privacy policy

privacy

Privacy Policy

Frame Labs Pty Ltd
Effective Date: 01.03.26
Last Updated: 28.02.26

Frame Labs Pty Ltd (“Frame Labs”, “we”, “us”, or “our”) develops and publishes interactive digital products, including virtual reality, mixed reality and related games, applications, demos, experiences, websites and support services.

This Privacy Policy explains how we collect, use, store, disclose and otherwise process personal information and other user data in connection with our games, apps, XR experiences and related services made available on Meta Quest and other platforms (collectively, the “Services”).

This Privacy Policy is intended to apply at the organisation level across all Frame Labs applications, games, experiences and related services, including any Meta Quest titles operated by us, unless a particular product includes a separate privacy notice.

By using our Services, you acknowledge that your information may be handled as described in this Privacy Policy.

1. Who we are

Frame Labs Pty Ltd
Website: www.framelabsxr.com.au
Email: privacy@framelabsxr.com.au
General contact: hello@framelabsxr.com.au

If you have any questions about this Privacy Policy or would like to make a privacy request, please contact us using the details above.

2. Scope of this Privacy Policy

This Privacy Policy applies to information collected or processed by Frame Labs in connection with:

  • our Meta Quest games, applications and immersive experiences;

  • our websites and landing pages;

  • customer support, community management and account enquiries;

  • newsletters, waitlists, promotional communications and events;

  • development, testing, analytics, security and operational support for our products.

This Privacy Policy does not apply to information collected solely by third parties that operate independently from us, including Meta Platforms, device manufacturers, app stores, payment providers, platform account providers, or third-party websites and services that may link to or integrate with our Services. Those parties may have their own privacy policies and terms.

3. The kinds of data we may process

Depending on the title you use, the features you access, your device settings, and the way you interact with our Services, we may process the following categories of data.

A. Contact and account information

We may process:

  • your name or username;

  • email address;

  • support ticket details;

  • social media handle if you contact us through social channels;

  • information you provide when joining a mailing list, beta program, giveaway, survey or community channel.

B. Platform, device and technical information

We may process technical information associated with your use of our Services, such as:

  • device type and model;

  • operating system and software version;

  • device identifiers;

  • app or build version;

  • crash logs, diagnostics and error reports;

  • IP address or approximate location inferred from IP address;

  • language, region and time zone settings;

  • network, performance and connection information.

C. Gameplay and usage information

We may process information about how you use our Services, including:

  • session dates and times;

  • gameplay progress and save data;

  • achievements, scores, level completion, missions, unlocks and preferences;

  • tutorial completion and feature usage;

  • multiplayer or matchmaking activity where relevant;

  • interactions with menus, controls, objects and gameplay systems;

  • general engagement metrics used to improve balancing, onboarding, comfort, accessibility and stability.

D. User-generated content and communications

If a Service permits it, we may process:

  • profile names;

  • messages sent to support;

  • bug reports and feedback submissions;

  • survey responses;

  • contest or community submissions;

  • voice or text communications where a game or feature includes these functions and where permitted by applicable law and platform settings.

E. XR, movement and interaction data

Some VR/MR experiences may process certain device-generated interaction data necessary to operate immersive features, such as:

  • controller inputs;

  • headset movement and orientation;

  • hand or gesture input where enabled;

  • spatial interaction events;

  • play boundary, room setup, anchors or scene understanding data if required by a particular experience and made available through the platform or device APIs.

Where this type of data is processed, we do so only for legitimate product functionality such as gameplay, interaction, comfort, safety, feature delivery, debugging or experience improvement, and only to the extent actually used by the relevant title.

F. Purchase, entitlement and transaction-related information

We may process limited transaction-related data, such as:

  • whether a user owns, installed or is entitled to access a title, expansion or feature;

  • transaction or order reference information supplied by the platform;

  • refund or support status.

We generally do not receive or store full payment card details when purchases are processed through platform providers such as Meta.

G. Marketing and communications information

If you opt in to receive marketing from us, we may process:

  • your email address;

  • subscription preferences;

  • records of whether communications were opened or interacted with, where lawful.

H. Information required for legal, compliance or security purposes

We may process information necessary to:

  • investigate abuse, cheating, fraud or security incidents;

  • enforce our Terms of Use or End User Licence Agreement;

  • comply with legal obligations, law enforcement requests or regulatory requirements;

  • protect our rights, users, staff, contractors and business operations.

