Privacy Policy
This Privacy Policy describes how user data is managed and processed within the standalone Virtual Reality (VR) video game “Lucky Shot” (hereinafter, the “Game”), distributed via the Meta Horizon Store platform.
Last updated: July 2026
1. Data controller
The Data Controller for personal data is:
- Company Name: ASSA S.R.L. (owner of the Vitruvio Virtual Reality brand)
- Registered Office: Via Emilia 482/d – 40068 San Lazzaro di Savena – Bologna, Italy
- Phone: +39 051790074
- E-mail: privacy@assa.bo.it
- Certified Email PEC: assa@legalmail.it
2. Age limits and protection of minors
Mature. Mature Themes
12 years. Legal Drugs, Inappropriate Language
Parental Guidance 15. Tobacco and Alcohol, Inappropriate Language
Teen. Use of Alcohol, Language
Refused Classification
PEGI 16 Use of Alcohol/Tobacco
12+
18+ Drugs, Language
16+ Use of Alcohol/Tobacco
3. Types of data collected and storage methods
The Game is a standalone VR application that does not have proprietary servers for storing user data. To ensure game functionality, we rely entirely on META’s cloud save system.
Through this system, the following data is stored and processed:
- Basic User Data: Unique Meta ID, username, and Meta profile avatar.
- Telemetry and Game Data: Total playtime, level progress, game statistics, and scores.
4. Purposes of processing
The aforementioned data is processed exclusively for purposes strictly related to the technical functioning and the user’s gaming experience, specifically for:
- Automatic saving of game progress in the cloud.
- Unlocking achievements.
- Managing and displaying game leaderboards.
Data processing is based on the execution of the end-user license agreement accepted by the user upon installing the Game (Art. 6, par. 1, let. b of the GDPR).
Data is retained for the entire duration of the Game’s use and for up to 30 days following a deletion request.
5. Specific declarations for Virtual Reality (spatial and movement data)
We recognize the importance of privacy in the context of Virtual Reality. In this regard, ASSA S.R.L. explicitly states the following:
- No recording of spatial data: The Game does not record, store, or transmit in any way data related to the user’s surrounding environment (room mapping or safety boundaries).
- No recording of movement data: The Game does not store or track raw biometric data related to the movements of the user’s body, hands (hand tracking), or eyes (eye tracking).
- No audio recording: The Game does not request microphone access and does not record conversations or voice data.
6. Third-party services and technologies used
The Game is developed and distributed using third-party technologies that may process data in accordance with their respective policies:
- Meta (Meta Horizon Store): Provides the distribution infrastructure, the VR ecosystem, and the data saving system linked to the user’s profile. For more information, please consult the Meta Privacy Policy.
- Unreal Engine (Epic Games): The Game was developed using the Unreal Engine graphic engine. The game engine itself does not collect personally identifiable user data during the standalone execution of the app.
7. User rights and data deletion
The GDPR (EU Regulation 2016/679) guarantees individuals full control over their personal data. Fundamental rights include:
- Right of access (Art. 15)
- Right to rectification (Art. 16)
- Right to erasure / Right to be forgotten (Art. 17)
- Right to restriction of processing (Art. 18)
- Right to data portability (Art. 20)
- Right to object (Art. 21)
The user also has the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).
Users have the right to access their game data or request its deletion at any time.
Since all data is stored on the Meta cloud save system linked to your account, you can request the deletion of Game-specific data or exercise your GDPR rights by sending an email to the Data Controller or to the dedicated technical support address:
Email for support and data deletion: meta@vitruviovirtualreality.com
Alternatively, the user can manage or delete application data directly within the settings of their Meta Quest headset or via the management panel of their Meta account.