Privacy Policy

Last Updated: September 25, 2025

RevelVR INC ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use Blobtown (the "Game") and any related services (collectively, the "Services") distributed via the Meta Horizon platform. By accessing or using our Services, you agree to this Privacy Policy and the Meta Horizon Developer Data Use Policy. If you do not agree, please do not use the Services.

This Privacy Policy is publicly available at http://blobtown.com/privacy-policy and complies with the Meta Horizon Developer Data Use Policy and applicable privacy laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and Children's Online Privacy Protection Act (COPPA).

1. Information We Collect

We collect the following types of information, including User Data (Meta Horizon User Data and Device User Data) and Developer User Data, as defined by the Meta Horizon Developer Data Use Policy:

Meta Horizon User Data:

• Meta Account ID: Used to create and manage your game account.
• Display Name and Username: Collected from the Meta Horizon platform.
• Profile Information: Limited to data provided via Meta Horizon APIs, such as avatars or friends data, where applicable.

Device User Data:

• Gameplay Data: Includes scores, customization settings, virtual currency balance (Blobium), in-game purchases, user-generated content, challenge progress, and other gameplay statistics.
• Abstracted Sensor Data: Limited to data necessary for gameplay, such as abstracted hand or body data, processed in compliance with Meta's policies.

Developer User Data:

• Voice Data: We may record and temporarily store voice chat interactions for moderation purposes, associated with your user ID to enforce community guidelines.

We obtain user consent or rely on appropriate legal bases for collecting and processing this data, as required by applicable law. For users under 13, we rely on Meta's parent-managed account mechanisms for consent.

2. How We Use Your Information

We use your information, including User Data, solely for the purposes permitted by the Meta Horizon Developer Data Use Policy:

Providing and Improving Services:

• To create and manage your account, enable core game functionalities (e.g., multiplayer features), and personalize your experience.
• To analyze aggregated, de-identified, or anonymized gameplay data to improve the Game, ensuring no individual user or device can be identified.

Moderation and Safety:

• To enforce community guidelines and ensure a safe environment by reviewing voice data and gameplay activity for violations.
• To process user reports or complaints regarding behavior in the Game.

Legal Compliance:

• To comply with applicable laws and regulations, such as responding to legal requests or ensuring COPPA compliance.

We do not use User Data for marketing, advertising, profiling, surveillance, or any prohibited purposes outlined in Section 4 of the Meta Horizon Developer Data Use Policy. We do not collect or use Advertising IDs for any purpose.

3. Disclosure of Your Information

We share your information only as permitted by the Meta Horizon Developer Data Use Policy:

Service Providers:

• GGWP: Acts as a Data Processor under GDPR for moderation purposes. We share usernames, user IDs, voice chat recordings, gameplay activity, and reports or complaints with GGWP to enforce community guidelines. GGWP processes data under our instructions, retains data for up to six months, and complies with this Privacy Policy and Meta's policies. We do not share personal data of users under 13 with GGWP.
• StayPro: Acts as a Data Processor under GDPR for voice moderation purposes.
• Normcore: Facilitates real-time multiplayer interactions, processing transient data (e.g., IP addresses, connection timestamps) necessary for gameplay. Normcore does not store data long-term and complies with this Privacy Policy and Meta's policies. We do not share personal data of users under 13 with Normcore.
• Advertising ID: We do not collect, use, or share Advertising IDs with any Service Providers or third parties.

All Service Providers are bound by written agreements that limit their use of User Data to providing services on our behalf, prohibit violations of this Privacy Policy, require data deletion upon termination of services, and mandate security and confidentiality.

Legal Requirements: We may disclose your information if required by law or in response to valid legal requests, retaining proof of such requirements.

User Consent: We share User Data with third parties only with your express consent or direction, retaining proof of such consent.

We do not sell, license, rent, or lend User Data, nor do we combine User Data with other data except as permitted by Meta's policies.

4. Data Security

We maintain administrative, physical, and technical safeguards that:

• Meet or exceed industry standards for the sensitivity of User Data.
• Comply with applicable data security and privacy laws.
• Prevent unauthorized access, destruction, loss, alteration, disclosure, or compromise of User Data.

We provide an accessible method for reporting security vulnerabilities at admin@revelvr.com and promptly address identified issues. In case of unauthorized processing or security incidents, we will notify Meta and affected users as required and begin immediate remediation.

