PERSONAL DATA PROCESSING INFORMATION
1. GAME
1.1. The company Delta VR Ventures s.r.o., ID No. 19621728, with registered office at Chvalská 718/10, Hloubětín 198 00 Prague 9, Czech Republic registered in the Commercial Register of the Municipal Court in Prague, file No. C 389336, under Czech laws ("Controller", "Company" or “We”) published VR action game Magic Madness, DLC Magic Madness VR Arena Builder or other product published by us („Game“).1.2. To use all features of the Game, you must agree to the End User License Agreement ("EULA") and have a Victoria VR Account ("Account"), which is provided and operated by Victoria VR Group, a.s. The creation and use of the Account is governed by the separate Victoria VR Account Terms and Conditions and the processing of personal data specifically in connection with the Account is described in the Victoria VR Account Privacy Policy.
1.3. The Game is distributed via
1.3.1. the Steam platform operated by Valve Corporation („Steam“),
1.3.2. the Meta Store (including the Meta Quest Store), operated by Meta Platforms Technologies LLC or its affiliates through which the Game is distributed, downloaded and purchased, and is played via the Meta Horizon platform (“Meta”), and
1.3.3. our website https://www.magicmadnessvr.com/ („Website“).
1.3.2. the Meta Store (including the Meta Quest Store), operated by Meta Platforms Technologies LLC or its affiliates through which the Game is distributed, downloaded and purchased, and is played via the Meta Horizon platform (“Meta”), and
1.3.3. our website https://www.magicmadnessvr.com/ („Website“).
2. PROCESSING OF PERSONAL DATA
2.1. If you use / play the Game, the Company becomes the controller of your personal data within the meaning of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("Regulation" OR „GDPR“).2.2. Certain features of the Game, including multiplayer and social gameplay modes, involve interaction between players and the processing and sharing of the data described below.
2.3. The Game uses a unified player account that may be accessed across different platforms. Your Game progress, virtual items, and entitlements may therefore be available regardless of the platform you use to access the Game.
3. Data we collect
3.1. We may collect and process the following categories of personal data:3.2. Account and Identity Data
3.2.1. Your name, surname, public display name, date of birth, gender, language preferences,
3.2.2. Your nickname used within the Game,
3.2.3. Account identifiers and authentication information made available to the Game as necessary to authenticate your Account.
3.2.4. Location and time zone settings.
3.3. Purposes: account authentication; age-gating; localization and UI language; determination of your Feng Shui element, security and fraud prevention; customer support; compliance (e.g., tax).3.2.2. Your nickname used within the Game,
3.2.3. Account identifiers and authentication information made available to the Game as necessary to authenticate your Account.
3.2.4. Location and time zone settings.
3.4. Legal basis: Art. 6(1)(b) GDPR contract (account, support), Art. 6(1)(c) GDPR legal obligation (tax invoicing where applicable), Art. 6(1)(f) GDPR legitimate interest (security/fraud).
3.5. Communication and Social Features
3.5.1. Forum activity, chat messages, in-game comments, shared media, reactions and reports
3.5.2. Voice chat snippets (e.g. when voice reporting is enabled in voice channels)
3.5.3. Where voice chat or platform-level reporting features are enabled, certain communication or moderation-related data may be temporarily processed where necessary for moderation, safety, abuse prevention, enforcement of the EULA, protection of users, or compliance with applicable law.
3.5.4. When you use multiplayer, social, public profile, leaderboard, chat, voice or similar features, your display name, avatar, profile cosmetics, rank, gameplay activity, communications and other information you choose to share may be visible to other players. Other players may also capture or share their own screenshots, recordings or streams of gameplay in which your avatar, display name, voice or in-game activity may appear.
3.5.5. User-generated content, including media, comments, reactions, reports, pictures, screenshots, gameplay recordings, video or audio clips, characters, maps, 3D objects and other content created, uploaded, shared or reported through the Game or related services.
3.5.6. Feedback submitted via forms, beta programs or UX research.
3.6. Purposes: provide in-game/social features; community moderation; safety; investigate EULA breaches; respond to support; improve features.3.5.2. Voice chat snippets (e.g. when voice reporting is enabled in voice channels)
3.5.3. Where voice chat or platform-level reporting features are enabled, certain communication or moderation-related data may be temporarily processed where necessary for moderation, safety, abuse prevention, enforcement of the EULA, protection of users, or compliance with applicable law.
