1. From what sources do we collect Personal Information

1. We may collect your Personal Information when you provide it to us directly, including the examples below.
   • When you create an account for the Game, we may collect your username and IP address.
   • When you play the Game, we may collect your movement data (tracking your hands and head) and voice data.
   • When you contact us directly, we may collect your first and last name, email address, and records and copies of your correspondence.
   • When you respond to a survey or questionnaire, we may collect the information provided.
2. We may collect your Personal Information automatically as you use our Game
   • We use Unity Analytics to collect gameplay and device information from our players.
3. From Third Parties
   • We may receive your Personal Information from or through third parties that help us provide or facilitate your access to the Services. For example, we may receive your Personal Information from the below third parties.
   • Game publishers such as Meta® and Valve®: When you purchase in-Game items or DLCs, we may receive your purchase history.
   • Social media platforms such as Discord®: When you join the Game Discord channel, we may receive your Discord username, user ID, and the information that you share publicly on our Discord channel. When you appeal against being banned from the Game Discord channel, we may receive your email address.
   • We abide by this Policy when we use Personal Information provided to us by third parties. However, we may not control the Personal Information that third parties collect or how they use that Personal Information. You should review the third parties' privacy policies for more information about how they collect, use, and share the Personal Information they obtain and use.

2. What categories of Personal Information do we collect

We may collect Personal Information about you. “Personal Information” means any information relating to an identified or identifiable individual. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

We do not knowingly or intentionally process any sensitive Personal Information.

• Personal Information We Collect When You Use Our Game
• Unity Analytics:Data collected by Unity includes but is not limited to hardware specs, usage data, and custom event data (where applicable). This data is collected and managed by Unity - see Unity Privacy Policy: https://unity.com/cn/legal/game-player-and-app-user-privacy-policy
• Commercial information: Purchase history of in-game items or DLCs.
• Audio, electronic, visual, thermal, olfactory, or similar information: Movement data (tracking your hands and head) and voice data.
• Personal Information we collected when you contact us by email.
• Identifiers: First and last name, Oculus ID, and email address.
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80 (e)): first and last name; and
• Other: Information that you email to us at support@forkingvr.com.
• Personal Information we collect when you visit the Game Discord Channel
• Identifiers: Discord username, Discord user ID, and email address;and
• Other: information from the content that you share publicly on Discord.

3. How We Use the Information We Collect

We collect, use, and disclose your Personal Information for the following specific business purposes:

• Providing Services: To enable us to provide our Services.
• Communication: To communicate with you, provide updates and other information related to our Services, furnish requested information, respond to comments and inquiries, and otherwise provide customer support.
• De-Identification and Aggregation: To de-identify and aggregate information collected through our Services and use it for any lawful purpose.
• Safety Issues: To address potential safety issues that may arise.
• Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
• Fraud and Incident Prevention: To detect security incidents, prevent malicious, deceptive, fraudulent, or illegal activities, and prosecute those responsible for such activities.

4. Children's privacy processing

In accordance with the policies of Meta® and Valve® for VR games, the Game is not designed for Children.(A “Child” is a person under the age needed to consent to the processing of Personal Information in their country of residence.)

User age is collected by the third-party gaming platforms Meta® in accordance with their policies. We do not collect information about the age of our users and/or we do not intentionally or knowingly collect, use, store, disclose, or otherwise process any personal information about Children.

If you become aware that your child or any child under your care has provided us with Personal Information without your consent, please contact us at the contact information listed below in the section “How to Contact Us”, and we will delete any such account or profile and associated Personal Information, and/or if we are notified that you are a Child, your account will be banned.

5. Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that Personal Information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

• Limited retention:

We retain each type of Personal Information only for as long as is necessary to fulfil the purpose for which the Personal Information was provided to us, or for an extended period to comply with any legal obligations, resolve disputes and enforce contracts (For example, we may retain Personal Information collected about you to prevent repeated violations or suspected violations of our Terms of Service if your account has been banned or your access to the Services has been disabled for any reason.)

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, subject to the foregoing considerations, it is our policy to delete your Personal Information if we stop operating the Game or feature through which the Personal Information was acquired.

• Purpose limitation:

We will use your Personal Information only for the Services you choose to access and for the purposes notified to you, unless we otherwise obtain your consent. We limit the collection of Personal Information to what is adequate, relevant, and reasonably necessary for those purposes.

• Security measures:

We use appropriate measures to ensure a level of security appropriate to the volume and nature of Personal Information processed and risk involved, considering the size, scope, and type of our business, and have implemented contractual, technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification.

As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Policy does not guarantee the security of your Personal Information. In the event of a security breach, we will notify the proper regulatory authorities and any affected users of the breach within 72 hours after we become aware of the breach.

