Privacy Policy

1. Information We Collect

We collect information in three ways: information you provide directly, information collected automatically, and data transmitted through real-time communication features.

1.1 Information You Provide

• Display name or username entered when joining or creating a room;
• Messages or text content submitted through in-game chat or response inputs;
• Age declarations and consent confirmations, including for 18+ content;
• Feedback, bug reports, or communications sent to contact@floor63.com;
• Content submitted as part of game mechanics (captions, answers, personal facts).

1.2 Automatically Collected Information

• IP address and approximate geographic location derived from IP address;
• Device type, operating system, and browser type and version;
• Session identifiers and room codes associated with your session;
• Connection quality data, latency metrics, and technical performance information;
• Usage data including features used, time spent on the Platform, and error logs;
• Referral source.

1.3 Real-Time Communication Data

Floor63 enables live video and audio communication. With respect to real-time data:

• Live video and audio streams are transmitted in real time using WebRTC technology;
• Where direct peer-to-peer connections cannot be established, encrypted streams may be relayed through TURN servers solely to maintain connection quality;
• Floor63 does not record, store, or archive live video or audio streams unless explicitly notified in writing;
• We cannot guarantee that other participants will not record sessions using their own tools or devices.

Floor63 does not record your video or audio. Streams pass through relay servers only when technically necessary and are not retained after your session ends.

1.4 Information We Do Not Collect

We do not intentionally collect government-issued identification, payment card information, biometric data, precise GPS location data, or sensitive personal information beyond what is necessary to operate the Platform.

2. Legal Basis for Processing

For users in the EEA, UK, and other jurisdictions requiring a legal basis for data processing, we rely on the following grounds:

• Contractual Necessity: Processing necessary to provide Platform services including transmitting video/audio and enabling game sessions.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse prevention, and service improvement where not overridden by your fundamental rights.
• Legal Obligation: Processing required to comply with applicable laws including responding to valid legal requests.
• Consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

3. How We Use Your Information

3.1 Platform Operation

• To enable real-time video and audio communication between session participants;
• To generate and manage room codes and session states;
• To deliver game mechanics, prompts, and interactive features;
• To associate display names with in-session actions and scoring.

3.2 Safety and Abuse Prevention

• To detect, investigate, and respond to reports of abuse, harassment, or harmful conduct;
• To enforce our Terms of Service and community guidelines;
• To identify and prevent fraudulent, illegal, or unauthorised access;
• To protect the rights, property, and safety of users and third parties.

3.3 Platform Improvement

• To analyse usage patterns and improve Platform features and performance;
• To diagnose and resolve technical issues;
• To conduct research and analysis to understand user interactions.

3.4 Legal Compliance

• To comply with applicable laws, regulations, and legal processes;
• To respond to lawful requests from government authorities and law enforcement;
• To establish, exercise, or defend legal claims.

4. Children's Privacy

4.1 Users Under 13

Floor63 is not directed at or intended for use by children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will take immediate steps to delete such information.

If you are a parent or guardian and believe your child under 13 has used Floor63, please contact us immediately at contact@floor63.com with the subject line "Child Privacy Concern".

4.2 Users Aged 13 to 17

Users between the ages of 13 and 17 may use Floor63 with parental or guardian consent. Minor users are not permitted to access 18+ content under any circumstances.

If you believe a child has been exposed to harmful content on Floor63, please report it immediately to contact@floor63.com.

5. How We Share Your Information

5.1 We Do Not Sell Your Data

Floor63 does not sell, rent, or trade your personal information to third parties for their commercial purposes. This applies to all users regardless of location, including California residents under the CCPA/CPRA.

5.2 Service Providers

We share data with trusted third-party service providers who assist us in operating the Platform. These providers are bound by confidentiality obligations and data processing agreements and may only process your data on our behalf. Our service providers may include cloud infrastructure providers, WebRTC TURN/STUN server operators, analytics providers, security and fraud prevention services, and customer support tools.

5.3 Legal Disclosure

We may disclose your information without prior notice if required to do so by law or to comply with a legal obligation, protect and defend the rights or property of Floor63, prevent or investigate possible wrongdoing, protect user safety, or report child sexual exploitation material (CSAM) to appropriate authorities.

5.4 Business Transfers

If Floor63 is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify users of any such transfer and the successor entity will be required to honour this Privacy Policy unless a new policy is provided with reasonable notice.

6. International Data Transfers

Floor63 may operate infrastructure and service providers located in various countries. If your data is transferred outside of your home jurisdiction, we will ensure that appropriate safeguards are in place, such as standard contractual clauses approved by relevant data protection authorities, or other lawful transfer mechanisms as required by applicable law.

7. Data Retention

• Session Data: Technical session data is retained for a limited period for security monitoring purposes, after which it is deleted or anonymised.
• Display Names and Chat Content: In-session display names and chat content are generally not retained beyond the active session.
• Abuse and Safety Records: Where a user is suspended or banned, we may retain records of the violation to prevent re-registration and protect other users.
• Legal Hold: Where data is subject to a legal hold or dispute, we will retain such data until the matter is resolved.
• Live Streams: Live audio and video streams are not stored. They are transmitted in real time and are not retained after the session ends.

8. Security

We implement reasonable and appropriate technical and organisational measures to protect your personal data. Our security measures include encryption of data in transit using industry-standard TLS protocols, access controls limiting internal access on a need-to-know basis, regular review of our data handling practices, and use of vetted third-party infrastructure providers.

However, no system is completely secure. By using Floor63, you acknowledge and accept the inherent security risks of internet-based communication platforms. If you believe your data has been compromised, please contact us immediately at contact@floor63.com.

9. Your Privacy Rights

9.1 Rights Available to All Users

• Right to Access: Request confirmation of whether we hold personal data about you and receive a copy.
• Right to Correction: Request that we correct any inaccurate or incomplete personal data.
• Right to Deletion: Request that we delete your personal data, subject to legal obligations.
• Right to Object: Object to certain types of processing, including processing based on legitimate interests.

9.2 EEA, UK, and Swiss Users (GDPR / UK GDPR)

• Right to Data Portability: Receive your personal data in a structured, machine-readable format.
• Right to Restrict Processing: Request restriction of processing in certain circumstances.
• Right to Lodge a Complaint: Lodge a complaint with your local data protection supervisory authority.

9.3 California Residents (CCPA / CPRA)

California residents have the right to know what personal information is collected and how it is used; request deletion; opt out of the sale or sharing of personal information (Floor63 does not sell personal information); non-discrimination for exercising privacy rights; and correct inaccurate personal information.

9.4 South African Users (POPIA)

South African users have the right to access, correct, and request deletion of their personal information as provided under the Protection of Personal Information Act. You may also object to the processing of your personal information and have the right to lodge a complaint with the Information Regulator of South Africa.

9.5 Exercising Your Rights

To exercise any of the above rights, please contact us at contact@floor63.com with the subject line "Privacy Rights Request". We will respond within the timeframe required by applicable law (generally within 30 days). We may need to verify your identity before processing your request.

10. Cookies and Tracking Technologies

• Strictly Necessary Cookies: Required for the Platform to function, including session management and security features. These cannot be disabled.
• Performance and Analytics Cookies: Used to understand how users interact with the Platform and to improve performance. These are only placed where permitted by applicable law.

You may control cookie preferences through your browser settings. Disabling certain cookies may impact Platform functionality. Where required by law, we will request your consent before placing non-essential cookies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the Effective Date and, where practicable, provide notice through the Platform. Your continued use of Floor63 after changes constitutes acceptance of the updated Privacy Policy.