Privacy Policy

PRIVACY POLICY

TINY FLOCK

Last updated: 2026 September 4th

1. Who We Are

Tiny Flock (“the Game”) is developed and published by UAB No Brakes Games, a company registered in Lithuania, with its registered office at Ukmergеs st. 126, Vilnius, Lithuania (“we”, “us”, “our”). We are the data controller for the purposes of the EU General Data Protection Regulation (GDPR) with respect to any personal data described in this Policy.

Contact for privacy questions: privacy@nobrakesgames.com

2. Scope of This Policy

This Policy explains what happens to information in connection with your use of the Game on Steam (PC) and Meta Horizon Store (Meta Quest). It covers:

  • What the Game itself collects, processes, or stores.
  • What the platforms you play on (Valve/Steam and Meta) collect on their own behalf.
  • How VR-specific sensor data, such as hand tracking, is used.
  • How the Game uses the Meta Platform SDK for achievements, cloud saves, and age category detection.

This Policy does not cover the practices of Valve Corporation or Meta Platforms, Inc., which are governed by their own privacy policies, linked in Section 7.

3. Information the Game Itself Collects

By design, Tiny Flock does not require its own account, does not include multiplayer, online matchmaking, voice chat, or friend lists, and does not use any third-party analytics, advertising, or crash-reporting SDK of our own. As a result, we do not directly collect, transmit, or store:

  • Names, email addresses, or account credentials of our own.
  • Gameplay analytics or telemetry sent to our own servers.
  • Voice, chat, or social data.
  • Location data.

Local save data not synced via Meta’s cloud save (see Section 4) is stored only on your device and is not accessible to us. The one exception to the “no third-party SDK” principle above is our use of the Meta Platform SDK, described next.

4. Meta Platform SDK: What We Collect and How We Use It

Tiny Flock is self-certified with Meta as a Mixed Ages app — intended for both children under 13 (ages 10–12) and teen/adult users (13+) — as required for its listing on the Meta Horizon Store. To support that, the Game integrates three features of the Meta Platform SDK. For each, we set out exactly what data is involved and the single purpose we use it for. We do not use any of this data for advertising, profiling, analytics, or any purpose beyond what is listed below, and we do not operate a server of our own that receives, views, or stores any of it — it is sent from your headset directly to Meta’s systems through the SDK.

Achievements

Data collected: your Meta account ID (a unique account identifier), plus which in-game achievement was unlocked and when.

How it’s used: solely to record the unlock against your Meta account so it displays in your Meta profile and headset achievement list. Not used for anything else.

Cloud Backup (save data)

Data collected: your Meta account ID, together with your save file (game progress and in-game settings).

How it’s used: solely to back up and restore your progress across devices signed in to the same Meta account (for example, after reinstalling the Game or switching headsets). Not used for anything else.

Age Category

Data collected: a coarse age category linked to your Meta account — child (ages 10–12), teen (13–17), adult (18+), or unknown. We never receive your exact date of birth.

How it’s used: solely to determine which Platform SDK features and experiences are appropriate to enable for your account, consistent with Meta’s own age-based feature limitations for younger players. Not used for anything else.

No separate account, login, or registration with us is required for any of the above; the identifier used throughout is the Meta account you already use to access the headset.

Meta Data Use Checkup: because these are Platform SDK features subject to Meta’s Developer Data Use Policy, our use of them is certified through Meta’s Data Use Checkup (DUC) process, and this Policy is the privacy policy submitted and reviewed as part of that certification.

5. How to Request Deletion of Your Data

Any user, in any region, may request deletion of the data described in this Policy at any time, free of charge, as follows:

  • Cloud Backup / save data — self-service: while signed in to your Meta account, go to the Cloud Backups page at secure.oculus.com/my/cloud-backup on a computer, find Tiny Flock, and select Delete. This permanently removes your stored backup from Meta’s servers. Uninstalling the Game and clearing local app data on your headset removes the on-device copy.
  • Achievements — achievement records are stored by Meta, not us. You can request deletion through Meta’s Accounts Center privacy tools or by contacting Meta Support directly, or you can email us at privacy@nobrakesgames.com and we will help you submit the request to Meta.
  • Age category — this value is managed entirely by Meta through your account settings; it is not stored by the Game or by us.
  • Data we hold ourselves — for anything you’ve sent us directly (e.g., support emails), email privacy@nobrakesgames.com with “Delete my data” in the subject line, and we will delete it within 30 days.

We do not charge a fee for any deletion request and do not condition deletion on your region or any other characteristic. If a request cannot be fulfilled for a specific legal reason (for example, data we must retain briefly to comply with law), we will tell you why.

6. Hand Tracking and Other VR Sensor Data

The Game uses hand tracking to let you interact with the virtual environment using your hands instead of, or alongside, controllers. Specifically:

  • Hand tracking data is processed locally, on your headset, in real time.
  • This data is used only to render your hand movements in the Game and is never transmitted to us, stored, or shared with any third party — including as part of the achievement, cloud save, or age category data described in Section 4.
  • No eye tracking, face tracking, or body/health biometric data is collected by the Game.

Note: the Meta Quest operating system itself may process additional sensor data (e.g., for Guardian/boundary safety, controller-free hand tracking at the OS level) independently of our Game, governed by Meta’s own privacy policy — see Section 7.

