Privacy Policy

Last Updated: 14 June 2026

1. Introduction

This Privacy Policy explains how Colin Frank (“we”, “us”, “our”) collects, uses, and protects information in connection with games, interactive experiences, and applications we develop.

We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.


2. Data Controller

The data controller responsible for the processing described in this Privacy Policy is:

Colin Frank
Contact: https://www.colinfranksounding.com/contact/
Website: https://www.colinfranksounding.com/


3. Information We Collect

Depending on the features of a given application, we may collect or process the following categories of information:

  • User or platform identifiers provided by third-party platforms (e.g. account or session identifiers)
  • Session identifiers used for multiplayer or networked functionality
  • Spatial or positional data used to support real-time or mixed-reality interactions
  • Spatial anchor or coordinate system data used for shared spatial alignment
  • Device and network information required for connectivity and synchronisation
  • Technical data such as error logs, performance metrics, and diagnostic information

We do not intentionally collect sensitive personal data such as financial information, private communications, or media files.


4. How We Use Information

We use information only where necessary to operate and improve our applications, including to:

  • Enable multiplayer and networked interactions
  • Support shared spatial or real-world alignment between users
  • Synchronise interactive content across devices
  • Maintain application stability and performance
  • Diagnose and resolve technical issues
  • Ensure secure and reliable network communication

We do not use personal data for advertising, profiling, or automated decision-making.


5. Legal Basis for Processing

Where UK GDPR applies, we rely on the following lawful bases for processing personal data:

  • Performance of a contract (to provide the application functionality requested by the user)
  • Legitimate interests (to operate, maintain, and improve our applications)
  • Legal obligation (where processing is required by law)
  • Consent (where explicitly required for specific features or platforms)

6. Data Sharing and Third Parties

We may share or process data using third-party service providers where necessary to operate our applications.

These may include:

Meta Platforms Technologies

Photon Engine GmbH (Photon Fusion)

We do not sell or rent personal data to third parties.


7. Data Retention

We retain personal data only for as long as necessary to provide the relevant application functionality or to comply with legal obligations.

In general:

  • Multiplayer session data is processed in real time and is not stored long-term
  • Spatial alignment data is used temporarily for session synchronisation
  • Diagnostic logs, where collected, are retained only for troubleshooting purposes

Retention periods may vary depending on the specific application and technical requirements.


8. International Data Transfers

Some third-party providers may process data outside the United Kingdom. Please refer to the data policies of third-party providers in these instances.


9. Your Rights

Under UK data protection law, you may have the right to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion of your data
  • Restrict or object to processing
  • Withdraw consent where processing is based on consent
  • Request information about how your data is processed

To exercise these rights, please contact us using the details below.


10. Children’s Privacy

Our applications are not intended for use by children below the minimum age required by applicable platform policies and laws.

We do not knowingly collect personal data from children outside these requirements.


11. Security

We implement reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction.

However, no method of transmission or storage is completely secure.


12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date.


13. Contact Information

For questions about this Privacy Policy or to exercise your data protection rights, please use the contact form on our website:

https://www.colinfranksounding.com/contact/