3.5.4. When you use multiplayer, social, public profile, leaderboard, chat, voice or similar features, your display name, avatar, profile cosmetics, rank, gameplay activity, communications and other information you choose to share may be visible to other players. Other players may also capture or share their own screenshots, recordings or streams of gameplay in which your avatar, display name, voice or in-game activity may appear.
3.5.5. User-generated content, including media, comments, reactions, reports, pictures, screenshots, gameplay recordings, video or audio clips, characters, maps, 3D objects and other content created, uploaded, shared or reported through the Game or related services.
3.5.6. Feedback submitted via forms, beta programs or UX research.
3.7. Legal basis: Art. 6(1)(b) GDPR (feature delivery), Art. 6(1)(f) GDPR (moderation/safety).
3.8. Game and Content Usage
3.8.1. Game progress, play frequency, character builds, virtual currency, skill trees (statistics like Favorite Skin, Most Used Spell, Favorite Arena, Number of Matches, Number of Wins, Number of Kills, Average Kills/Match, Total Damage, Average Damage, Most Kills/Match, Kill/Death Ratio for Last 5 Matches, Total Healing, Most Damage/Match, Top Death Spell) and other,
3.8.2. Purchase logs, unlocks, limited-time rewards, and social stats,
3.8.3. Data about your choices and behaviors in interactive content (e.g. whether you explore PvP or cooperative zones, what VR tools you use, etc.), Event and interaction data (statistics like Match Start/Finish, Player Join Session, Spell Cast (All Types), Player Death, Game Start, Skin Customization, Arena Type Button (Play Now, Custom, Training), Enter/Exit Builder, Tutorial Begin/Complete/Interrupt/Stay).
3.8.4. Feng-shui element attribution, used to personalize the user’s virtual space and character narrative.
3.9. Purposes: gameplay functionality; matchmaking; anti-cheat; analytics and balancing; leaderboards (optional social display); content personalization.3.8.2. Purchase logs, unlocks, limited-time rewards, and social stats,
3.8.3. Data about your choices and behaviors in interactive content (e.g. whether you explore PvP or cooperative zones, what VR tools you use, etc.), Event and interaction data (statistics like Match Start/Finish, Player Join Session, Spell Cast (All Types), Player Death, Game Start, Skin Customization, Arena Type Button (Play Now, Custom, Training), Enter/Exit Builder, Tutorial Begin/Complete/Interrupt/Stay).
3.8.4. Feng-shui element attribution, used to personalize the user’s virtual space and character narrative.
3.10. Legal basis: Art. 6(1)(b) GDPR (core gameplay), Art. 6(1)(f) GDPR (anti-cheat, analytics, leaderboards).
3.11. Technical and Device Information
3.11.1. IP address, device type, OS, crash logs, browser version, installed plugins, unique hardware identifiers
3.11.2. Audio device data used for voice chat processing
3.11.3. VR interaction data, such as headset and controller position, orientation, movement, gesture inputs, tracking quality and related technical signals necessary to provide VR gameplay and spell-casting functionality.
3.11.4. Network latency and FPS-related diagnostics
3.12. Purposes: diagnostics; security; performance optimization; cheating/fraud detection.3.11.2. Audio device data used for voice chat processing
3.11.3. VR interaction data, such as headset and controller position, orientation, movement, gesture inputs, tracking quality and related technical signals necessary to provide VR gameplay and spell-casting functionality.
3.11.4. Network latency and FPS-related diagnostics
3.13. Legal basis: Art. 6(1)(b) GDPR (Game functionality), Art. 6(1)(f) GDPR (security, diagnostics, fraud prevention and performance optimization).
3.14. Location and Geolocation Data
3.14.1. Approximate geographic location from IP address
3.14.2. Precise GPS data if you consent (e.g. for location-specific experiences)
3.15. Purposes: regional content/pricing; location-based features.3.14.2. Precise GPS data if you consent (e.g. for location-specific experiences)
3.16. Legal basis: Art. 6(1)(b) GDPR (regional features), Art. 6(1)(f) GDPR (fraud prevention), Art. 6(1)(a) GDPR consent for precise GPS.
3.17. Payment, Purchase and Reward Data
3.17.1. Steam or Meta Purchases.
3.18. Data: purchase history, item identifiers, pricing and currency, entitlement status, refund status, and technical signals required to grant items in the Game. We do not receive your full billing details or card data from Steam or Meta.3.19. Purposes: grant and maintain entitlements; fulfil refunds granted by Steam or Meta; prevent fraud and abuse.