7. Information Collected by Platforms

Steam and Meta act as independent data controllers for the accounts, purchases, and platform-level data associated with your use of their storefronts and hardware. We do not have access to this data beyond what is described in Section 4, unless you separately share it with us (e.g., by writing to our support email).

Platform What they may collect / their policy
Valve / Steam Account data, purchase history, playtime, achievements, and Steam Cloud saves, per the Steam Privacy Policy.
Meta / Meta Quest Meta Horizon account data, headset usage, Guardian/room-scale setup, plus the achievement, cloud save, and age category data the Game requests via the Meta Platform SDK (Section 4), per the Meta Privacy Policy and Meta Horizon OS data practices.

 

8. Children’s and Mixed-Audience Privacy

Tiny Flock is self-certified with Meta as a Mixed Ages app and may be played by children as young as 10 (Meta does not permit users under 10 on its platform at all). Because the Game requests the Get Age Category API described in Section 4, we receive a coarse age signal (child, teen, adult, or unknown) from Meta for each player, without receiving an exact birthdate. We use this signal to determine which Platform SDK features are available to a given player, consistent with Meta’s own age-based feature limitations for child users.

The Game does not otherwise implement its own account creation, registration, or independent age-verification mechanism — age category comes solely from the Meta account already set up for the headset, under Meta’s own age requirements and parental supervision tools (including parent-managed accounts for players aged 10–12).

We remain responsible for complying with applicable child-privacy laws — including COPPA in the U.S. and GDPR in the EU — for players identified as children, regardless of Meta’s own certification. If you are a parent or guardian and believe your child has provided us with personal data outside of the platform account and SDK systems described above (for example, by emailing our support address), please contact us and we will delete it.

9. Legal Basis for Processing (GDPR)

Where you contact us directly (e.g., support requests, bug reports sent by email), we process the personal data you provide (such as your email address) on the basis of:

  • Your consent (Art. 6(1)(a) GDPR), given by contacting us; or
  • Our legitimate interest in providing customer support and improving the Game (Art. 6(1)(f) GDPR).

Achievement, cloud save, and age category data described in Section 4 is processed by Meta as an independent controller, under the legal basis set out in Meta’s own privacy policy.

10. Data Retention

We retain support correspondence only for as long as necessary to resolve your inquiry and for a reasonable period afterward for record-keeping, typically no longer than 24 months. We do not retain gameplay, achievement, save, or age category data ourselves, since none of it is transmitted to or stored by us.

11. Your Rights

If you are in the European Economic Area, UK, or a jurisdiction with similar data protection laws, you have the right to:

  • Access the personal data we hold about you.
  • Request correction or deletion of that data.
  • Object to or restrict certain processing.
  • Lodge a complaint with your local data protection authority — in Lithuania, the State Data Protection Inspectorate (VDAI).

To exercise these rights regarding data held by us directly, contact privacy@nobrakesgames.com. For data held by Steam or Meta, including achievement, cloud save, and age category data, please contact them directly using the links in Section 7.

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, this section supplements the rest of this Policy as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA).

Categories of personal information: in the preceding 12 months, the only personal information connected with Tiny Flock is (a) identifiers (your Meta account ID) and internet/network activity (achievement, cloud save, and age category data) passed through to Meta via the Meta Platform SDK as described in Section 4, which we do not receive, view, or retain ourselves, and (b) any information you voluntarily provide in support correspondence, such as your email address. We do not collect sensitive personal information (e.g., precise geolocation, biometric data for identification, or government IDs), and hand tracking data never leaves your device (Section 6).

Sale or sharing: we do not sell personal information, and we do not share it for cross-context behavioral advertising. We run no advertising or ad-tracking SDKs of our own.

Under the CCPA/CPRA, California residents have the right to:

  • Know and access the specific pieces and categories of personal information we hold.
  • Delete personal information we have collected (subject to certain exceptions).
  • Correct inaccurate personal information.
  • Opt out of the sale or sharing of personal information — not applicable, since we do not sell or share.
  • Limit the use of sensitive personal information — not applicable, since we do not collect any.
  • Not be discriminated against for exercising any of these rights.

To exercise these rights over data we hold directly, contact privacy@nobrakesgames.com; we may need to verify your identity before fulfilling a request. For data held by Meta or Steam (including achievement, cloud save, and age category data), please exercise your rights with them directly using the links in Section 7. You may also designate an authorized agent to submit a request on your behalf.

We do not offer financial incentive programs and have not sold or shared personal information for cross-context behavioral advertising in the preceding 12 months.

13. International Data Transfers

Because Steam and Meta operate globally, any data they collect — including achievement, cloud save, and age category data processed via the Meta Platform SDK — may be processed outside your country of residence, subject to their own safeguards. We do not transfer personal data internationally ourselves, as we do not receive or store it directly.

14. Changes to This Policy

We may update this Policy from time to time, for example to reflect new features or platform requirements. The “Last updated” date at the top will always reflect the most recent revision. Material changes will be noted on our store page or website where required.

15. Contact Us

UAB No Brakes Games
Ukmerges st. 126 Vilnius, Lithuania Email: privacy@nobrakesgames.com.