4. How we collect data

We may collect data:

  • directly from you, such as when you contact support, submit feedback, join a mailing list, complete a form, or otherwise communicate with us;

  • automatically from your use of our Services, such as gameplay telemetry, device information, crash reporting and analytics;

  • from platform partners and service providers, such as Meta or other storefront/platform operators, who may provide entitlement, account-linked, support or device-related information;

  • from community tools or marketing platforms, where you sign up to receive updates or participate in promotions;

  • from testing and QA environments, if you participate in alpha, beta or user-testing programs.

5. Why we process data

We process user data for the following purposes:

To provide and operate our Services

Including to:

  • deliver gameplay and app functionality;

  • authenticate access and verify entitlements;

  • save progress and preferences;

  • enable multiplayer, social or community features where offered;

  • provide updates, patches and content.

To maintain, secure and improve our products

Including to:

  • diagnose bugs, crashes and performance issues;

  • understand how users engage with features;

  • improve usability, comfort, accessibility and onboarding;

  • optimise game balance, difficulty and design;

  • test, develop and refine existing and future products.

To communicate with users

Including to:

  • respond to support requests and privacy enquiries;

  • provide technical assistance;

  • send service-related notices;

  • send newsletters or marketing communications where you have opted in or where otherwise permitted by law.

To protect users and our business

Including to:

  • detect and prevent fraud, abuse, cheating, unauthorised access and harmful activity;

  • enforce our policies, terms and rights;

  • protect the integrity and security of our Services, systems and community spaces.

To comply with legal obligations

Including to:

  • respond to lawful requests from regulators, courts or law enforcement;

  • comply with record-keeping, accounting, tax and corporate obligations;

  • establish, exercise or defend legal claims.

6. Legal bases for processing

Where applicable under relevant privacy laws, we process information on one or more of the following bases:

  • performance of a contract with you, including providing the Service you requested;

  • our legitimate interests, such as improving, securing and administering our Services;

  • your consent, where required by law;

  • compliance with legal obligations.

7. How long we retain data

We retain data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, resolve disputes, enforce agreements, comply with legal obligations, and maintain appropriate business and security records.

Retention periods may vary depending on:

  • the nature of the data;

  • the title or feature involved;

  • whether the data is required for support, safety, security or legal compliance;

  • whether deletion has been requested and is technically feasible without undermining lawful obligations or core service records.

We may also de-identify or aggregate information so that it can no longer reasonably identify a user and use that information for analytics, research and product improvement.

8. When we share data

We do not sell personal information in the ordinary sense of selling customer lists for money. We may share data in the following circumstances.

With service providers and contractors

We may share information with trusted vendors, consultants, developers, analytics providers, hosting providers, cloud infrastructure providers, CRM/email tools, customer support providers, QA testers and similar service providers who process information on our behalf for the purposes described in this Privacy Policy.

With platform and distribution partners

We may receive data from, and share limited data with, platform operators and partners such as Meta where necessary to publish, operate, support, secure or improve our Services.

With affiliated companies or project partners

In some cases, Frame Labs may collaborate with publishers, licensors, co-developers, investors, distributors or project partners. We may share information where reasonably necessary to operate, support, market, analyse or deliver a product, subject to contractual and legal safeguards.

For legal and safety reasons

We may disclose information where reasonably necessary to:

  • comply with applicable law, regulation, court order or lawful request;

  • investigate fraud, security incidents or violations of our terms;

  • protect the rights, property or safety of Frame Labs, our users or others.

In a business transaction

If Frame Labs undergoes a merger, acquisition, investment transaction, restructuring, sale of assets or similar corporate event, user information may be disclosed to relevant parties subject to appropriate confidentiality and legal safeguards.

9. International data transfers

Frame Labs is based in Australia, but our service providers, infrastructure partners and collaborators may be located in other countries. As a result, your information may be stored or processed outside your country of residence, including in countries that may have different data protection laws.

Where required, we take reasonable steps to ensure that overseas recipients handle data in a manner consistent with applicable privacy laws and with appropriate safeguards.

10. Analytics, diagnostics and similar technologies

We may use analytics, crash reporting, telemetry and diagnostic tools to understand how our Services perform and how users engage with them. These tools may process technical and usage information such as device details, session information, crash logs, feature interaction data and approximate location derived from IP address.

