Privacy Policy - My Perfect Date

1.1. When you play the virtual reality (VR), mixed reality (MR), augmented reality (AR), extended reality (XR), desktop, mobile, web, demo, prototype, test or other games and related online services that we develop, co-develop, publish, distribute, market, operate, test, support and/or otherwise make available as a VR game publisher and development studio (“Game(s)”), including through Meta Quest / Meta Horizon Store, Steam / SteamVR, PlayStation / PS VR2, PICO, Apple Vision Pro / visionOS, Viveport, SideQuest, Apple App Store, Google Play Store and other app stores or platforms, or visit or use our website https://hypervr.games/ (“Website”), we may collect certain information about you that can either directly or indirectly identify you (“Personal Data”).

1.2. Please be aware that SIA “Hyper Reality” is both a VR game publisher and a VR game developer, and SIA “Hyper Reality” is the owner of the HyperVR Games brand. Some of our Games are developed together with our partner developers, and some of our Games may be published, distributed, monetized, promoted, hosted, supported or operated in collaboration with partner publishers, co-publishers, platform providers, app stores or other partners. Depending on the relevant commercial and technical arrangements, SIA “Hyper Reality” / HyperVR Games may act as an independent controller, joint controller, processor/service provider, publisher, co-publisher, developer, co-developer, data recipient or technical service provider.

Such third parties are responsible for their own processing practices where they act as independent controllers. In particular, a partner publisher, co-publisher or platform provider may control app-store listings, platform accounts, entitlement checks, in-app purchases, advertising/monetization SDKs, user acquisition, consent management, customer support, payment reporting, platform disclosures, multiplayer or social features and other platform or publishing-related processing for a Game.

For the avoidance of doubt, this Privacy Policy covers Personal Data processing for which SIA “Hyper Reality” / HyperVR Games determines the purposes and means, or which is carried out by us in connection with our game development, co-development, publishing, distribution, testing, analytics, support, business and Website activities. Any processing carried out independently by partner publishers, partner developers, app stores, platform providers, advertising networks, analytics providers, payment providers, social networks or other third parties is governed by their own privacy policies, terms, notices and consent tools. Where a partner publisher, co-publisher, platform store page, in-game notice or platform privacy disclosure contains more specific information about a Game, that policy or notice may provide additional or primary information about the processing controlled by that publisher, platform or third party.

1.3. Our Website may include links to third-party websites, applications, platform stores, communities, social media pages, payment pages, support tools, marketing pages and other services that are independently operated and provided by third parties. Each of these third-party providers maintains its own privacy policies, cookie policies, and terms and conditions. We strongly encourage you to review these policies before interacting with their services. We are not responsible for any personal data processing carried out by third-party providers via their websites, applications, platforms, communities or services.

Third-party services operate under their own privacy policies. We encourage users to review those policies before interacting with such services.

1.4.1. Individuals who install, access, test or play our Games, demos, prototypes, playtests, online features or platform features, to the extent the relevant processing is controlled by SIA “Hyper Reality” / HyperVR Games or carried out in connection with our development, co-development, publishing, testing, analytics, support or business activities;

1.4.2. Visitors to our Website and related pages, including, but not limited to, users consuming website content and applicants submitting their information through the Website;

1.4.3. Partner publishers, co-publishers, partner developers, studios, contractors, suppliers, business partners and their representatives who contact us, send project materials, cooperate with us, or otherwise interact with us in relation to VR/MR/AR/XR game development, publishing, distribution, testing, analytics, monetization, marketing, recruitment or other business purposes;

1.4.4. Users who interact with us through Meta, Steam, PlayStation, PICO, Apple, Viveport, SideQuest, Discord, Reddit, TikTok, YouTube, X, Facebook, Instagram or other platforms;

1.4.5. Job applicants, playtesters and other individuals whose Personal Data we collect and process in accordance with this Privacy Policy.

Unless explicitly stated otherwise, all references and provisions in this Privacy Policy apply to all of the above categories of data subjects.

The controller of your Personal Data who determines purposes and means of the processing is SIA “Hyper Reality”, registered in the Register of Legal Entities of the Republic of Latvia under Registration Number 40203309134, legal address: Dzirnavu street 41-11, Riga, LV-1010, Latvia (“Hyper Reality”, “HyperVR Games”, “we”, “us”, “our”, etc.). SIA “Hyper Reality” is the owner of the HyperVR Games brand.

For game support and general deletion support and for data inquiries, privacy requests and data deletion requests, you may contact: support@hypervr.games.

1.6.2. automatically, through electronic means, including cookies and similar technologies on the Website, game software, software development kits (“SDKs”), device identifiers, headset identifiers, platform identifiers, advertising identifiers, app instance identifiers, server logs, crash logs, analytics events, diagnostics, entitlement checks, purchase validation events, controller or headset events and similar technologies while you play our Games or use our Website.

Additionally, if you contact us via social media or community platforms, we may collect information about you that is publicly available or provided through such platforms.

1.6.3. from third parties, including platform providers, app stores, partner publishers, co-publishers, partner developers, advertising networks, attribution partners, analytics providers, payment and purchase validation providers, anti-fraud providers, multiplayer providers, community platforms, social networks, contractors and other service providers, to the extent permitted by applicable law, the relevant contracts and your privacy choices.

