Privacy Policy

Last Updated: September 23, 2025

1. Introduction

FantaPass MR Studio Inc. (“FantaPass,” “we,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our products and services, including our mixed reality multiplayer game Superhero IRL and any future titles or applications we publish for Meta Quest or other platforms (collectively, the “Services”).

By using our Services, you agree to the practices described in this Privacy Policy. If you do not agree, you should not use the Services.

2. Information We Collect

We may collect the following categories of information when you use our Services:

  • Identifiers: Usernames, user IDs, and profile information provided by the platform; unique identifiers assigned by service providers such as Epic Online Services; Internet Protocol addresses; device and hardware identifiers.

  • Geolocation Data: General location information such as country and state derived from network or platform data.

  • Commercial Information: Records of purchases and transactions, including the purchase of the game itself through the Meta Quest Store, as well as in-game items, downloadable content, and related transaction history.

  • Internet or Network Activity: Information about gameplay sessions, multiplayer activity, in-game preferences and settings, language selections, and parental control settings.

  • Audio, Electronic, and Spatial Data: Motion and spatial tracking data, including head and hand positions, required to deliver mixed reality gameplay. Voice chat data transmitted for multiplayer communication in real time; FantaPass does not record or store voice chat.

  • Protected Classification Information: Age or age category (child, teen, or adult) as provided by the platform, to enforce age restrictions and comply with applicable law.

  • Support and Communications: Information voluntarily provided when contacting us for customer support, including your name, email address, and the content of your correspondence.

We do not knowingly collect sensitive categories of personal data such as financial account numbers, biometric identifiers, or health information.

3. How We Process Information

We process information as follows:

  • Identifiers and account information are processed to authenticate users, connect players in multiplayer sessions, and enable peer-to-peer networking.

  • Geolocation data is processed to determine regional access, comply with platform or legal restrictions, and monitor general usage by country or state.

  • Commercial information is processed to verify and fulfill purchases, deliver downloadable content, and maintain transaction records for accounting and compliance.

  • Gameplay and network activity are processed automatically to enable core game functions, track progress, manage session connectivity, and ensure parental and platform controls are applied.

  • Audio and spatial data are processed in real time to render mixed reality gameplay and support voice chat between players. Audio is transmitted but not recorded or retained by FantaPass.

  • Age information is processed to confirm eligibility to play and enforce restrictions such as blocking access to children under 13.

  • Support and communications are processed to respond to inquiries, provide assistance, and resolve technical or account issues.

4. Purposes of Processing

We use the information collected for the following purposes:

  • To provide, operate, and maintain our Services.

  • To process transactions and deliver purchased content.

  • To analyze, improve, and optimize gameplay and overall user experience.

  • To communicate with users regarding updates, notices, and support inquiries.

  • To protect the integrity and security of the Services, investigate abuse, and enforce our Terms of Service.

  • To comply with applicable laws, regulations, and legal obligations.

5. How We Share or Disclose Information

We understand the importance of keeping your personal information private. We do not sell your personal information to third parties. However, we may share information in the following circumstances, only to the extent necessary for the purposes outlined in this Privacy Policy:

  • With Service Providers and Partners: We engage third-party companies that provide services on our behalf or that help facilitate gameplay.

    • Platform Providers: When you access Superhero IRL or other FantaPass titles on Meta Quest, Meta Platforms has access to certain information about you and your use of the game, as governed by Meta’s privacy policies. We receive information from Meta such as your user ID, age category, and purchase confirmations to operate our Services. We may also share information back to Meta for purposes such as account verification, content distribution, or enforcement of platform rules.

    • Epic Online Services: Multiplayer sessions are supported by Epic Games’ Online Services. To establish peer-to-peer connections and enable voice chat, identifiers and networking information including IP addresses and EOS-assigned user IDs are processed by Epic. Epic uses this information only to provide connectivity and session support.

    • Cloud or Backend Service Providers: In addition to Epic, we may use other providers for data analytics, error logging, or cloud storage of non-sensitive data such as gameplay statistics or backups. These providers receive only the information necessary to perform their functions and are bound by contractual obligations to safeguard the data.

  • With Other Players: Because our Services include multiplayer functionality, certain information is inherently shared with other participants in your sessions. This includes your in-game profile such as username or display name, your avatar’s movements, and voice chat communications. Voice or text communications transmitted in-game are received by other players directly. Users should be mindful of the information they share during gameplay.