We use this information to:

  • maintain service stability;

  • troubleshoot technical issues;

  • understand user engagement;

  • improve product design and performance;

  • inform updates and future development.

Where required by law, we will seek consent before using certain analytics or marketing technologies.

11. Children’s privacy

Our Services are not intended to collect personal information from children in breach of applicable law. Some Frame Labs titles may be suitable for broad audiences, but users must comply with the age requirements, account terms and parental supervision requirements of the relevant platform.

If we become aware that we have collected personal information from a child in a manner inconsistent with applicable law, we will take reasonable steps to delete that information or otherwise comply with legal requirements.

Parents or guardians who believe a child has provided us with personal information should contact us at privacy@framelabsxr.com.au.

12. Sensitive data, biometrics and voice data

Frame Labs does not intentionally collect or retain sensitive biometric identifiers unless a specific product feature requires it and such processing is clearly disclosed and lawful.

Some XR features may involve hand input, body movement, spatial interaction or voice-related functionality. If a title uses such features:

  • we will only process the information necessary to provide the feature;

  • we will not use it for unrelated purposes unless separately disclosed and permitted by law;

  • we will apply reasonable safeguards appropriate to the nature of the data.

If a title includes voice chat, voice commands, or similar features, additional title-specific notices may apply.

13. Security

We take reasonable technical, organisational and administrative measures to protect information against loss, misuse, unauthorised access, disclosure, alteration and destruction. These measures may include access controls, encryption in transit where appropriate, secure hosting environments, vendor management and role-based restrictions.

However, no system can be guaranteed to be completely secure, and we cannot guarantee absolute security.

14. Your rights and choices

Depending on where you live, you may have rights in relation to your personal information, including the right to:

  • request access to personal information we hold about you;

  • request correction of inaccurate or incomplete information;

  • request deletion of personal information;

  • object to or request restriction of certain processing;

  • withdraw consent where processing is based on consent;

  • request a copy of certain information in a portable format, where applicable;

  • lodge a complaint with a privacy regulator.

We will respond to requests in accordance with applicable law.

15. How to request deletion of your data

Users may request deletion of personal data processed by Frame Labs by contacting us at:

privacy@framelabsxr.com.au
Subject line: Data Deletion Request

To help us process your request, please include:

  • your name;

  • the email address associated with your enquiry, if any;

  • the name of the game, app or experience;

  • your platform username or account identifier, if relevant;

  • details of the information you want deleted.

We may need to verify your identity before acting on a request.

Please note:

  • some information may need to be retained for legal, security, fraud prevention, transaction, backup or compliance reasons;

  • if data is stored solely by a platform provider such as Meta, you may also need to contact that provider directly or use their account controls;

  • if deletion affects saved progress, entitlements, multiplayer records or support history, some functionality may be impacted.

If a title includes a self-service deletion or account reset feature, that feature may also be used where available.

16. Access and correction requests

If you want to access, update or correct personal information we hold about you, please contact:

privacy@framelabsxr.com.au

We may take reasonable steps to verify your identity before responding.

17. Marketing communications

If you subscribe to receive marketing or newsletters from Frame Labs, you can unsubscribe at any time by:

We may still send non-promotional communications where necessary for service, transactional or legal purposes.

18. Third-party links and services

Our Services or websites may contain links to third-party services, websites, SDKs, platforms, storefronts or social channels. We are not responsible for the privacy practices of those third parties. We encourage users to review their privacy policies before interacting with them.

19. Region-specific notice for Australian users

Frame Labs is subject to applicable Australian privacy laws, including the Privacy Act 1988 (Cth) where applicable. If you are in Australia and have concerns about how we handle your personal information, please contact us first so we can try to resolve the issue.

If you are not satisfied with our response, you may be able to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

20. Region-specific notice for users in other jurisdictions

If laws in your jurisdiction provide additional privacy rights, we will handle personal information in accordance with those laws to the extent applicable. This may include rights relating to access, deletion, objection, portability, appeal or complaint.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our products, services, legal obligations or privacy practices. When we do, we will update the “Last Updated” date above. If changes are material, we may provide additional notice where appropriate.

The current version of this Privacy Policy will be made publicly available on our website via a secure and accessible URL.

22. Contact us

For privacy questions, requests or complaints, contact:

Frame Labs Pty Ltd
Website: www.framelabsxr.com.au
Email: privacy@framelabsxr.com.au
General enquiries: hello@framelabsxr.com.au