1.7. This Privacy Policy may be subject to periodic revisions and updates. Whenever modifications are made to this Privacy Policy, we will always keep the last version of our Privacy Policy on our Website.

If we introduce significant changes that require your explicit consent for the continued processing of your Personal Data, we will request your consent or renewed consent (if previously obtained).

1.8. Our processing may involve users located outside the European Union, and Personal Data may be transferred to countries outside the European Economic Area, the United Kingdom or Switzerland. Where such transfers occur, we rely on adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum or other lawful safeguards, and we assess whether supplementary technical and organizational measures are required.

1.9. As a VR game publisher and developer, we may be responsible for providing or updating privacy disclosures in Meta Quest / Meta Horizon Store, Steamworks / Steam, PlayStation, PICO, Apple App Store / Apple Vision Pro, Viveport, SideQuest, Google Play Console and other app-store or platform systems for Games published through our accounts. We may also assist partner publishers or co-publishers with privacy information needed for their platform submissions, including privacy labels, data safety disclosures, SDK disclosures, headset permissions, platform permissions and similar platform requirements. Where a Game is published through a partner publisher or co-publisher account, that partner may be responsible for submitting, maintaining and updating the relevant app-store or platform disclosures, and we may provide technical information about SDKs, game events, VR/MR/AR/XR permissions and data flows to support accuracy.

1.10. This Privacy Policy should be read together with our Cookies Policy, Terms of Use, game-specific notices, partner publisher privacy policies, app-store privacy disclosures, in-game consent notices, headset and device permission prompts, platform permission prompts and the privacy settings available on your device, headset or in the relevant Game.

1.11. We may update this Privacy Policy from time to time to reflect changes in our Games, Website, technologies, platforms, SDKs, legal obligations, business model or privacy practices. The latest version will be made available on our Website or through the relevant Game, store page or platform notice. If we make material changes that require consent or additional notice under applicable law, we will provide such notice or request consent as required.

If you do not agree with this Privacy Policy, you should not install, access, play, test or continue using our Games, Website or related services.

2. Which Personal Data do we collect and process

2.1. We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing. Categories of Personal Data that we process are specified below.

The specific categories of Personal Data collected may vary by Game, country, platform, headset, device, app-store requirements, platform permissions, publisher requirements, SDK configuration, user device settings, consent status and the features that you choose to use. Not all categories listed below are collected in every Game. In Games published or operated with partner publishers, co-publishers or platforms, such third parties may collect or control additional categories of Personal Data described in their own privacy policies, platform disclosures or game-specific notices.