3.20. Legal basis: Art. 6(1)(b) GDPR (contract – deliver purchased items); Art. 6(1)(f) GDPR (fraud prevention).
3.20.1. Website Purchases.
3.21. Data: transaction identifiers, purchaser name and email, billing country/region, VAT/tax identifiers where applicable, invoice details, payment IDs or last 4 digits (if provided by the processor), and in-game currency or item identifiers (e.g. VR Bucks).3.22. Purposes: process orders and issue invoices; grant entitlements; handle refunds or chargebacks; comply with tax and accounting duties; prevent fraud.
3.23. Legal basis: Art. 6(1)(b) GDPR (contract – order processing and entitlements); Art. 6(1)(c) GDPR (legal obligations – tax/accounting); Art. 6(1)(f) GDPR (fraud prevention).
3.24. Meta or Steam User Data
3.25. When you access the Game via the Meta or Steam platform, we process certain user and device data provided by Meta or Steam, such as platform identifiers, username, avatar, voice communication data (where enabled), device and performance data, and gameplay interaction data (“Platform User Data”).
3.26. Purposes: enable multiplayer and social features; provide voice communication; ensure safety and moderation; prevent abuse and cheating; operate and improve the Game.
3.27. Legal basis: Art. 6(1)(b) GDPR (performance of contract – gameplay functionality); Art. 6(1)(f) GDPR (security, moderation, fraud prevention).
3.28. Platform User Data is used solely for operating, securing and improving the Game and is processed in accordance with the applicable platform terms, developer policies and data use requirements of Meta or Steam, as applicable.
3.29. Meta and Steam act as independent controllers for platform-level data they process in accordance with their own privacy policies and platform terms.
3.30. Cookies, Tracking and Inference Data
3.30.1. Use of cookies and similar tracking technologies;
3.30.2. Session data: clickstream, referral sources;
3.30.3. Inferred preferences and behavioral profiles (e.g. skill level).
3.31. Purposes: analytics; Game improvement; personalizationg.3.30.2. Session data: clickstream, referral sources;
3.30.3. Inferred preferences and behavioral profiles (e.g. skill level).
3.32. Legal basis: Art. 6(1)(a) GDPR consent for non-essential cookies/ads IDs; Art. 6(1)(f) GDPR for strictly necessary analytics without identifiers (where permitted).
3.33. Publicly Available or Social Media Data
3.33.1. Information you post publicly (e.g. Reddit, Discord, Twitter, YouTube comments about our products)
3.33.2. Data from platforms you link (e.g., Steam)
3.34. Purposes: community engagement; safety moderation; Game feedback; account linking features.3.33.2. Data from platforms you link (e.g., Steam)
3.35. Legal basis: Art. 6(1)(f) GDPR legitimate interest; Art. 6(1)(b) GDPR where linking is user-initiated.
3.36. Event Participation and Attendance Data
3.37. We may collect the following data when you register for, attend, or participate in our physical or digital events (e.g., tournaments, community meetups, developer conferences, or promotional streams):
3.37.1. Name, surname and contact information (e.g., email address);
3.37.2. Technical data (e.g., IP address, device data) in case of online events;
3.37.3. Event-related interactions (e.g., chat messages, polls, feedback forms);
3.37.4. Recordings, video streams, or photographs if the event is recorded (always with prior notice);
3.37.5. Registration and attendance data (e.g., time of entry, login status, session logs).
3.38. Purposes: registration and access; event security; communications; post-event analytics; marketing use of recordings only with consent.3.37.2. Technical data (e.g., IP address, device data) in case of online events;
3.37.3. Event-related interactions (e.g., chat messages, polls, feedback forms);
3.37.4. Recordings, video streams, or photographs if the event is recorded (always with prior notice);
3.37.5. Registration and attendance data (e.g., time of entry, login status, session logs).
3.39. Legal basis: Art. 6(1)(b) GDPR contract (registration), Art. 6(1)(f) GDPR (security/analytics), Art. 6(1)(a) GDPR - consent (recordings for public distribution).
3.40. AI Builder and Moderation Data
3.40.1. User prompts, tool parameters, generated outputs metadata, system decisions (allow/deny), and moderation logs (e.g., IP keyword matches, regex flags).