  • For Legal Reasons: We may disclose personal information if required to do so by law or in response to valid legal processes such as subpoenas or court orders. We may also disclose information if necessary to comply with legal obligations, protect the rights and safety of FantaPass or others, investigate and defend against claims, or prevent and stop illegal or unethical activity.

  • Business Transfers: In the event of a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, or transition of services, information may be disclosed or transferred to a successor or affiliate. Any such recipient will remain bound by similar privacy obligations.

  • With Consent: In all other cases, we will only share your personal information with third parties if you provide explicit consent.

6. Data Storage and Security

We take reasonable measures to protect personal information from unauthorized access, loss, misuse, or alteration. Safeguards include technical, administrative, and physical protections appropriate to the sensitivity of the data. Personal data transmitted during gameplay is encrypted in transit, and confidential information stored by us is maintained on secured servers.

Despite these measures, no system is entirely secure. We cannot guarantee absolute protection of your data, especially for transmissions over the Internet.

Personal information is primarily processed on your device and on our systems in the United States. If you are located outside the United States, your information may be transferred to jurisdictions with different data protection laws. We take steps to ensure appropriate safeguards are in place for such transfers, as required by applicable law.

We retain personal information as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. When information is no longer needed, we delete or anonymize it in accordance with our data retention procedures.

7. Your Rights and Choices

All users worldwide are entitled to the following rights regarding their personal information:

  • Right of Access: You may request confirmation of whether we process your personal information and obtain a copy of the information we hold.

  • Right of Correction: You may request correction of inaccurate or incomplete personal information. Account details held by Meta must be updated through Meta account settings; information we hold directly can be corrected by contacting us.

  • Right of Deletion: You may request deletion of your personal information. We will comply unless retention is required by law or necessary for security and integrity, such as detecting fraud or abuse. When you uninstall our games, we stop collecting new data. Minimal records, such as prior support communications or essential logs, may remain only for as long as legally required.

  • Right to Restrict Processing: You may request that we limit how your personal information is processed under certain circumstances.

  • Right to Object: You may object to specific processing activities, including the use of data for marketing or profiling.

  • Right to Data Portability: You may request your personal information in a structured, machine-readable format that can be transferred to another provider, where legally required.

  • Right to Withdraw Consent: You may withdraw consent where processing is based on consent. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

  • Marketing Preferences: You may opt out of marketing communications at any time.

  • Right to Non-Discrimination: You may exercise your privacy rights without being denied access to services, charged different prices, or receiving a lower quality of service.

These rights apply to all users globally. In addition, specific jurisdictions provide further protections:

  • California Residents (CCPA/CPRA):

    • You may request to know the categories of personal information collected, sources of collection, purposes of use, and categories of third parties with whom it is shared.

    • You may opt out of the sale or sharing of personal information. FantaPass does not sell personal data.

  • European Union and UK Residents (GDPR):

    • You may lodge a complaint with a Data Protection Authority.

    • You may refuse to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects without safeguards.

    • You may object to or restrict transfers of personal data outside the EEA or UK unless adequate protections are in place.

8. How to Exercise Rights

You may exercise your rights by contacting us at contact@fantapassmr.com with the subject line “Privacy Rights Request.”

We may require you to verify your identity before fulfilling requests, which may involve confirming details that match our records. Once verified, we will respond in accordance with applicable law.

9. Children’s Privacy

Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from anyone under 13. If you are under 13, you may not use Superhero IRL or any other FantaPass game.

If we learn that we have inadvertently collected personal information from a child under 13, we will promptly delete it. Parents or guardians who believe their child may have provided us with information should contact us at contact@fantapassmr.com.

For minors aged 13 and above but under the age of majority in their jurisdiction, parental consent may be required by law. Parents or guardians should review this Privacy Policy with their child. Certain features, such as voice chat, may also be restricted or disabled by default on the Meta platform for younger users.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material updates will be communicated within the Services or through other reasonable means. The “Last Updated” date reflects the latest revision. Continued use of the Services after changes take effect constitutes acceptance of the revised policy.

11. Contact Us

FantaPass MR Studio Inc.
Registered Office: 8 The Green, Suite B, Dover, DE 19901, USA
Office: 600 California St, Floor 12, Suite 039, San Francisco, CA 94108, USA
Email: contact@fantapassmr.com

12. Acknowledgment

By agreeing to our Terms of Service, or by installing, accessing, or using the Services, you acknowledge that you have read, understood, and agree to this Privacy Policy, and you consent to the collection, use, and processing of your information as described herein. If you do not agree, you should not use the Services.