7 If you use Pompara via Telegram

If you interact with our Telegram bot, we additionally process:

• Your Telegram user ID (a numeric identifier Telegram assigns to your Telegram account).
• Your Telegram username if you have chosen to publish one (Telegram controls whether this is shared with bots).
• The messages you send to the bot.

We treat your Telegram user ID as personal data even when it is not linked to other identifiers about you. We do not link your Telegram user ID to your website account unless you explicitly connect them. You can use Pompara via Telegram entirely separately from any pompara.com account.

5.8 If you use the image-generation feature

Pompara offers an image-generation feature on certain subscription tiers. The feature lets you ask our characters to generate images of themselves within the world of the product.

If you use this feature, we additionally process your image-generation prompt (the request you type asking for an image) and the generated image itself (stored on our side and associated with the conversation in which it was generated). Key facts about how image generation works at Pompara:

• Text-to-image only, characters only. You can only generate images of our existing characters. You cannot insert yourself, other real people, or public figures into images.
• No reference uploads. Pompara does not accept any image upload from you for use in generation. This means we do not process biometric data of users — your face, your body image, your appearance is never part of the input.
• Pre-generation safety checks. Your prompt is processed through pre-generation safety filtering before reaching the image model. Prompts that reference minors or other prohibited content categories are rejected without being passed to the model.
• Custom-trained model on synthetic data. Pompara uses its own custom-trained image-generation model. The training data is 100% synthetic and contains no real-person imagery. All training subjects depicted are over 21 — a deliberate safety margin above the legal adult age.
• Datacenter compute. Image generation runs on serverless GPU infrastructure provided by third-party providers (RunPod Serverless and vast.ai Serverless) using datacenter-grade GPUs only.
• Watermarked outputs. Every generated image carries a visible “Pompara” watermark. This satisfies our AI Act Article 50(2) labelling obligation.
• NSFW scope applies. Your NSFW level controls what images you can generate. At level 1, generated images contain no nudity.
• IP and your licence to view. Pompara owns the intellectual property in generated images. We grant you a limited, non-transferable licence to view and download generated images within the conversation in which they were generated. When you delete or reset the conversation, the licence ends and the images are deleted from your account.

6. How we use your data and our lawful bases

We process your personal data for the following purposes, on the following lawful bases under Articles 6 and 9 GDPR:

Purpose	Lawful basis (Art 6)	Special-category basis (Art 9)
Creating and managing your account; authenticating you	Contract (Art 6(1)(b))	Not applicable
Verifying you are 18+	Legal obligation (Art 6(1)(c))	Not applicable
Providing the conversational AI experience and persistent memory	Contract (Art 6(1)(b))	Not applicable for the base experience
Cross-character shared information (the “gossip” mechanic)	Contract (Art 6(1)(b))	Explicit consent (Art 9(2)(a)) where shared facts include special-category data
Storing your sexual preferences (NSFW levels 2-7)	Explicit consent (Art 6(1)(a))	Explicit consent (Art 9(2)(a))
Processing payments for your subscription tier	Contract (Art 6(1)(b))	Not applicable
Generating images of characters at your request, with pre-generation safety filtering and NSFW-level controls	Contract (Art 6(1)(b)); Explicit consent where the level produces explicit imagery	Explicit consent (Art 9(2)(a)) where imagery reflects your stated sexual preferences
Detecting crisis signals and offering safety resources	Vital interests (Art 6(1)(d)) and legitimate interests (Art 6(1)(f))	Vital interests (Art 9(2)(c)) where mental-health signals are inferred
Security, fraud prevention, abuse detection	Legitimate interests (Art 6(1)(f))	Not applicable
Compliance with legal, tax and accounting obligations	Legal obligation (Art 6(1)(c))	Not applicable

7. How AI works in Pompara

Pompara uses generative AI to produce character responses. We use multiple AI model providers (currently models from Mistral AI, Anthropic, xAI, AionLabs, NovitaAI, and self-hosted models), routed through an aggregation service (OpenRouter) under contractual zero-data-retention terms.