3.40.2. We may also store minimal error/debug logs to improve safety and quality.
3.41. Purposes: provide AI creation features; prevent infringing/illegal content; abuse/fraud detection; safety auditing; quality improvement.3.40.2. We may also store minimal error/debug logs to improve safety and quality.
3.42. Legal basis: Art. 6(1)(b) GDPR (feature delivery); Art. 6(1)(f) GDPR (safety/moderation, service integrity).
3.43. Unless stated otherwise, we collect personal data directly from you or your device when you use our services or interact with our platforms.
4. Legal title and purpose of processing in detail
4.1. We process your personal data only where we have a valid legal basis under Article 6 of the General Data Protection Regulation (GDPR). These are:4.2. Performance of contractual and legal obligations
4.2.1. We process name, surname, and where required billing address and tax identifiers to issue invoices and comply with tax laws.
4.2.2. The date of birth is processed to verify that you comply with the age restriction.
4.2.3. Account identifiers and authentication information made available to the Game are processed to authenticate you and enable you to access the Game through your Account.
4.2.4. We also process the date of birth and gender so that we can determine which element (earth, wood, water, metal or fire) corresponds to your person in traditional Chinese feng-shui teachings. Based on this analysis, the content in the games is then adjusted and personalized. If you do not want us to process your gender, please contact us directly.
4.2.5. Technical data are processed to make the Game functional.
4.2.6. We process data you provide when registering for or attending our events (e.g., name, email, login time) in order to manage your participation, provide access to event content, and issue confirmations or communications related to the event. This processing is necessary for the performance of the contract (your registration or attendance).
4.2.7. If you use our developer tools, SDKs, or APIs, we process personal data such as your name, email, organization and developer account credentials to manage access, authenticate API use, and deliver technical support or updates. This processing is based on our contractual obligation to provide developer services.
4.2.8. Billing and transaction data related to paid developer features or event services are processed to fulfil legal obligations in tax, accounting, and commercial law.
4.2.9. We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in Account, support request etc.).
4.3. Processing of personal data based on legitimate interest4.2.2. The date of birth is processed to verify that you comply with the age restriction.
4.2.3. Account identifiers and authentication information made available to the Game are processed to authenticate you and enable you to access the Game through your Account.
4.2.4. We also process the date of birth and gender so that we can determine which element (earth, wood, water, metal or fire) corresponds to your person in traditional Chinese feng-shui teachings. Based on this analysis, the content in the games is then adjusted and personalized. If you do not want us to process your gender, please contact us directly.
4.2.5. Technical data are processed to make the Game functional.
4.2.6. We process data you provide when registering for or attending our events (e.g., name, email, login time) in order to manage your participation, provide access to event content, and issue confirmations or communications related to the event. This processing is necessary for the performance of the contract (your registration or attendance).
4.2.7. If you use our developer tools, SDKs, or APIs, we process personal data such as your name, email, organization and developer account credentials to manage access, authenticate API use, and deliver technical support or updates. This processing is based on our contractual obligation to provide developer services.
4.2.8. Billing and transaction data related to paid developer features or event services are processed to fulfil legal obligations in tax, accounting, and commercial law.
4.2.9. We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in Account, support request etc.).
4.4. We process certain personal data based on our legitimate interests, provided such processing does not override your fundamental rights and freedoms. This includes:
4.4.1. Processing pseudonymised statistical and technical data to:
4.5. - prevent misuse or abuse of the Game;4.6. - detect technical issues and maintain service availability;
4.7. - improve the Game experience;
4.8. - detecting and preventing fraud, cheating, or violations of our End User License Agreement (EULA), including using gameplay telemetry to identify patterns of behaviour that may indicate such activities. This is essential to ensure fairness and platform integrity for all users.
4.8.1. Displaying leaderboards and rankings based on your performance in the Game (e.g., nickname, achievements, scores). This social feature is designed to foster competition and engagement, and you may object to this type of data being published or displayed under your nickname by contacting us.
4.8.2. Processing publicly available content and data from social or gaming platforms (e.g., Reddit, Discord, Steam, Twitch) in order to understand community feedback, monitor engagement, and improve the Game and communication strategies. This is based on our legitimate interest in Game development and community management. We only process data that has been made publicly accessible by the user or shared through linked Accounts, and we take appropriate measures to minimize the scope of such data.
4.8.3. Processing linked Account data (e.g., from Steam or Meta) where the user voluntarily connects their external profile to enhance cross-platform functionality, track game progress, or provide personalized features. Such processing is based on our legitimate interest in providing seamless and integrated user experiences.