Your practices and activities are likewise very important for the protection of your Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you share publicly in the Game or on the Game Discord channel, including the below:

• Do not use your real name when selecting a username.
• Do not share your real name or anything private about yourself or anyone else with other users.
• Do not pick a password that is easy to guess, and do not share your password.

Please remember that we have no control over what third parties do with the content of your communications and no responsibility or obligation regarding third parties.

6. Cross-border Data Transfers

Your data may be stored on secure servers located outside your resident country, such as in Singapore or the United States. We select server locations based on rigorous criteria to ensure your data's safety.

To adhere to applicable data protection laws, we utilize European Commission approved standard contractual clauses, constantly updating them based on the latest legal benchmarks.

7. In what situations do we disclose your Personal Information

We may disclose Personal Information to third parties if you consent to us doing so, as well as in the following circumstances:

• Vendors and Service Providers. We work with third-party service providers who provide services in connection with the provision of our Game. These third parties may have access to or process Personal Information about you as part of providing those services for us.
• As Required By Law and Similar Disclosures. We may disclose Personal Information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
• To Enforce Legal Claims. We also reserve the right to disclose Personal Information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Game and any facilities or equipment used to make the Platform available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Merger, Sale, or Other Asset Transfers. Personal Information may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.
• Aggregate Data. We may make certain aggregate or otherwise anonymized information available to third parties for various purposes, including compliance with various reporting obligations, unless we are prohibited from doing so under applicable law.
• Business Partners. We may share Personal Information with our business partners, including for the purposes of sales, marketing, recruiting and other related purposes.

8. What rights do you have to your Personal Information

Right to Access, Correct, Delete, or Restrict Processing

Subject to any limitations and exceptions under applicable law, you have the right to request access to your Personal Information and exercise the below rights.

• have the right to correct or update certain types of Personal Information. In many cases, you can review or update your account information by accessing your account online.
• have the right to request deletion of your Personal Information. If you choose to have your Personal Information removed from the Services, we will carry out your request within 30 days of account verification, subject to extension, and we will only retain minimal Personal Information to document your request and the actions we took to carry out your request.
• have the right to restrict certain processing of your Personal Information and the right to object to some types of processing of your Personal Information.
• have the right to withdraw your consent at any time.
• have the right to lodge a complaint regarding our collection, storage, or processing of your Personal Information with a data protection supervisory authority in the country where you live or work.

We will comply with your requests in accordance with, and subject to, applicable law. For example, we are not required to delete your Personal Information if we have an overriding legitimate ground for retaining that information, such as to prevent fraud. Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity or (2) where doing so would adversely affect the rights or freedoms of other individuals. Further, we are not required to carry out a requested action in some instances, including where the request is considered excessive.

To exercise your rights, please send an email to support@forkingvr.com.

9. Legal Bases for Processing European Personal Information (EEA)

If you are located in the European Economic Area (“EEA”) or the United Kingdom (together, “Europe”), we only process your Personal Information when we have a valid “legal basis,” including as set forth below.

• Consent. You have consented to the use of your Personal Information.
• Contract. We need your Personal Information to provide you with our Services. For example, we may need to process your Personal Information to respond to your inquiries or requests.
• Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information
• Legitimate Interests. We or a third party have a legitimate interest in using your Personal Information. Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and to improve the safety, security, and performance of our Game. We only rely on our or a third party's legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

10. California Resident Privacy Notice

For the purposes of this California Resident Privacy Notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

The following applies to California, Colorado, Connecticut, Utah, and Virginia Residents:(This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy):

11. Your California Privacy Rights

If you are a California resident, you may exercise the following rights:

• Right to Know and Access: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and confirm your verifiable consumer request, we will disclose to you the following, to the extent retained by us:
• the categories of Personal Information we collected about you;
• the categories of sources for the Personal Information we collected about you.
• our business or commercial purpose for collecting, selling, or sharing that Personal Information.
• the categories of third parties with whom we disclose that Personal Information.
• the specific pieces of Personal Information we collected about you (also known as a data portability request);
• Right to Correction: You have the right to request that we correct inaccurate Personal Information.
• Verification: Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
• Right to Equal Service and Price: You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
• Submit Requests: To exercise your rights under the CCPA, please send an email to support@forkingvr.com.

12. Changes and Updates to this Policy

We reserve the right to change this Policy from time to time consistent with applicable law. Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time.

If we modify this Policy, we will make it available through the Game, and indicate the effective date. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may generate a pop-up or similar notification when you access the Game for the first time after such material changes are made. Your continued use of the Game after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

13. How to Contact Us

If you have any questions, comments, or concerns regarding this Policy or our processing activities, or if you wish to exercise your privacy rights, please send an email to support@forkingvr.com with the subject line “Personal Information Request.”

If you are a law enforcement agency, please send an email to support@forkingvr.com with the subject line “Law Enforcement Request.”