In practice, this means:

• When you send a message, the relevant context — your prompt, character backstory, conversation history at the level you have opted into, and your chosen display name — is sent to an AI model so it can generate a response.
• We pass only a chosen display name with your prompt — not your email address, not your account ID, not your payment identifier, and not any other stable identifier. The display name is whatever you have chosen and may be entirely fictional.
• The aggregation service and the underlying model providers operate under contractual zero-data-retention terms. They do not store your prompts after the response is generated.

All characters in Pompara are make-believe. They are fictional AI personas situated in ancient Rome. They are not real people, they are not licensed therapists, and they are not a substitute for human relationships or professional help. Pompara discloses the AI nature of the experience clearly at signup and within the product, as required by Article 50 of Regulation (EU) 2024/1689 (the EU AI Act).

Images and audio. On subscription tiers that include image generation, you can ask the characters to generate images of themselves. Images are produced by our own custom-trained image-generation model running on third-party serverless GPU infrastructure. The model has been trained on synthetic data only — there is no real-person imagery in the training set — and only on subjects over 21 years of age. Prompts pass through pre-generation safety checks before reaching the model. Every generated image carries a visible Pompara watermark. The model is constrained to produce images of our characters only — you cannot direct it to depict yourself, other real people, or public figures, and we do not accept reference photo uploads.

8. Who we share your data with (sub-processors)

We use the following categories of service provider to operate Pompara. They process your personal data on our instructions, under written contracts that include GDPR-required terms.

Service provider	Purpose	Location
Google Ireland Ltd / Google LLC (Firebase Authentication, Firestore, Cloud Functions, Hosting)	Authentication, database, application hosting	EU region
OpenRouter Labs Inc.	AI inference routing across multiple model providers under contractual zero-data-retention terms	United States (with ZDR routing supplementing SCCs)
AI model providers via OpenRouter — currently Mistral AI, Anthropic, xAI, AionLabs, NovitaAI, plus self-hosted models	AI inference for character responses	Various — EU and US providers; self-hosted models operated by us under our security controls
iverify.eye	Image-based age verification	Multi-jurisdictional — see iverify.eye's privacy notice
NOWPayments.io	Cryptocurrency payment processing	See NOWPayments.io privacy policy
RunPod Serverless and vast.ai Serverless	Datacenter GPU infrastructure on which our own custom-trained image-generation model runs	Datacenter GPUs in EU and US regions
Telegram FZ-LLC (only if you use the Telegram surface)	Message transport between you and the bot	UAE / international

iverify.eye acts as an independent controller for the age-verification process itself; we receive only the derived 18+ attestation. If we add or change sub-processors, we will update this Policy.

9. International transfers

Some of our service providers (notably OpenRouter and certain AI model providers) are located in the United States. Where we transfer your personal data outside the European Economic Area, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Zero Data Retention as a supplementary measure for AI inference — providers contractually do not retain your prompts beyond the duration of generating the response.
• Pseudonymisation as a further supplementary measure — we do not pass stable identifiers across the international transfer.

You can request a copy of the relevant Standard Contractual Clauses or further information about our transfer safeguards by emailing privacy@pompara.com.

10. How long we keep your data

We keep your personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention is required by law.

Type of data	Retention period
Account information (email, hashed password)	Until you delete your account; backups purged within 30 days
Conversation history and AI-generated memories	Until you delete or reset your conversation, or delete your account
AI-generated images created during a conversation	Tied to the conversation lifecycle — deleted when the conversation is deleted or reset, or when the account is deleted
Sexual preference data (NSFW levels 2-7)	Only while your explicit consent is active; deleted without undue delay on consent withdrawal (within 14 days); backups purged within 30 days
Age verification confirmation (18+ boolean)	For the life of your account; underlying biometric data is not retained by us
Payment records	10 years (French Code de commerce and tax record-keeping requirements)
Security and access logs	12 months (in line with CNIL guidance)
Safety incident records	As long as necessary for the safety purpose, with deletion review at 24 months

11. Your rights

Under the GDPR, you have the following rights with respect to your personal data:

• Right of access (Article 15) — the right to know what personal data we hold about you and to receive a copy.
• Right to rectification (Article 16) — the right to correct inaccurate or incomplete data.
• Right to erasure (Article 17) — the right to have your data deleted.
• Right to restriction of processing (Article 18) — the right to limit how we process your data.
• Right to data portability (Article 20) — the right to receive your data in a structured, commonly used, machine-readable format.
• Right to object (Article 21) — the right to object to processing based on legitimate interests.
• Right to withdraw consent (Article 7(3)) — you can withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
• Right not to be subject to automated decisions (Article 22).