4.8.4. We may process technical and analytical data related to event participation (e.g., usage logs, chat activity, attendance metrics) to improve future events, ensure technical stability, and analyse audience engagement. This processing is based on our legitimate interest in event optimization and service delivery.
4.8.5. When you interact with our developer tools, we may collect telemetry, error logs, and feature usage statistics to monitor performance, detect issues, and continuously improve the platform. This processing is based on our legitimate interest in maintaining and improving the quality of our developer infrastructure.
4.8.6. If you post or interact via developer communication channels (e.g., Discord, GitHub, support forums), we may retain relevant identifiers and message logs as part of community moderation and support. This is based on our legitimate interest in maintaining a safe and functional development environment.
4.8.7. We may send you commercial communications related to similar products or services, or with information about updates, contests, and other events. This is based on our legitimate interest in promoting our offerings and engaging with our user community. You can opt out of such communications at any time.
4.8.8. This processing is conducted using aggregated or pseudonymised data where possible, and never involves automated decision-making that would produce legal or similarly significant effects. You have the right to object to this processing at any time (see Section 9).
4.9. Processing of personal data on the basis of consent4.8.2. Processing publicly available content and data from social or gaming platforms (e.g., Reddit, Discord, Steam, Twitch) in order to understand community feedback, monitor engagement, and improve the Game and communication strategies. This is based on our legitimate interest in Game development and community management. We only process data that has been made publicly accessible by the user or shared through linked Accounts, and we take appropriate measures to minimize the scope of such data.
4.8.3. Processing linked Account data (e.g., from Steam or Meta) where the user voluntarily connects their external profile to enhance cross-platform functionality, track game progress, or provide personalized features. Such processing is based on our legitimate interest in providing seamless and integrated user experiences.
4.8.4. We may process technical and analytical data related to event participation (e.g., usage logs, chat activity, attendance metrics) to improve future events, ensure technical stability, and analyse audience engagement. This processing is based on our legitimate interest in event optimization and service delivery.
4.8.5. When you interact with our developer tools, we may collect telemetry, error logs, and feature usage statistics to monitor performance, detect issues, and continuously improve the platform. This processing is based on our legitimate interest in maintaining and improving the quality of our developer infrastructure.
4.8.6. If you post or interact via developer communication channels (e.g., Discord, GitHub, support forums), we may retain relevant identifiers and message logs as part of community moderation and support. This is based on our legitimate interest in maintaining a safe and functional development environment.
4.8.7. We may send you commercial communications related to similar products or services, or with information about updates, contests, and other events. This is based on our legitimate interest in promoting our offerings and engaging with our user community. You can opt out of such communications at any time.
4.8.8. This processing is conducted using aggregated or pseudonymised data where possible, and never involves automated decision-making that would produce legal or similarly significant effects. You have the right to object to this processing at any time (see Section 9).
4.9.1. We use cookies and similar tracking technologies on our Website. Non-essential cookies (e.g., analytics, personalization, and marketing cookies) are only used with your explicit consent, in accordance with Article 6(1)(a) GDPR and applicable ePrivacy laws.
4.9.2. These cookies help us:
4.10. - understand how users interact with our website and services;4.9.2. These cookies help us:
4.11. - improve user experience and website performance;
4.12. - deliver personalized content, relevant promotions, and targeted offers;
4.13. - measure the effectiveness of marketing campaigns and optimize our communication.
4.13.1. You can manage your cookie preferences at any time via our Cookie Banner or Cookie Settings.
4.13.2. We process precise geolocation data (e.g., GPS) only if you provide your consent within the relevant application. This data may be used to enable location-based features or experiences. You can withdraw your consent at any time in your device settings.
4.13.3. Where we record or stream physical or digital events and use the footage for public distribution (e.g., marketing videos, highlight reels), we process your image, voice, or other identifying data based on your consent. You will always be informed in advance and may opt out of such processing.
4.13.4. If you sign up to receive our newsletter or marketing emails that do not fall under our legitimate interest (e.g., unrelated Game announcements, third-party promotions), we will process your contact data (e.g., email address) based on your explicit consent.
4.13.5. You have the right to withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
4.13.6. By providing consent under this Privacy Policy, you confirm that you are legally capable of giving such consent under the laws applicable to you. If you are under the age of legal majority in your country of residence, you confirm that your parent or legal guardian has reviewed and approved such consent where required by applicable law.
