Privacy Policy

Effective: May 30, 2021

Turtletop Software, a Canadian company (“us”, “we,“our”, or “Company” ) operates Ultimate Chess VR, a virtual reality chess game. This page informs you of our policies regarding the collection, use and disclosure of personal Information as well as game related information we receive from users of Ultimate Chess VR, our other games, applications, websites, and software. By playing Ultimate Chess VR, you agree to the collection and use of information in accordance with our privacy policy. Please read this privacy policy carefully to understand our practices regarding the collection and treatment of your information. Do not use Ultimate Chess VR or our other games, applications, websites, or software unless you consent to the collection, maintenance and use of your information as described in this privacy policy. This Policy does NOT apply to information we collect offline or you provide to or is collected by any third party (except as otherwise provided below).

Personal Information

We may collect personal information from you in accordance with this privacy policy and applicable law. How we collect personal information and our policies governing its use, deletion and disclosure are described in this privacy policy. “Personal information” refers to any information that can be used to personally identify you, such as your name, email address, address, voice, IP address, “personal data”, etc. (as that term is defined Article 4(1) of the General Data Protection Regulation), other identifiers by which you may be contacted online or offline, and other similar types of information under applicable law. Additionally, “Personal information” may include some non-personal information when it is linked with other types of personal information or non-personal information (e.g., motion sensor information or motion tracker information).

When you play Ultimate Chess VR, we may collect information from you in the following ways:

Sources of Collection

We may collect your Personal Information when you provide it to us directly. For example:

  • When you register for an account to use our services, we may collect your age or date of birth, email address, phone number, username, and display name.
  • When you contact us or report a problem with the services, we may collect records and copies of your correspondence.
  • When you play Ultimate Chess VR, we may collect information on your in-game statistics, friends, what platform you are using, which headset you are using and its serial code, IP-address, game settings, owned DLC and personal information.
  • When you use the multiplayer chat or other public functions in the Ultimate Chess VR, we may collect the information you choose to disclose such as your username.
  • When you respond to a survey or questionnaire, we may collect the information provided.

Information from Third Party Platforms

We may automatically receive your personal information from the platform through which you downloaded and play Ultimate Chess VR (e.g. Oculus, Steam). Personal Information collected by the third-party platform that you use to access Ultimate Chess VR is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see the Oculus Privacy Policy, Steam Privacy Policy Agreement as applicable). For instance, when you first play Ultimate Chess VR using the Oculus store, your Oculus ID will automatically be transmitted to us, with no action on your part.  Our use of your personal information collected through the Game is limited to the purposes described in the “How We Use Your Information” section below. If you provide your personal data to third parties, then we are not involved. We have no control over these sites or the activities of the third parties. In that case, the privacy policy of the third party applies. We are not responsible for the content of the privacy policy of these parties and the way in which these parties deal with personal data. We encourage you to review their privacy and security practices and policies before you provide personal information to them.

Revealing personal information in Ultimate Chess VR

You may choose to reveal personal information in Ultimate Chess VR through multiplayer chat or other public functions, including through your username. In addition to being accessible to other users with whom you are interacting, we may also capture this information using recording functions that we use to monitor users’ activity in Ultimate Chess VR. We cannot control how other users will use personal information that you reveal using multiplayer chat or other public functions, so, if you reveal personal information through multiplayer chat or other public functions, you are doing so at your own risk. Similarly, users must not create a username that reflects their own real name or reveals personal information. If you include personal information in your display name, you are doing so at your own risk.


We may use cookies in connection with automatic data collection through our websites. A cookie is a small text file placed on the hard drive of your computer which is used to uniquely identify you. Some cookies on our services come from third parties. These cookies improve your experience by helping us better tailor our services to you. For example, Google Analytics may use cookies to collect your Personal Information on our behalf to analyze your use of our services.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you do this you may be unable to access certain parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you access our websites.

Data Processing and Security

All information that you provide to us is stored in Canada. No matter where you are, you consent to the processing, transferring, and storage of your information, including personal information, in and to Canada and other countries. Laws that apply to the collection, maintenance and use of information in Canada (or any other country) may not be as comprehensive or strict as the laws of the country where you’re located. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. When you directly provide us with personal information, including through registration, we will encrypt that information using secure socket layer technology or similar technologies. We may retain data collected from you, including personal information, to support customer service inquiries and prevent repeated violations or suspected violations of the Terms of Service if your account has been banned or your access to the services has been disabled for any reason. We may retain your information for as long as is necessary and relevant to your use of the services and our operations, which may include retaining your information beyond the end of your use of the services. To dispose of personal information, we may anonymize it, delete it or take other measures we deem to be appropriate. We would like to point out that we cannot guarantee absolute security when sending personal data via the internet or storing personal data. We advise you to take this into account before sharing personal data. 

Use of Personal Data

Our legal bases for processing personal data are as follows:

  • The fulfillment of our and Ultimate Chess VR’s service and intended experience;
  • Improving the game and business;
  • Compliance with the applicable law;
  • Addressing legal issues;
  • Providing a safe and fun experience for everyone that plays Ultimate Chess VR and uses our services;
  • Responding to customer service inquiries and providing customer service;
  • Fulfillment of our contractual obligations to users of Ultimate Chess VR; and
  • To protect you and other users.

We, including our affiliates and subsidiaries, may also use your personal information:

  • To offer, operate, maintain, and improve our services;
  • To present our services to you;
  • To operate all features within our services;
  • To investigate violations of our Terms of Service and attempt to prevent additional violations;
  • To provide you with notices about your registration;
  • To notify you about changes to our services or any of our related products;
  • For any other purpose with your consent.

Also, where you have given us permission to do so, we may use your information to send you news and updates about our products or services, including special offers and promotions. When we send you news or updates, we’ll also tell you how to opt out of receiving such notices.

Disclosure of your personal information

We do not share or otherwise disclose your personal information with or to third parties except:

  • With your consent;
  • As may be necessary to protect your safety or the safety of other users;
  • To our affiliates and subsidiaries, to the extent consistent with this privacy policy, and who treat the information in confidentiality;
  • To our lawyers, consultants, accountants, business advisors and similar third parties who owe us duties of confidentiality;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Turtletop Software’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company pertaining to the users of our services is among the assets transferred;
  • To enable us to take precautions against liability;
  • To protect the safety and security of our services;
  • Where required to do so by law or legal process; or
  • Where it is in aggregated and/or non-personally identifiable form.

Personal Data Rights

You can send a request for access, correction, deletion, data transfer of your personal data or request for withdrawal of your consent or objection to the processing of your personal data by messaging us on the bottom of our website under “Contact Us” or through social media.

To prevent abuse, we ask you to identify yourself adequately in the case of a written request for access, rectification or erasure. You can do this by sending a copy of a valid proof of identity. 

Users will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. However, we’d much rather you contact us first, so we can try to address any concerns that you have about our privacy practices.

Changes to Privacy Policy

We may update this privacy policy from time to time, so please review it frequently. We will post any new or updated privacy policy on our website.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.