5. Data Retention and Deletion

We retain data only as long as necessary to provide the Services or comply with legal obligations:

• Voice Data: Retained temporarily for moderation purposes, typically up to six months.
• Other Data: Retained while your account is active or as needed for the Services, unless deletion is requested or required.

We delete User Data, and ensure our Service Providers delete User Data, without undue delay when:

• You request deletion.
• Your account is deleted or inactive, unless the data is de-identified.
• The data is no longer necessary for the Services.
• Deletion is requested by Meta or required by law.

All users, regardless of region, can request data deletion or correction by contacting admin@revelvr.com. We provide an easily accessible and clearly marked method for these requests within the Game.

Service Provider Oversight:

• We maintain agreements with Service Providers (e.g., GGWP, Normcore) to ensure compliance with this Privacy Policy and Meta's policies. Upon Meta's request, we will provide contact information for our Service Providers, details of the types of data shared, and copies of our agreements with them.
• If Meta prohibits the use of a Service Provider, we will immediately cease using that Service Provider and ensure compliance with Meta's requirements, including data deletion where applicable.

6. Children's Privacy

Under Age 10: The Game is not intended for children under 10. We do not knowingly collect personal information from children under 10. If we become aware of such data, we will delete it immediately.

Users Aged 10 to Under 13: We support parent-managed Meta child accounts for users aged 10 to under 13, relying on Meta's age verification and parental consent mechanisms for COPPA compliance. We collect only the minimum data necessary for the Services (e.g., gameplay data, display names) and do not share personal data of users under 13 with third-party services like GGWP or Normcore.

Parental Rights: Parents managing Meta child accounts can review, delete, or refuse further collection of their child's data by contacting admin@revelvr.com.

COPPA Compliance: We comply with COPPA. If you believe we have collected data from a child under 13 without parental consent, contact us at admin@revelvr.com.

7. Your Rights

All users, regardless of region, have the following rights:

• Access and Portability: Request access to or a copy of your data.
• Correction and Deletion: Request correction or deletion of your data.
• Objection and Restriction: Object to or restrict processing of your data.
• Consent Withdrawal: Withdraw consent for data processing.

To exercise these rights, contact admin@revelvr.com or use the in-Game tools provided for data requests. For EEA users, these rights are guaranteed under GDPR. For California residents, additional rights apply under the CCPA.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States. For transfers of Meta Ireland Data (personal data controlled by Meta Platforms Ireland Limited) outside the EEA, we comply with the Standard Contractual Clauses (Module One) as annexed to European Commission Decision (EU) 2021/914. For transfers of UK Data subject to the UK GDPR, we comply with the UK International Data Transfer Addendum. Contact admin@revelvr.com for details on these safeguards.

9. Compliance with Meta Horizon Developer Data Use Policy

We comply with the Meta Horizon Developer Data Use Policy, including:

• Content Review: Submitting our Content for Meta's review to ensure compliance before accessing Meta Horizon User Data.
• Annual Certification: Certifying compliance with Meta's policies annually via the Data Use Checkup.
• Audits: Cooperating with Meta's audits of our IT systems and records to verify compliance, with at least 10 business days' notice unless urgent.
• Service Provider Oversight: Maintaining agreements with Service Providers (e.g., GGWP, Normcore) to ensure compliance and providing Meta with their contact information upon request.

We do not use User Data for prohibited practices, such as surveillance, profiling, or unauthorized data combination, and we protect user IDs, access tokens, and app secrets.

10. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting the updated Policy within the Game and at http://blobtown.com/privacy-policy, and updating the "Last Updated" date. Your continued use of the Services after such changes constitutes your agreement to the updated Policy.

11. Contact Us

For questions, concerns, or to exercise your rights, contact us at:

Email: admin@revelvr.com

We maintain up-to-date contact information with Meta to respond to data deletion requests and compliance inquiries.

12. Legal Disclaimer

This Privacy Policy is provided for informational purposes and does not constitute legal advice.

Your privacy is important to us, and we are committed to safeguarding your personal information in compliance with the Meta Horizon Developer Data Use Policy and applicable laws. Thank you for choosing Blobtown!

Note: By using Blobtown, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and the Meta Horizon Developer Data Use Policy.