4.13.2. We process precise geolocation data (e.g., GPS) only if you provide your consent within the relevant application. This data may be used to enable location-based features or experiences. You can withdraw your consent at any time in your device settings.
4.13.3. Where we record or stream physical or digital events and use the footage for public distribution (e.g., marketing videos, highlight reels), we process your image, voice, or other identifying data based on your consent. You will always be informed in advance and may opt out of such processing.
4.13.4. If you sign up to receive our newsletter or marketing emails that do not fall under our legitimate interest (e.g., unrelated Game announcements, third-party promotions), we will process your contact data (e.g., email address) based on your explicit consent.
4.13.5. You have the right to withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
4.13.6. By providing consent under this Privacy Policy, you confirm that you are legally capable of giving such consent under the laws applicable to you. If you are under the age of legal majority in your country of residence, you confirm that your parent or legal guardian has reviewed and approved such consent where required by applicable law.
5. Storage time
5.1. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or to comply with legal obligations, in accordance with Article 5(1)(e) GDPR. The retention period depends on the legal basis for processing:5.2. Contractual necessity (Article 6(1)(b) GDPR) - We retain personal data necessary for the performance of the contract (e.g., user Account data, game activity, technical data) for the duration of the contract or End User License Agreement (EULA) and up to 4 years following termination, for the purpose of handling claims, disputes, or support history.
5.3. Legal obligations (Article 6(1)(c) GDPR) - We retain data such as billing and payment records for the period required by tax, accounting, consumer protection, or other legislation.
5.4. Legitimate interest (Article 6(1)(f) GDPR) - We retain personal data processed under legitimate interest (e.g., pseudonymised analytics, anti-fraud logs, leaderboard data) for as long as the interest applies and for up to 3 years after Account deletion, unless you object to further processing.
5.5. Consent (Article 6(1)(a) GDPR) - We retain personal data collected on the basis of your consent (e.g., marketing preferences, cookie tracking, in-game personalization) only until you withdraw your consent or until the stated purpose is fulfilled. You may withdraw your consent at any time (see Section 8).
5.6. Where an Account is deactivated or terminated in accordance with the Victoria VR Account Terms and Conditions, access to the Game through that Account may cease. Personal data processed by us in connection with the Game will be retained, deleted or anonymised in accordance with the retention periods set out in this Privacy Policy.¨
5.7. Where required by Meta, Steam or other applicable platform policies, we may delete, restrict, anonymize or otherwise modify Platform User Data upon request from the relevant platform provider, in addition to deletion requests submitted by users.
6. Processors, International Data Transfers and information sharing
6.1. For the effective operation of our services, we may engage third-party service providers (data processors) to process personal data on our behalf, strictly in accordance with Article 28 GDPR and subject to appropriate contractual safeguards. These include:6.1.1. Game developer - Victoria VR Group, a.s., ID No. 21924945, with registered office at Václavské náměstí 796/42, Nové Město, 110 00 Prague 1, Czech Republic, registered in the Commercial Register of the Municipal Court in Prague, file No. B 29030. For certain processing activities related to the operation of the Victoria VR Account system, authentication, account management, cross-platform functionality and Game services, Delta VR Ventures s.r.o. and Victoria VR Group a.s. may act as joint controllers within the meaning of Article 26 GDPR. The parties have entered into an arrangement allocating their respective responsibilities for compliance with applicable data protection laws. Users may exercise their rights under the GDPR by contacting either party. Victoria VR Group a.s. may also process personal data as a processor on behalf of the Company for certain technical, hosting, moderation, analytics, customer support, cloud and infrastructure-related services necessary for the operation of the Game.
6.1.2. Cloud Hosting & Infrastructure Providers
6.2. – Microsoft Azure,6.1.2. Cloud Hosting & Infrastructure Providers
6.2.1. Payment Processors
6.3. – e.g., Stripe, PayPal6.3.1. Marketing & Analytics Tools
6.4. – e.g., Google Analytics, Mailchimp, HubSpot,6.4.1. Customer Support Platforms
6.5. – e.g., Zendesk, Freshdesk, Intercom6.5.1. Communication Services
6.6. – e.g., Twilio (SMS/email), SendGrid, Mailgun6.6.1. Security & Authentication Tools
6.7. - e.g. Cloudflare6.7.1. Developer & Debugging Tools
6.8. – e.g., Sentry (for error tracking)6.8.1. CRM and User Data Management
6.8.2. External IT Providers or Software Contractors
6.9. – e.g., freelance developers or third-party agencies managing infrastructure, databases, or applications6.8.2. External IT Providers or Software Contractors
6.10. We ensure that all processors provide sufficient guarantees to implement appropriate technical and organisational measures in accordance with the GDPR. We primarily process your personal data within the European Union. If personal data is transferred outside the EU/EEA (e.g., to the United States), we rely on one or more of the following safeguards:
