Privacy Policy

Effective Date: October 1, 2026

1. Introduction and Scope

EroGrid ("Company", "we", "our", or "us") is committed to protecting the privacy and security of the personal data of our users ("you", "your"). This Privacy Policy details the technical and operational methodologies we employ to collect, process, store, and transfer your data within our artificial intelligence content generation infrastructure (the "Services").

As an entity operating from the European Union, this policy has been drafted in strict adherence to the General Data Protection Regulation (GDPR) (EU) 2016/679, the Digital Services Act (DSA) (EU) 2022/2065, the ePrivacy Directive, and applicable international data protection frameworks including the California Consumer Privacy Act (CCPA).

2. Identity of the Data Controller

For the purposes of the GDPR, EroGrid acts as the Data Controller for the personal data collected through the Services.

Contact Information for Privacy Matters:

Data Protection Officer (DPO): dpo@erogrid.com
Legal Department: legal@erogrid.com

3. Categories of Personal Data Collected

We collect and process the following categories of personal data, strictly adhering to the principle of data minimization:

3.1 Identity and Contact Data

Registration Data: Encrypted email address, cryptographic password hashes (bcrypt/Argon2), and assigned alphanumeric User IDs.
Age Verification Data: To comply with strict EU and member state regulations regarding adult content, we utilize certified third-party Identity Verification Providers (IDVs). EroGrid does not permanently store your raw biometric data or unredacted government ID images. We solely retain a cryptographic confirmation token and the verified Date of Birth required for legal audits.

3.2 Financial and Transaction Data

Payment Processing: We do not process or store full Primary Account Numbers (PANs). All card and fiat transactions are routed via PCI-DSS compliant non-custodial processors (e.g., MoonPay Commerce). We retain only billing identifiers, transaction IDs, and reference tokens for anti-fraud and accounting purposes.
Cryptocurrency Transactions: Wallet addresses and TXIDs used for subscription payments via sovereign gateways (BTCPay Server, Bitcart) or card-to-crypto protocols (MoonPay Commerce) are stored on our ledgers exclusively for payment reconciliation.

3.3 Technical and Telemetry Data

Infrastructure Logs: IP addresses, User-Agent strings, TLS session IDs, and request timestamps are retained in volatile memory for strict security purposes (DDoS mitigation and API abuse detection), after which they are automatically expunged or anonymized.
Generation Metadata: The text prompts, negative prompts, seed numbers, and configuration weights submitted to the inference nodes.

Under the GDPR, we rely on the following legal bases to process your personal data:

Performance of a Contract (Art. 6(1)(b)): Processing Identity and Financial Data to provide the Services, manage your subscription, and execute AI generation requests.
Legal Obligation (Art. 6(1)(c)): Processing Age Verification Data to comply with statutory requirements preventing minors from accessing explicit content, as well as accounting and tax obligations.
Legitimate Interests (Art. 6(1)(f)): Processing Technical Data to ensure network security, prevent fraud, and optimize our GPU cluster routing, provided these interests do not override your fundamental rights.
Consent (Art. 6(1)(a)): For non-essential tracking cookies or explicit opt-in data contributions.

5. Machine Learning and Data Boundary

We maintain a strict boundary between user data and our foundational model training protocols:

Private Generations: Images generated via the Services using paid Compute Credits, along with their associated prompts, are strictly excluded from any automated machine learning training, fine-tuning, or LoRA extraction pipelines. Your private content remains your own.
Opt-In Contributions: Users may explicitly opt-in to donate specific generated images to our telemetry pool to improve algorithmic safety and anatomical coherence. Such data is permanently anonymized prior to ingestion.

We do not sell, rent, or trade your personal data. Disclosures are strictly limited to the following operational necessities:

Authorized Subprocessors & Core Infrastructure: We engage trusted third-party services to operate the platform. All subprocessors are bound by rigorous Data Processing Agreements (DPAs) compliant with GDPR Article 28. Our core integrations include:
- Supabase: Primary relational database, edge functions, and encrypted object storage for gallery media.
- Cloudflare: Global Content Delivery Network (CDN), DNS routing, and DDoS mitigation.
- Bitcart: Self-custodial processing of USDT payments (TRON network). Payment addresses and transaction reconciliation are handled on our own infrastructure; Bitcart acts purely as processing software with no access to identity data.
- Large Language Models (LLMs): Providers such as xAI (Grok) and OpenAI are utilized for inference and the generation of vector embeddings (memory). Prompts and chat context are transmitted securely for generation but are strictly opted out of external model training.
- Payment Processors: MoonPay Commerce (card payments) and BTCPay Server (sovereign cryptocurrency). We do not store your complete financial data on our servers.
- OAuth Providers: If you choose to authenticate via Discord or Twitter (X), we cache only the necessary tokens and profile metadata (e.g., via discord-cache) required to maintain your session.
- Identity Verification (IDV): Third-party KYC providers used exclusively to enforce age restrictions without retaining permanent biometric data on our servers.
Law Enforcement and Statutory Reporting: We will disclose data if required by a valid EU or member state judicial order. Furthermore, we are legally mandated to report any detected instances of Child Sexual Abuse Material (CSAM) to the relevant European authorities (e.g., Europol) and international bodies (NCMEC), providing all associated user metadata.

7. International Data Transfers

EroGrid's primary inference clusters and databases are located within the European Union (e.g., Frankfurt). In instances where data must be routed through or stored in the United States, we rely on the EU-US Data Privacy Framework (DPF) and the European Commission’s Standard Contractual Clauses (SCCs) to guarantee an equivalent level of protection.

As an EU resident (and extended globally by our policy), you possess comprehensive rights regarding your personal data:

Right to Access: Request a structured JSON export of all personal data and generation metadata associated with your account.
Right to Rectification: Correct inaccurate or incomplete account data.
Right to Erasure ("Right to be Forgotten"): Request the permanent deletion of your account and associated generations. Note: Certain financial records and cryptographic age-verification tokens must be retained by law for tax audits and minor-protection compliance.
Right to Restriction & Objection: Object to processing based on legitimate interests.
Right to Data Portability: Receive your data in a machine-readable format.

To exercise these rights, submit a formal request via your Account Settings dashboard or email dpo@erogrid.com. We respond to all verified requests within 30 calendar days.

9. Data Security

EroGrid implements enterprise-grade, defense-in-depth security architectures:

Data at Rest: All PostgreSQL databases (via Supabase) and object storage buckets are encrypted utilizing AES-256 block-level encryption.
Data in Transit: All traffic over the public internet is encrypted using TLS 1.3 with Perfect Forward Secrecy (PFS).
Access Controls: Internal access to production environments requires multi-factor authentication (MFA) and operates on a principle of least privilege.

10. Data Retention Periods

We apply category-specific retention periods in line with the storage limitation principle (Art. 5.1.e GDPR):

Account and profile data: Retained while the account is active and permanently deleted 30 days after a deletion request (grace window for reversal and outstanding balance compliance).
Financial records (credits, payments, reconciliation): Retained for 10 years per applicable accounting and tax obligations; transaction identifiers are pseudonymized after 24 months.
Generated content (images, chats, memories): Retained while the account is active or shows session activity within the last 90 days; inactive resources follow the Retention Policy in the Terms of Service (§8).
Age verification tokens: Retained only as long as necessary to evidence compliance with legal age-protection obligations and purged once those obligations expire.
Technical and security logs: Retained for a maximum of 90 days in abuse-mitigation systems, after which they are purged or anonymized.
Product telemetry (analytics): Analytics events are collected without cookies, without device storage and without IP addresses, with persistence limited to the browser session, and are aggregated or deleted after 12 months.

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