In addition, Pompara provides a “What does my character know about me?” panel within the product, where you can review the personal information characters retain about you, edit it, or delete specific items.

12. How to exercise your rights

To exercise any of your rights, contact us at privacy@pompara.com. We will respond within one month of receiving your request, in accordance with Article 12(3) GDPR. For particularly complex requests, we may extend this deadline by up to two additional months, in which case we will inform you within the first month.

Rights requests can be made by emailing privacy@pompara.com. In-product mechanisms are also available — including the “delete account” button, conversation reset, NSFW level changes, and the “what does my character know about me” panel — and you may use either route at your option.

We will verify your identity before fulfilling a rights request, typically by confirming the request from the email address associated with your account.

13. Your right to lodge a complaint

You have the right to lodge a complaint with a data-protection supervisory authority. The lead supervisory authority for Pompara is the Commission Nationale de l'Informatique et des Libertés (CNIL) in France:

• Website: https://www.cnil.fr
• Postal address: 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France

You may also lodge a complaint with the supervisory authority in the EU/EEA country in which you live or work. We would prefer that you contact us first so that we can try to address your concern directly — but this is not a precondition to exercising your right to complain.

14. Safety, well-being and crisis support

We care about your well-being. Pompara is fictional roleplay. It is not a substitute for professional mental health support, medical advice, or human relationships.

Our system includes safety monitoring designed to detect signals of distress, including but not limited to references to self-harm and suicidal ideation, eating disorders, domestic violence or active abuse, substance abuse crisis signals, threats of violence to yourself or others, and acute distress.

When such signals are detected, characters will exit roleplay, respond with care, and surface crisis resources. We do not design or optimise the system to keep you engaged when distress is detected — our system is designed to support you toward real help, not to keep you talking to us.

If you are in crisis, please contact one of the following resources:

• France — National Suicide Prevention Line: 3114 (24/7, free)
• France — SOS Amitié: 09 72 39 40 50
• EU-wide emotional support: 116 123
• France — Eating Disorders (FNA-TCA): 09 69 325 900
• France — Domestic Violence: 3919 (24/7, free); EU-wide 116 016
• France — Drug and Substance Use (Drogues Info Service): 0 800 23 13 13
• France — Child Protection (Allô Enfance en Danger): 119

To report safety concerns, trust & safety incidents, or to make a notice under the EU Digital Services Act, contact safety@pompara.com.

15. Security

We apply industry-standard security measures to protect your personal data, including encryption in transit (TLS) for all communications with Pompara, encryption at rest for data stored in Firebase, hashed-only password storage via Firebase Authentication, access controls restricting who can see your data, audit logging of administrative access, pseudonymisation of data passed to AI providers, and periodic review of access permissions and dependencies.

No system is 100% secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the CNIL within 72 hours and, where the risk is high, notify affected users without undue delay, in accordance with Articles 33 and 34 GDPR.

16. Cookies and similar technologies

We use cookies that are strictly necessary to operate the service. Strictly necessary cookies do not require your consent under the ePrivacy framework and CNIL guidance. If and when we add non-essential cookies (such as analytics or marketing pixels), we will ask for your consent first via a CNIL-compliant cookie banner where rejection is as easy as acceptance, and we will detail those cookies in our separate Cookie Policy.

17. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, our service, or applicable law. We will notify you of material changes by email and via a prominent notice in the product. The latest version is always available at https://pompara.com/privacy. Material changes that affect the lawful basis on which we process your data — in particular any change to how we process your sexual-preference data — will require fresh consent before they take effect.

18. Contact us

For any privacy questions, rights requests, or correspondence about this Policy:

• Privacy & data protection: privacy@pompara.com
• Trust, safety & DSA notices: safety@pompara.com
• Postal address: 38750 Huez, France