6.10.1. Standard Contractual Clauses (SCCs) approved by the European Commission;
6.10.2. An adequacy decision by the European Commission (e.g., for countries like Switzerland);
6.10.3. Additional technical, contractual and organisational measures to ensure equivalent data protection.
6.11. You can request more information about international transfers by contacting us (see Section 9).6.10.2. An adequacy decision by the European Commission (e.g., for countries like Switzerland);
6.10.3. Additional technical, contractual and organisational measures to ensure equivalent data protection.
6.12. Certain profile and gameplay information may be publicly visible to other users depending on your privacy settings, including your display name, avatar, profile cosmetics, rank, achievements and selected gameplay statistics.
6.13. We may share some of the information we collect to help operate, support, and improve our services. Depending on how you interact with us, common examples of sharing include:
6.13.1. With platform partners (e.g., Steam, Meta) to facilitate gameplay, purchases, entitlements, and refunds made through the relevant platform.
6.13.2. With the Game developer for development, security, operation, and support of the Game and AI Builder features under appropriate data protection terms.
6.13.3. With payment providers (e.g., Stripe) for purchases on our Website to process payments, refunds, chargebacks, and to issue invoices where applicable.
6.13.4. With other users, particularly when you use social features like chat, where certain profile elements may be visible.
6.13.5. Publicly, such as your display name, content you create or share, basic game statistics, and similar information, which may be generally accessible to others.
6.13.6. With service providers that operate on our behalf in accordance with our instructions, including cloud storage services, payment processors, marketing and advertising partners, and support services.
6.13.7. When we are legally required to do so or when it is necessary to protect rights and safety, such as in response to legal proceedings, investigations of potential violations of our terms or applicable laws, or when there is a risk of serious harm to individuals or property.
6.13.8. With affiliated entities within our corporate structure, including for the provision of international support or shared services.
6.13.9. In the context of a corporate transaction, including mergers, acquisitions, reorganizations, or the sale of assets.
6.13.10. With your consent, for example, when you link an external account or participate in cross-platform events, promotions, or shared gameplay experiences.
6.13.11. In aggregated or de-identified form, which does not personally identify you and may be used for analytics, research, or similar purposes.
6.14. When we share your personal data with third parties, we make reasonable efforts to ensure that they provide protections equivalent to those described in this privacy policy.6.13.2. With the Game developer for development, security, operation, and support of the Game and AI Builder features under appropriate data protection terms.
6.13.3. With payment providers (e.g., Stripe) for purchases on our Website to process payments, refunds, chargebacks, and to issue invoices where applicable.
6.13.4. With other users, particularly when you use social features like chat, where certain profile elements may be visible.
6.13.5. Publicly, such as your display name, content you create or share, basic game statistics, and similar information, which may be generally accessible to others.
6.13.6. With service providers that operate on our behalf in accordance with our instructions, including cloud storage services, payment processors, marketing and advertising partners, and support services.
6.13.7. When we are legally required to do so or when it is necessary to protect rights and safety, such as in response to legal proceedings, investigations of potential violations of our terms or applicable laws, or when there is a risk of serious harm to individuals or property.
6.13.8. With affiliated entities within our corporate structure, including for the provision of international support or shared services.
6.13.9. In the context of a corporate transaction, including mergers, acquisitions, reorganizations, or the sale of assets.
6.13.10. With your consent, for example, when you link an external account or participate in cross-platform events, promotions, or shared gameplay experiences.
6.13.11. In aggregated or de-identified form, which does not personally identify you and may be used for analytics, research, or similar purposes.
6.15. Please note that third parties you interact with through our services (such as Epic, Steam, or Meta) may have their own privacy policies and data practices. We encourage you to review those policies before sharing information or linking accounts.
