Policy Privacy - MyPetXR

Introduction
This Privacy Policy outlines how Metagate collects, uses, and protects user data specific to the MyPetXR game on the Meta Quest platform. It is intended to complement Metagate’s general Privacy Policy and provides further details relevant to MyPetXR users.

1. Data Collection
MyPetXR collects minimal personal data necessary to provide a personalized and secure gaming experience. Specifically, we collect:

• User Avatar Information: To customize the in-game experience.
• Gameplay Metrics: To track progress, achievements, and feedback.
• Device Information: Including headset model and firmware for performance optimization.
• Session Data: Duration and interactions for experience enhancement.

Data Saved in Unity Cloud Save (UCS):
Metagate saves specific user data in Unity Cloud Save to ensure that players can retrieve their settings and progress when they reaccess the game. These saved data include:

• Oculus User ID: A unique alphanumeric code associated with the user's Meta Quest profile.
• Audio Settings: Personalized volume and audio preferences.
• Occlusion Settings: Preferences related to in-game visual occlusion settings.
• Pet Name: The customized name of the player’s virtual pet (e.g., the dog’s name in the game).

Additional Information:
Certain data types are accessed and used only within the game environment but are not stored by Metagate. These include:

• User Profile: Access to the Oculus username and profile photo to personalize the experience. This data is not saved by Metagate.
• Sensor and Device Data: MyPetXR utilizes the microphone, hand tracking, and spatial tracking data to enable immersive gameplay features. These inputs are processed locally during gameplay and not retained by Metagate.

Purpose:
All data collected is used solely to enhance gameplay, ensure security, and provide support. No additional data unrelated to gameplay is collected.

2. Consent
User consent is obtained via a clear, mandatory checkbox upon first login to MyPetXR. By checking this box, users confirm that they have read, understood, and agreed to this Privacy Policy.

3. Access and Modification
Users have the right to access and modify their data. Tools are provided within the game settings to:

• View collected data.
• Update preferences.
  For further assistance, users can contact Metagate’s Data Protection Officer (DPO) at dpo@themetagate.it.

4. Data Deletion
Users may request data deletion by:

• Sending an email request to dpo@themetagate.it.
  Upon verification, the user’s data will be permanently removed within 30 days.

5. Data Security
Metagate implements robust security measures, including:

• Limited access to databases.
• Offline backups.
• Data encryption during storage and transfer.

All data collection processes occur within the secure Meta Quest environment. No browser-based access is utilized, reducing potential attack vectors.

6. Communications
Policy updates and changes will be communicated to users:

• Via the official Metagate website.
• Through in-app notifications upon new updates.

7. Data Retention
User data is retained for a maximum of 2 years from the last access to the game. This retention period ensures operational continuity while adhering to the principles of data minimization.

8. Minors
MyPetXR is not intended for users under the age of 18. Metagate does not knowingly collect personal information from minors. If a parent or guardian believes their child has provided personal information, they can request its deletion by contacting dpo@themetagate.it.

9. Cookies and Tracking
MyPetXR does not collect cookies or tracking data. (except during closed Alpha Testing phases, where minimal usage data may be gathered for debugging purposes).

10. Data Protection Officer (DPO)
The appointed DPO for Metagate is Marco Pizzini, responsible for ensuring compliance with data protection regulations. For any privacy concerns or inquiries, please contact:
Email: dpo@themetagate.it

11. Legal Basis for Data Processing
In compliance with the GDPR, MyPetXR processes personal information based on:

• User Consent: As provided during the onboarding process.
• Contractual Necessity: To fulfill the service provided by MyPetXR.
• Legal Obligations: To comply with applicable laws and regulations.
• Legitimate Interests: When necessary to improve service quality and security, without overriding user rights.

12. Selling Personal Information
Metagate does not sell personal information, as defined under the California Consumer Privacy Act (CCPA).

13. User Rights
GDPR: If you are a resident of the EEA, you have the right to:

• Access your personal data.
• Request correction, updates, or deletion of your data.
• Port your data to another service.

CCPA: If you are a California resident, you have the right to:

• Access personal information held by Metagate.
• Request deletion or correction of your data.
• Transfer data to another provider.

14. Policy Updates
This Privacy Policy may be updated to reflect changes in legal requirements or service improvements. The latest update will always be available in the MyPetXR app and on the Metagate website.

Effective Date: 07/01/2025

Contact Information:
For questions or concerns, please contact the DPO at dpo@themetagate.it.