2.2.1. Personal Data of Game users
2.2.1.1. Reason - to check the quality of Game content
Purpose of the processing	In order to check and improve the quality of Games content we need to collect data about: Progress of passing the Games by users (are there any stages that are too difficult); Are ads displayed and are ads working properly with Games content; Frames per second (FPS) and performance of the Games across different devices, headsets, controllers and platforms; How many users keep playing the Games for a long time; How long users play Games; Games testing, playtests, prototypes and build validation.
Type of Personal Data	Game data: Game name; Game configuration version; Session ID; Event ID; Game event type (e.g., “install”, “level_completed”, “show_ad”); Event context (arbitrary key/value pairs for in-Game event data, soft/hard currency, placement, level, scene, mode, difficulty, item, VR comfort setting or other feature context); FPS Game information, loading time, latency, frame drops and performance information; Event time; Install time. Device and platform data: Device, headset or controller model; OS name, firmware, platform and store; Unity device ID=device ID or similar engine/app identifier; Advertiser ID (GAID/IDFA), device IDFA or other advertising identifier where available and permitted; Attribution network device ID - external device ID (such as Adjust ID or AppsFlyer ID, where used).
Legal ground for the processing	The legal basis for processing is our legitimate interest in analyzing gameplay data to improve game quality and user experience, while ensuring that your privacy rights are not overridden. Consent applies where required by applicable law, platform rules or SDK configuration.
2.2.1.2. Reason - Identification of problems in the Games
Purpose of the processing	In order to identify problems in the Games and fix them we need to collect data about: Game freeze/suspension; Inability to load the Game; Problems while passing the Game; Checking the display and operation of ads in the application; VR comfort, headset compatibility, controller tracking, multiplayer, cloud-save, purchase delivery, entitlement or platform permission issues; Errors, warnings and diagnostics.
Type of Personal Data	Game data: Game name; Game configuration version; Session ID; Event ID; Game event type; Event context and Game state at the time of the problem; FPS Game information, crash reports, diagnostics, stack traces, loading time, memory usage, network status and platform status; Event time; Install time. Device data: Device, headset and controller name; OS name, firmware, app version, SDK version and graphics settings; Unity device ID=device ID; Advertiser ID (GAID/IDFA), device IDFA or platform identifier where available and permitted; Attribution network device ID - external device ID.
Legal ground for the processing	The legitimate interest based on the balance of interests: - Our interest is in identifying and resolving technical issues to improve the quality, compatibility, safety and stability of the Games; - This processing is necessary for maintaining and enhancing the Games and does not override your privacy rights. Performance of contract may also apply where processing is necessary to provide a working Game or requested support.
2.2.1.3. Reason - Financial analysis
Purpose of the processing	In order to analyze financial information, we need to collect data about: How many ads are viewed by users; What income does the Game bring (viewing ads, purchases, subscriptions, downloadable content or platform revenue); User acquisition costs; Partner publisher, platform and store reporting.
Type of Personal Data	Advertisement data: Ads type (e.g., interstitial / banner / rewarded / platform ad format); Advertisement placement name; Impressions count; Revenue figures; Specific and custom data depending on the event, Game, platform and user. The type of data which is collected is acquisition, monetization and advertisement data as well as purchase, entitlement and revenue data. Attribution data: Source (ad network identifier); Campaign name; Creatives name; source_app_id (adgroup ID - attribution manager data); tracker token (token ID - attribution manager data). Device data: device or headset name; OS name; Unity device ID=device ID; advertiser ID (GAID/IDFA), device IDFA or platform advertising ID where available and permitted; attribution network device ID - external device ID.
Legal ground for the processing	The legitimate interest is based on the balance of interests: - Our interest is in analyzing the financial performance of the Games and the effectiveness of advertising, monetization, platform and publishing activities, which is necessary for operating and improving our business; - This processing is carried out only to the extent necessary and does not override your privacy rights.
2.2.1.4. Reason - Marketing analysis
Purpose of the processing	We group users by number / countries / by activity in order to determine the audience for the acquisition of users and monetization, measure marketing performance, evaluate campaign effectiveness and improve promotional activities.
Type of Personal Data	Attribution data: Source (ad network identifier); Campaign name; Creatives name; Revenue figures; source_app_id (adgroup ID - attribution manager data); tracker token (token ID - attribution manager data). GeoIP: IP; country; ASN name. Game data: Game name; Game configuration version; Session ID; Event ID; Game event type; Event context; FPS Game information; Event time; Install time. Device data: device or headset name; OS name; Unity device ID=device ID; advertiser ID (GAID/IDFA), device IDFA or platform advertising ID where available and permitted; attribution network device ID - external device ID.
Legal ground for the processing	The legitimate interest based on the balance of interests: - Our interest is in analyzing aggregated user activity and marketing performance to improve user acquisition and monetization strategies; - This processing is limited to what is necessary for these purposes and does not override your privacy rights. or (when applicable) Consent (for personalized advertising and user-level marketing profiling).
2.2.1.5. Reason - VR, MR, AR, XR and headset features
Purpose of the processing	To enable VR/MR/AR/XR gameplay, controller tracking, hand tracking, headset movement, comfort settings, guardian/boundary awareness, mixed reality interactions, platform permissions, passthrough or similar immersive features that may be offered by a Game or platform.
Type of Personal Data	VR/MR/AR/XR data: headset position, orientation, controller input, controller position, hand interaction, gesture or movement events generated by the Game; height, play area, comfort settings, handedness, locomotion settings, boundary or guardian status, and similar gameplay configuration data; spatial anchor, scene understanding, room setup, passthrough, microphone, camera, eye-tracking, face-tracking or hand-tracking permission status where a platform makes such permission data available to the Game; voice-chat or microphone data where a Game includes voice features. Voice data is typically processed in real time and is not stored by us unless storage is necessary for moderation, support, safety, abuse-prevention, legal compliance or another purpose described in a game-specific notice; information about whether a privacy-sensitive permission is enabled, denied or changed in platform settings.
Legal ground for the processing	Performance of contract where processing is needed to provide the VR/MR/AR/XR feature you use. Consent where required for privacy-sensitive headset permissions, microphone, recording, cookies, similar technologies or tracking. Legitimate interest in operating, securing and improving the feature where allowed by law. Legal obligation or vital interest may apply where processing is strictly necessary for safety, abuse prevention or legal compliance. We do not intentionally collect raw eye-tracking data, raw facial-expression data, raw room scans, raw passthrough camera feeds, biometric templates or health data unless a specific Game feature clearly requires such data, the platform permits it, and the processing is separately disclosed and lawful. Where platforms process these signals on-device and do not share raw data with us, we only receive the limited data made available by the platform or generated by the Game.
2.2.1.6. Reason - To provide, operate, test and secure the Games
Purpose of the processing	To provide access to the Games, operate core gameplay features, maintain sessions, authenticate app instances, verify entitlements, test builds, apply country or platform settings, support partner publisher or platform operations where applicable, prevent misuse and keep the Games secure.
Type of Personal Data	Operational and security data: internal player ID, app instance ID, installation ID and session identifiers; device, headset or controller model, OS, firmware, app version, build number, language and country/region; IP address and server logs; crash, performance, diagnostics and error logs; build, testing, QA, gameplay and level-progress events; security, abuse, bot, invalid-traffic, anti-cheat or anti-fraud indicators; entitlement, subscription, store receipt, platform account or purchase validation status where provided by the platform.