7. AUTOMATED DECISION-MAKING
7.1. We use certain forms of automated processing to enhance the user experience, maintain fair gameplay, and ensure Game integrity. These activities do not produce legal or similarly significant effects within the meaning of Article 22 GDPR. Examples include:7.1.1. Fraud detection and duplicate Account prevention using behavioral patterns and login metadata;
7.1.2. Matchmaking in multiplayer games based on skill level, latency, and in-game behavior.
7.2. These types of automated processing are based on our legitimate interest in improving our services (Article 6(1)(f) GDPR) or are necessary for the performance of the contract (Article 6(1)(b) GDPR), depending on the context.7.1.2. Matchmaking in multiplayer games based on skill level, latency, and in-game behavior.
7.3. We never use automated decision-making to make decisions that have legal or similarly significant effects on you without meaningful human involvement.
7.4. You have the right to object to automated processing or profiling where it is based on our legitimate interest (see Section 8).
8. Your rights
8.1. In particular, you have the following rights in relation to your personal data:8.1.1. Right of access to personal data - you can contact us at any time to ask if we are processing your personal data and, if so, to request further information about this processing.
8.1.2. The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
8.1.3. Right to request restriction of processing - in the cases referred to in Article 18 of the GDPR, you have the right to request restriction of the processing of your personal data.
8.1.4. Right to erasure of personal data - in the cases referred to in Article 17 of the GDPR, you have the right to request that we erase personal data concerning you without undue delay.
8.1.5. Right to request data transfer - under the conditions set out in Article 20 of the GDPR, you have the right to ask us to transfer your personal data to a third party.
8.1.6. Right to withdraw the consent to process your personal data. We process your personal data based on your consent. You can withdraw such consent at any time by sending us a request at [email protected].
8.1.7. Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
8.1.8. Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the Office for Personal Data Protection of the Czech Republic (Úřad pro ochranu osobních údajů).
8.1.2. The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
8.1.3. Right to request restriction of processing - in the cases referred to in Article 18 of the GDPR, you have the right to request restriction of the processing of your personal data.
8.1.4. Right to erasure of personal data - in the cases referred to in Article 17 of the GDPR, you have the right to request that we erase personal data concerning you without undue delay.
8.1.5. Right to request data transfer - under the conditions set out in Article 20 of the GDPR, you have the right to ask us to transfer your personal data to a third party.
8.1.6. Right to withdraw the consent to process your personal data. We process your personal data based on your consent. You can withdraw such consent at any time by sending us a request at [email protected].
8.1.7. Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
8.1.8. Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the Office for Personal Data Protection of the Czech Republic (Úřad pro ochranu osobních údajů).
9. Contact
9.1. If you want to contact us, ask us about anything related to the processing of your personal data or tell us that you do not want us to process your personal data, you can use the following contact details:9.2. Delta VR Ventures s.r.o.
9.3. Email: [email protected]
9.4. Address: Chvalská 718/10, 198 00 Prague 9, Czech Republic
10. other and final provisions
10.1. If you refuse to provide personal data necessary for the above purposes, we may not be able to provide you with our service.10.2. Most processing activities are carried out through automated systems to support efficiency, accuracy, and scalability.
11. U.S. PRIVACY ADDENDUM
11.1. This section applies to users located in the United States.11.2. We collect and use personal information as described in Section 3 for the purposes set out in Sections 3–6 (e.g., account management, gameplay, payments, security, analytics, support, and marketing).
11.3. We do not sell your personal information for monetary consideration. We may "share" limited identifiers with advertising or analytics partners only with your prior consent (see Sections 3.8 and 4.3). You can withdraw or manage such consent at any time via your cookie or advertising settings.
11.4. Depending on your state of residence, you may have the right to:
11.4.1. request access to or a copy of your personal information;
11.4.2. request deletion of your personal information;
11.4.3. request correction of inaccurate personal information;
11.4.4. opt out of the sale or sharing of personal information and targeted advertising
11.4.5. request information about how we collect, use, and disclose personal information; and
11.4.6. not be discriminated against for exercising your privacy rights.
11.5. We do not use or disclose sensitive personal information to infer characteristics about you.11.4.2. request deletion of your personal information;
11.4.3. request correction of inaccurate personal information;
11.4.4. opt out of the sale or sharing of personal information and targeted advertising
11.4.5. request information about how we collect, use, and disclose personal information; and
11.4.6. not be discriminated against for exercising your privacy rights.
11.6. We retain personal information as described in Section 6 and apply reasonable and appropriate security measures consistent with applicable U.S. Privacy Laws.
11.7. This Privacy Policy is effective as of _____