Damp Gnat Privacy Policy
Version 0.6 June 2026
Last Updated: 16/06/2026
Damp Gnat Ltd (“we”, “us”, “our”) is committed to protecting your personal data and being transparent about how we use it. This privacy policy explains what information we collect, how we use it, and your rights under UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
This privacy policy applies to all Damp Gnat games and applications, including our VR/MR title Charlie Bravo SOS and any future immersive titles we release.
This policy applies to:
- our website (www.dampgnat.com)
- our VR, AR and Mixed Reality (MR) games and applications
- our mobile and desktop applications
- our mailing lists and marketing communications
- any services we provide online or offline
1. Who we are
Damp Gnat Ltd
Registered in England & Wales
Registered address: 12a Marlborough Place, Brighton, East Sussex, BN1 1WN
Email: info [at] dampgnat [dot] com
We are the data controller for the personal data described in this policy.
2. The types of data we collect
We only collect the data that is necessary for our games, website and services to function, to keep them secure and to understand how they are used. We do not collect more information than we need for these purposes.
2.1 Website visitors
- IP address
- Browser type and version
- Device information
- Pages visited and interactions
- Cookies and analytics data
2.2 Mailing list subscribers
- Name
- Email address
- Marketing preferences
- Interaction data (opens, clicks)
2.3 VR, AR and MR game players
Our applications run on a wide range of virtual reality (VR), augmented reality (AR), mixed reality (MR) and mobile devices. This includes current, legacy and future headsets, controllers, smartphones and spatial computing platforms provided by manufacturers such as Meta, PICO, Apple, Google, Samsung, Valve, Sony, HTC and others.
Depending on the device and features used, we may process:
Tracking and interaction data
- head, hand and controller position/orientation
- gesture recognition
- interaction events
- room‑scale boundaries and guardian/chaperone systems
Spatial and environmental data (MR/AR)
- plane detection
- anchors
- depth maps
- occlusion data
- scene understanding
- environmental meshes (including GlobalMesh)
Our applications may generate a spatial mesh of the player’s environment (such as GlobalMesh) to enable mixed‑reality gameplay features. In some cases, this reconstructed mesh is transmitted securely to our Firebase server so that we can process, store or synchronise environment data required for gameplay.
We do not transmit or store raw passthrough camera frames. All passthrough imagery is processed on‑device.
Gameplay and behavioural data
- in‑game actions
- progression
- interaction patterns
- comfort settings
Device and performance data
- device model
- operating system
- SDK version
- performance metrics (frame rate, thermal events)
- crash logs and diagnostics
Voice and communication features (if applicable)
If a game includes voice chat or voice‑based features, audio is processed only to provide that feature.
We do not use voice data for advertising, profiling or biometric identification.
2.4 Platform‑level data collection
Platform providers such as Meta, PICO, Apple, Google, Samsung, Valve, Sony and HTC may independently collect device identifiers, performance data, usage analytics, spatial mapping information or other telemetry as part of their system‑level operation.
We do not control this processing and recommend reviewing the relevant platform’s privacy policy.
3. How we use your data (purposes)
To provide and operate our games and services
- gameplay functionality
- spatial interaction
- environment reconstruction
- synchronising or persisting spatial meshes (e.g., GlobalMesh)
- safety boundaries
- device compatibility
To improve performance and stability
- crash reporting
- diagnostics
- optimisation
To understand how players use our games
- analytics
- feature usage
- interaction patterns
To communicate with you
- responding to enquiries
- sending updates (with consent)
- customer support
To comply with legal obligations
- financial record‑keeping
- responding to lawful requests
We do NOT use your data for:
- third‑party advertising
- ad networks
- data brokerage
- building marketing profiles of individual players
4. Lawful bases for processing
We rely on the following lawful bases under UK GDPR:
Contract
To provide you with the game or service you have downloaded or accessed.
Legitimate interests
For:
- analytics
- crash reporting
- security
- improving our games
- preventing misuse
- processing spatial meshes required for gameplay
We balance these interests against your rights and expectations.
Consent
For:
- marketing emails
- non‑essential cookies
- optional analytics (where applicable)
You can withdraw consent at any time.
Legal obligation
For financial records and compliance.
5. Cookies and similar technologies
We use cookies and similar technologies on our website for:
- essential site functionality
- analytics
- remembering preferences
Non‑essential cookies are only used with your consent, in line with PECR.
You can change your cookie settings at any time.
6. Who we share data with
We may share data with trusted service providers who help us operate our services, such as:
- website hosting providers
- email and mailing list platforms
- analytics providers
- crash reporting services
- cloud storage providers
- Firebase (for storing and processing reconstructed spatial meshes such as GlobalMesh)
These providers only process data on our instructions and are bound by confidentiality and data protection obligations.
We do not sell your data.
We do not share your data with advertisers or ad networks.
7. International transfers
Some of our service providers (e.g., Unity, Google, Meta, Amazon Web Services, Firebase) may process data outside the UK.
Where this happens, we use approved safeguards such as:
- the UK International Data Transfer Agreement (IDTA)
- Standard Contractual Clauses (SCCs)
- adequacy regulations
8. Data retention
We keep data only for as long as necessary:
- Mailing list data — until you unsubscribe
- Analytics data — typically 24–36 months
- Crash logs — up to 24 months
- Gameplay data — varies by title; only retained as long as needed for functionality
- Spatial meshes (e.g., GlobalMesh) — retained only for as long as required for gameplay features such as environment persistence, synchronisation or reconstruction
9. Children’s data
Our games are not designed for children under the minimum age required by the relevant platform.
We do not knowingly collect children’s personal data.
If you believe a child has provided us with personal data, please contact us.
10. Your rights
You have the following rights under UK GDPR:
- access your data
- correct inaccurate data
- request deletion
- restrict processing
- object to processing
- data portability
- withdraw consent
- lodge a complaint with the ICO
You can request deletion of your personal data at any time using the in‑app “Delete My Data” option. When you press this button, all information associated with your account is automatically and permanently removed from our systems. This includes gameplay data, analytics data, spatial meshes (such as GlobalMesh), logs, and any bug reports you have submitted.
We do not maintain separate backups, so once deleted, your data cannot be recovered.
Information Commissioner’s Office (ICO)
Telephone: 0303 123 1113
11. Security
We use appropriate technical and organisational measures to protect your data, including:
- encryption in transit
- secure servers
- access controls
- secure storage of spatial meshes (e.g., GlobalMesh) on Firebase with restricted access
- local‑only processing for passthrough camera data
We do not use biometric identification.
12. Changes to this policy
We may update this policy from time to time.
The latest version will always be available on our website.
If new device capabilities introduce additional categories of data, we will update this policy to reflect how those features are used within our applications.