Legal ground for the processing	Performance of contract where processing is necessary to provide the Game or requested features. Legitimate interests in developing, operating, securing, testing, troubleshooting and improving the Games, provided your rights and freedoms are not overridden. Legal obligation where applicable. Where we process Personal Data on behalf of a partner publisher, co-publisher or another controller, that party determines the relevant legal basis.
2.2.1.7. Reason - Advertising, attribution, user acquisition, monetization and campaign measurement
Purpose of the processing	To display contextual or, where permitted, personalized advertisements; measure advertising performance; attribute installs and conversions; analyse user acquisition and monetization; apply frequency capping; prevent advertising fraud and invalid traffic; promote our Games; and respect consent, opt-out and platform privacy signals. In Games published, co-published or operated by partner publishers or platforms, the partner may configure or control some or all advertising, attribution and monetization SDKs.
Type of Personal Data	Advertising, monetization and attribution data: IDFA, GAID, AAID, platform advertising IDs or other advertising identifiers where available and permitted; IDFV, app instance ID, install ID, attribution partner IDs and tracker tokens; IP address, coarse location and device/headset/OS/platform information; game/app name, install time and event timestamps; ad impressions, ad clicks, ad placements, conversion events and revenue information; campaign, source, ad network, ad group, creative ID and attribution data; consent status, consent string, privacy preferences, Global Privacy Control signal, Do Not Sell or Share preference and opt-out signals. We do not intentionally use this data to create sensitive profiles and we do not use data of known children for personalized advertising.
Legal ground for the processing	Consent where required for personalized advertising, tracking, access to advertising identifiers, cookies, SDKs or similar technologies. Legitimate interest may apply to contextual advertising, aggregated measurement, fraud prevention and campaign performance analysis where allowed by law and where your rights are not overridden. Where a partner publisher, co-publisher, platform or advertising partner controls advertising or monetization, that party is responsible for the applicable legal basis and notices.
2.2.1.8. Reason - In-app purchases, subscriptions, revenue reporting and payment verification
Purpose of the processing	To verify and deliver purchases, subscriptions, virtual currency, downloadable content, unlocks or other in-game items; analyse revenue; process refunds; maintain accounting records; support partner publisher, co-publisher or platform reporting; perform entitlement checks; and prevent refund abuse.
Type of Personal Data	Purchase and revenue data: app store, platform or store transaction ID; product ID and SKU; price and currency; purchase, subscription, renewal or refund time; receipt, entitlement or validation status; country/region; limited device, app, platform and player ID data; publisher, co-publisher, platform revenue reports or aggregated monetization reports. We do not receive your payment card or bank account details from Meta, Steam, PlayStation, Apple, PICO, Viveport, SideQuest, Google Play or other app stores, platforms or payment providers.
Legal ground for the processing	Performance of contract; compliance with legal obligations; legitimate interest in accounting, fraud prevention, refund handling, revenue analysis, partner reporting and dispute management.
2.2.1.9. Reason - Multiplayer, social, community and user-generated content features
Purpose of the processing	To provide multiplayer sessions, lobbies, matchmaking, leaderboards, achievements, friend or party features, social interactions, user-generated content, voice chat, text chat, moderation, reporting, anti-abuse, code-of-conduct enforcement and community support where such features are available.
Type of Personal Data	Multiplayer and community data: platform user ID, display name, username, avatar, friend/party/lobby identifiers and multiplayer session identifiers; leaderboard score, achievements, match result, session history and interaction data; text chat, voice chat, reports, moderation records, user-generated content, screenshots, recordings, comments and other content that you submit or make available; abuse-prevention, safety, trust, moderation, block, mute, report and ban information; Discord, social media or community profile information if you interact with us through those services.
Legal ground for the processing	Performance of contract where processing is necessary to provide the multiplayer, social or community feature. Legitimate interest in community management, moderation, user safety, abuse prevention, service integrity and enforcing our rules. Consent where required by law or platform rules. Legal obligation where applicable.
2.2.1.10. Reason - Customer support, bug reports, privacy requests and communications with Game users
Purpose of the processing	To respond to support requests, deletion requests, privacy requests, gameplay or technical issues, bug reports, refund-related questions, restore progress where available, communicate service-related information and coordinate support with partner publishers, co-publishers, platforms or developers where applicable.
Type of Personal Data	Contact data and support content: email address, name, username, platform ID, order or transaction ID if you provide it; player ID, game, device, headset, platform and app version information; screenshots, attachments, crash details, video clips, logs or other information that you provide; conversation history and support ticket metadata; information shared with or received from a partner publisher, co-publisher, platform support team or partner developer where the Game is published, operated or supported with that party.
Legal ground for the processing	Performance of contract or legitimate interest in responding to requests, supporting users, fixing Games, protecting privacy and protecting the Games; consent where required for optional communications; legal obligation where we must respond to privacy requests or retain records.
2.2.1.11. Reason - Compliance, fraud prevention, safety and enforcement
Purpose of the processing	To comply with legal obligations, enforce terms and policies, protect users and third parties, detect or prevent fraud, abuse, cheating, bots, invalid traffic, security incidents or illegal activity, establish, exercise or defend legal claims, and cooperate with competent authorities where legally required.
Type of Personal Data	Compliance and enforcement data: device, headset, app, player, platform, advertising and transaction identifiers; IP address, timestamps, server logs and security logs; purchase/refund history and fraud indicators; communications and evidence submitted by you, partner publishers, platforms or third parties; moderation, reporting, ban, safety or abuse-prevention records; information requested by competent authorities where legally required.
Legal ground for the processing	Legal obligation where applicable; legitimate interests in protecting our Games, users, rights, property and business operations; establishment, exercise or defence of legal claims.
2.2.2. Personal Data of Website or social media users
Reason - To consider and reply to incoming queries
Purpose of the processing	You may contact us via social media or email indicated on our Website or directly through our Website. We will process Personal Data you provide to give feedback (including but not limited to evaluate candidates for the vacant position for the purposes of entering into contractual relations with the successful candidate in accordance with the applicable laws and regulations; to communicate with you regarding job interviews, test assignments and other recruitment related matters; to review and evaluate your eligibility and suitability for the position under consideration). This also includes requests from partner publishers, co-publishers, partner developers, studios, contractors, suppliers, job applicants or other business partners who submit game/project materials, technical information, platform or app-store links, portfolio information, cooperation requests, recruitment information or other business communications.
Type of Personal Data	Email; Personal information from the social media via which you contacted us; Full name and surname; Phone number; Relevant CV entries; Other data that you provide in your query. Additional business-contact and cooperation data may include company/studio name, role/title, business email, messenger/social profile, country, game/project name, build or gameplay video link, app-store link, pitch deck, technical documentation, monetization or analytics information, marketing materials, communication history and any other information voluntarily provided in the submission.
Legal ground for the processing	The processing is based on our legitimate interest in managing incoming inquiries and providing timely communication. This processing is necessary to handle your request and does not override your privacy rights. Where the inquiry relates to a potential development, co-development, publishing, testing, marketing, monetization, analytics or other business cooperation, processing may also be based on taking steps prior to entering into a contract at your request and on our legitimate interest in evaluating, managing and documenting business opportunities.

2.3. Additional VR/MR/AR/XR Game Development, Publishing and Platform Information

Depending on the Game, the publisher, co-publisher, platform and SDKs integrated in that Game, we may also process internal player ID, app instance ID, installation ID, app version, build number, platform account or entitlement information provided by app stores or partner publishers, purchase verification data, refund or chargeback signals, consent status, age or region flags, device or headset privacy settings, push-notification token, anti-fraud or abuse signals, diagnostics, crash and performance logs, playtest data and information necessary to comply with app-store, VR platform, advertising network, publisher, developer account and legal requirements.

We make reasonable efforts to ensure that the data practices described in this Privacy Policy are consistent with the technical information we provide for Meta Quest / Meta Horizon Store, Steam / SteamVR, PlayStation / PS VR2, PICO, Apple Vision Pro / visionOS, Viveport, SideQuest, Apple App Store, Google Play Data Safety information and similar platform disclosures. In Games published, co-published or operated through partner publisher accounts, the relevant publisher may be responsible for public privacy disclosures, in-game consent tools and store-listing information. Such platform or publisher disclosures may summarise complex practices and may vary by Game, platform, region, headset, permissions and SDK configuration.

We do not intentionally collect precise GPS location, health data, government identifiers, payment card numbers, bank account details, biometric templates or data for the purpose of uniquely identifying a person by biometric means through our Games or Website, unless a specific Game feature clearly requires such data, the processing is separately disclosed, and a valid legal basis exists. VR, MR and AR data can be sensitive because it may relate to movement, environment, voice, gestures or other immersive interactions. We therefore seek to minimize this data, process it only for the relevant feature or purpose, and rely on platform permission prompts, in-game notices, technical safeguards and user controls where appropriate.

We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you. We may use profiling for aggregated analytics, segmentation, fraud prevention, advertising measurement, game balancing, quality assurance, monetization analysis and personalized advertising where permitted by law and your privacy choices. You may object to or opt out of such processing where applicable.

We may collect your Personal Data by automated means, such as cookies (strictly necessary, analytical, marketing and social media cookies), web beacons and web server logs when you visit our Website. In our Games, similar technologies may include SDKs, pixels, local storage, device identifiers, platform identifiers, advertising identifiers, headset identifiers and app-instance identifiers, as described in this Privacy Policy and in our Cookies Policy.

If you need to review detailed information about Cookies and similar technology and if you need detailed information regarding how we collect and use cookies, please refer to our Cookies Policy, which is available here: https://hypervr.games/cookies/.

3. Term of Personal Data Processing and Place of Storage

We retain your Personal Data only as long as necessary to fulfil the purposes described in the section “Which Personal Data do we collect and process.” Once the retention period has expired, we will securely delete, anonymize or aggregate your Personal Data.

We determine the retention period based on the last recorded activity or interaction, as applicable to the type of data.

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including compliance with legal obligations, resolving disputes, enforcing agreements, preventing fraud, responding to privacy requests and protecting our legal rights.

“Last activity” is defined as the last time you accessed or used the relevant Game, Website or service. “Last interaction” is defined as the date of your most recent message, form submission or other communication with us. Aggregated or anonymised information that no longer reasonably identifies you may be retained and used for analytics, product, business and reporting purposes without a fixed period.

Your Personal Data may be stored and processed in the European Economic Area and in other countries where we, our group companies, partner publishers, partner developers, service providers, platform providers or infrastructure providers operate. Any transfer of Personal Data outside the EU is protected by Standard Contractual Clauses or other GDPR-compliant safeguards. To protect your Personal Data, we implement comprehensive technical and organizational measures, including:

We process your Personal Data based on one or more of the following GDPR-compliant legal grounds:

You have the right to access, correct, erase, restrict, object to the processing of your Personal Data, and request data portability. You also have the right to object to processing based on legitimate interests. For more information, see the section “Your Rights” or contact us at data@hypervr.games or support@hypervr.games. You can manage your privacy preferences through in-game settings, device settings, headset/platform settings, Website cookie settings or by contacting us directly.

4. Third Parties and Your Personal Data

This sharing is strictly for the purposes described in the section “Which Personal Data do we collect and process” and only with the third parties described below.

You have the right to withdraw consent at any time for processing based on consent.

For the avoidance of doubt, sharing identifiers or SDK event data with advertising partners for cross-context behavioral advertising may be considered “sharing” or “sale” under certain U.S. state privacy laws even if no money is exchanged. Where required, we will provide an opt-out mechanism and honor applicable privacy signals.

Our service is global by nature and your data can therefore be transferred to anywhere in the world (some third-party companies or their group members may be located outside the European Union (EU), including in countries that may not provide an adequate level of data protection). Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Third-party services operate under their own privacy policies. We encourage users to review those policies before interacting with such services.

If you wish to review the relevant SCCs or agreements, you may contact us using the methods in the “Contact Us” section.

Third-party services operate under their own privacy policies. We encourage users to review those policies before interacting with such services. Some providers may act as processors/service providers, while others may act as independent controllers or joint controllers depending on the technology and the purposes for which they process data. We aim to use contractual safeguards, data processing agreements, SCCs, publisher terms, platform terms and SDK configurations to limit processing to the disclosed purposes. In Games published, co-published or operated with partner publishers, co-publishers or platforms, such parties may separately select, configure and control certain providers.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Meta Quest / Meta Platforms / Meta Horizon Store	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Platform accounts, app store, entitlements, purchases, achievements, platform analytics, permissions, social features, headset settings and store disclosures.
Valve / Steam / Steamworks / SteamVR	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Steam store, SteamVR, purchases, cloud saves, achievements, platform IDs, multiplayer and platform services.
Sony Interactive Entertainment / PlayStation / PS VR2	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	PlayStation Store, purchases, platform accounts, achievements, multiplayer and platform services.
PICO, Apple App Store / Apple Vision Pro / visionOS, Viveport, SideQuest and other platform providers	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Platform accounts, stores, purchases, entitlements, permissions and platform services.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Google Firebase / Google Analytics	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Checking the quality of Games content, diagnostics, analytics, reporting and understanding the effectiveness of our services.
GameAnalytics	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Checking and improving the quality of Games content, progression, retention, playtime, session events and product metrics.
Unity Analytics / Unity Gaming Services / Meta developer tools / Steamworks reports / PlayFab or similar services	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Product metrics, telemetry, platform reporting, backend reporting and game improvement.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Google Firebase Crashlytics	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Identification of problems in the Games, crash reports, diagnostics and error analysis.
GameAnalytics	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Identification of problems in the Games and product diagnostics.
Unity Cloud Diagnostics / Sentry / Backtrace / platform crash reporting or similar services	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Crash reports, diagnostics, logs, performance and error analysis.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Meta, Google Ads / AdMob, TikTok, Unity Ads, AppLovin, ironSource, Mintegral, Chartboost, Adjust, AppsFlyer, Moloco and similar services	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Advertising, attribution, campaign measurement, install tracking, conversion tracking, monetization analytics, ad mediation and fraud prevention, where used and where permitted by law and platform rules.
Platform advertising or store promotional tools	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Promotion, store listing performance, campaign measurement and platform advertising where available.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Google Cloud, AWS, Microsoft Azure, PlayFab, Photon, Epic Online Services, Unity Gaming Services, Steamworks, Meta Platform Services, PlayStation Network, Game Center, Discord integrations or similar services	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Hosting, matchmaking, leaderboards, cloud saves, multiplayer sessions, server logs, authentication and online features.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Email, ticketing, support, social media and community providers such as Discord, Meta, Steam forums, PlayStation community features, YouTube, TikTok, X, Facebook, Instagram, Zendesk, Freshdesk or similar services	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Support, communications, moderation, community management, social media interactions and user inquiries.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Meta Quest Store, Steam, PlayStation Store, Apple App Store, PICO Store, Viveport, SideQuest and other platform stores or payment processors	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Payment processing, purchases, refunds, entitlements, tax and purchase validation. We generally receive limited purchase metadata, not full payment card or bank details.

4.4.8. Our partner publishers, co-publishers, partner developers and studios

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Partner publishers, co-publishers, partner developers, contractors, studios and suppliers	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	Relevant Game, analytics, QA, build, crash, marketing, monetization, support or business data only for the Games or projects for which they are engaged and only to the extent necessary.

4.4.9. Law enforcement agencies, public authorities or other judicial bodies and organisations.

Provider / Category	Its privacy policy, terms and SCC (if applicable)	Purposes of transfer / processing
Authorities, courts, regulators, professional advisers and corporate transaction parties	Relevant provider privacy policy, platform terms, service terms, SDK documentation, data processing terms and/or SCC / transfer terms, where applicable.	We may disclose information if legally required, to comply with valid legal processes, enforce terms and policies, detect or prevent fraud or technical issues, protect rights and safety, obtain legal/accounting advice, or in connection with a merger, acquisition, financing, reorganization or sale of assets.

4.5. Third persons that may process your personal data independently from us:

4.5.1. Other third persons may process your personal data with regard to your use of the Games as independent controllers of your personal data when you make in-app purchases, use platform accounts, save your game progress, use multiplayer or social features, interact with communities or access platform services via such third persons. We cannot control how these independent controllers process your personal data. Please consult their privacy policies for more information.

4.5.2. When you make payments related to the Game(s), you submit your payment details to the relevant app store or platform store (Meta Quest Store, Steam, PlayStation Store, Apple App Store, PICO Store, Viveport, SideQuest, Google Play Store or other stores) that processes your payments. We only receive a limited amount of information from such third person, such as product ID, price and currency, purchase time, transaction ID, entitlement status or receipt validation information. We do not receive your payment card or bank details.

4.5.3. When you use cloud save, achievements, platform social features, platform accounts, Game Center, Play Games, Steam Cloud, Meta platform services, PlayStation Network or similar services, the relevant platform provider may process your Game data according to its own privacy policy. You can manage some platform data sharing through the relevant platform settings.

4.5.4. Meta, Valve/Steam, Sony/PlayStation, PICO, Apple, Google, HTC/Viveport, SideQuest and other platform providers may also process device identifiers, headset identifiers, crash logs, purchase data, platform account data, age or region signals, app privacy disclosures and other platform data under their own privacy notices and developer terms. We do not control their independent processing, but we design and support our Games to align with applicable app-store and partner requirements.

4.5.5. Partner publishers or co-publishers may independently process Personal Data for Games that they publish, distribute, monetize, promote, host, support, moderate or operate. This may include platform account management, advertising SDKs, attribution, monetization, user acquisition, customer support, consent management, cloud services, social features, fraud prevention and platform compliance. Please review the privacy policy and in-game notices of the relevant partner publisher or co-publisher for publisher-controlled processing.

4.5.6. The specific advertising networks, attribution providers, mediation providers and analytics SDKs active in a Game may depend on the Game, publisher, country, device, platform, consent status and mediation configuration. Where required, we or the relevant partner publisher use child-directed treatment, limited ad tracking, restricted data processing, non-personalized advertising or similar SDK settings.

5. Your rights under the GDPR

You have the right to obtain information about the Personal Data we hold about you. You can request a copy of the Personal Data we process.

If you consider that any Personal Data we hold about you is inaccurate or incomplete, you have the right to ask us to correct or complete it. Some information may also be corrected directly within our apps or platform settings. Please contact us promptly if you notice any inaccuracies or omissions.

You may request that we delete some or all of your Personal Data from our systems. Please note that deleting the app from your device or headset does not automatically stop our processing if we have a lawful basis for keeping the data.

You have the right to request that we limit the processing of your Personal Data if:

5.1.5. right to data portability (to receive a copy of Personal Data in a commonly used machine-readable format)

You have the right to ask for a copy of your Personal Data in a structured, commonly used and machine-readable format and to request that we transmit the data to another controller where it’s technically possible if our legal basis is your consent or where the processing is necessary for the performance of a contract to which you are a party.

5.1.6. right to object against processing for specific purposes (such as direct marketing) and right to object to automated processing including profiling

You have the right to object to processing of your Personal Data (including direct marketing purposes) which is based on our legitimate interests at any time. We will no longer process Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If the processing of your Personal Data is based on your consent, you can withdraw it at any time. The procedure to exercise this right is described in this Policy.

You have the right to lodge a complaint with a data protection authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

5.2. You may exercise your rights by sending an email to data@hypervr.games or support@hypervr.games or a written notice to our registered office. You may also use our web form, in-app request mechanism, platform privacy tool or game-specific request mechanism where available. We will handle your request as quickly as possible, and no later than one month after receipt. This period may be extended by up to two additional months if necessary due to complexity or number of requests. We will notify you of any extension within one month and explain the reason for the delay.

5.3. If you request deletion of your Personal Data, we may retain it as required to comply with legal obligations or resolve disputes, including for tax, accounting, contractual, platform, safety, moderation or other legally required purposes. We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including compliance with legal obligations, resolving disputes, enforcing agreements, preventing fraud and protecting users.

Changing device, headset, publisher or platform settings may not delete previously collected data; for deletion or access requests, contact us or the relevant partner publisher/platform, depending on who controls the processing.

We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects for you. We may use automated segmentation, analytics, ad measurement, fraud detection, game balancing, QA tools, moderation signals and VR comfort/performance diagnostics to operate, test and improve Games, deliver or measure ads, and prevent misuse. Where required, you may object or withdraw consent.

6. Age limits

6.1. Our Games and Website are not directed to children under 13. Unless a specific Game, app-store age rating, platform age rule, partner publisher notice or game-specific notice provides otherwise, our Games are intended for users who are at least 16 years old or who have the consent or authorisation of a parent or legal guardian where required by applicable law. Certain VR platforms, Games, stores or age-rating systems may apply higher age limits, parental supervision requirements or content restrictions. You must comply with the age rules, parental controls and account requirements of the platform or store through which you access a Game. We do not knowingly collect Personal Data from, target personalized advertisements to, or enable behavioral advertising for children under 13 or under another age threshold required by applicable law. For users we know or believe to be under the applicable age threshold, we may limit data collection, disable personalized advertising, disable or restrict social features, use contextual advertising only, request parental consent, apply publisher or platform age settings, or restrict access to certain features.

6.2. If you are a child, we recommend that you obtain permission from your parents or legal guardian to play our Games or use our Website. You should also read this Privacy Policy with your parents or legal guardian so they can help you understand anything you may not understand. If you are a parent or legal guardian and you believe that your child has provided Personal Data to us without the required consent, or you wish to review, correct or delete your child’s Personal Data, please contact us using the details stated in this Privacy Policy or contact the relevant partner publisher or platform where the processing is controlled by that party.

6.3. We may use age gates, app-store age ratings, country information, platform settings, publisher consent management tools, parental control tools or other reasonable measures to apply age-appropriate privacy protections. The applicable age threshold may vary by country. If we become aware that we have collected Personal Data from a child contrary to applicable law, we will delete or anonymise such Personal Data, restrict the relevant processing, inform the relevant partner publisher or platform where appropriate, or take other appropriate steps.

6.4. We do not knowingly use Personal Data of known children for personalized advertising, cross-context behavioral advertising, profiling for advertising, sale or sharing under U.S. privacy laws, or other purposes prohibited by applicable child privacy laws.

7. Global Users / International Privacy Rights

If you access or use our Games or Website from outside the European Union or European Economic Area, local privacy laws may apply in addition to the GDPR. The rights and obligations described in this Privacy Policy may be supplemented by the laws of your country, including laws relating to consent, targeted advertising, sale or sharing of personal information, children’s privacy, data portability, deletion, correction, appeal rights, data localisation or cross-border transfers.

You can manage your privacy preferences through in-game settings, Website cookie settings, device settings, headset/platform settings, app-store/platform settings, advertising identifier controls or by contacting us directly.

Residents of California and certain other U.S. states may have additional rights under the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) and other applicable U.S. state privacy laws, including the right to:

Users in the United Kingdom and Switzerland may have rights similar to those available under the GDPR, including access, correction, deletion, restriction, objection, portability and complaint rights. Where Personal Data is transferred from the UK or Switzerland to countries without an adequacy decision, we rely on appropriate safeguards such as the UK International Data Transfer Addendum, Standard Contractual Clauses or other lawful mechanisms.

Where applicable, we comply with local privacy frameworks such as the PDPA (Singapore), POPIA (South Africa), Privacy Act (Australia), New Zealand Privacy Act, Japan APPI, South Korea PIPA, China PIPL and similar regional privacy laws. Users in these jurisdictions may exercise local data rights by contacting us or, where the relevant Game is controlled by a partner publisher, platform or co-publisher, by contacting that party through the contact mechanism in its privacy policy or in-game notice.

You may exercise any of the rights described above for your country of residence by contacting us at data@hypervr.games or support@hypervr.games. We will respond to your request in accordance with applicable local laws and may need to verify your identity before acting on your request. If the relevant Personal Data is controlled by a partner publisher, co-publisher, platform or app store, we may direct you to that party or forward your request where appropriate and permitted by law. You can manage your privacy preferences through in-game settings, Website cookie settings, partner publisher privacy tools, device settings, headset/platform settings, app-store/platform settings, advertising identifier controls or by contacting us directly.

8. Contact us

8.1. Should you have any questions regarding the processing of your Personal Data by us, do not hesitate to contact us under the email address: support@hypervr.games or by means of a written notice sent to the address of our registered office: Dzirnavu street 41-11, Riga, LV-1010, Latvia.

8.2. Be also informed that since we are registered under the law of the Republic of Latvia, the personal data authority overseeing us regarding the Personal Data processing is the Data State Inspectorate of Latvia (Datu valsts inspekcija), Elijas iela 17, Riga, LV-1050, Latvia, email: pasts@dvi.gov.lv, phone: +371 67223131, website: www.dvi.gov.lv. In case you have any doubts about how we process your Personal Data, you may contact the personal data authority of the Republic of Latvia anytime.

8.3. When contacting us about this Privacy Policy, please include the Game name, platform, device/platform ID if available, country/region, and a short description of your request so that we can identify the relevant data and respond more efficiently.

SIA “Hyper Reality” / HyperVR Games Privacy Policy

1. WHO COLLECTS AND PROCESS YOUR PERSONAL DATA