This Privacy Policy explains how 21st Q Ltd. ("Wisp," "we," "us," or "our") collects, uses, stores, and shares your personal information. By using the Wisp application ("App") and related services ("Service"), you agree to the practices described below. If you disagree with any part of this Policy, you must immediately cease use of the Service.

1. Information We Collect

1.1 Information You Provide

We collect information you supply when creating an account, including your name, email, credentials, profile data, messages, and in-app character metadata.

1.2 Creator Identity Verification Data (Sensitive Information)

If you create photorealistic NSFW characters, we require the following to prevent Non-Consensual Intimate Imagery (NCII):

• Legal Documentation: A high-resolution photo of your government-issued ID.
• Verification Selfie: A real-time photo of your face holding that same ID for manual biometric matching.
• Full Legal Name: As displayed on your government identification.

1.3 Biometric Information Consent

By submitting a verification selfie, you provide express, affirmative consent for 21st Q Ltd. to perform a manual biometric comparison to confirm your identity and age. This data is used solely for safety and fraud prevention and is not sold to third parties.

1.4 Information Collected Automatically

We log device characteristics (OS, model), IP addresses, and coarse location to detect unauthorized access and comply with regional age-gating laws.

2. How We Use Your Information

2.1 Service Provision & Payouts

We use your data to deliver AI content and facilitate the 50/50 revenue split for creators, including processing tax documentation where required.

2.2 Manual Review & Safety

Your ID media is used for a manual verification process. We review your documents to ensure you are only generating explicit content using your own likeness or AI-generated characters.

2.3 Compliance with Nevada Deepfake Laws

We process your data to comply with Nevada SB 213 and other statutes prohibiting the creation of non-consensual digital replicas.

3. Data Storage & Security

3.1 High-Security Encryption

All sensitive verification media (IDs and selfies) is stored in Convex encrypted storage. Access is strictly limited to authorized 21st Q Ltd. administrators via secure, role-based access controls.

3.2 No Fallibility Guarantee

While we employ industry-standard organizational and technical safeguards, no system is infallible; we cannot guarantee absolute security but maintain rigorous incident response playbooks for 2026 compliance.

4. Data Retention & Deletion

4.1 Biometric Retention Schedule

In accordance with storage minimization principles, we retain identity verification media only for the duration of your account's existence to verify ongoing compliance.

4.2 Permanent Disposal

Upon account termination or a verified deletion request, all biometric identifiers and ID photos will be permanently purged from our servers within thirty (30) days, unless retention is legally mandated for law enforcement purposes.

5. Your Rights & Choices

Depending on your jurisdiction (e.g., GDPR, CCPA, or Nevada Privacy Laws), you may have the right to:

• Access or Port your data.
• Request Deletion of your personal information.
• Opt-Out of automated profiling for significant decisions.

To exercise these rights, email info@getwisp.app.

6. Children's Privacy (18+ Only)

The Service is strictly for users eighteen (18) years of age or older. We do not knowingly collect information from minors. If we learn that a minor has bypassed our verification, we will delete their data immediately and terminate the account without notice.

7. Changes to This Policy

Material changes will be announced via in-app notice or email at least thirty (30) days before taking effect. Continued use after the effective date signifies your acceptance.

8. Contact Us

For questions regarding your privacy, contact: