PRIVACY NOTICE

Last updated: January 30, 2026

Mighty Coconut, LLC (also referred to as "we", "us", "our") are committed to protecting and respecting your privacy. We are the data controller for Personal Data (defined below) that we collect about you.

This Privacy Notice explains how we use any Personal Data we collect from you or that you provide to us when you visit our website (https://www.mightycoconut.com/), use our gaming applications ("Apps"), buy our products and services, contact us or otherwise engage with us (together the "Services"). 

In using the Services, you acknowledge your Personal Data will be collected, processed and stored by us in the United States (U.S.).

PERSONAL DATA WE COLLECT ABOUT YOU

When you use our Services, engage with us through social media, or
otherwise engage with us, we collect information from you, including your Personal Data.

"Personal Data" means information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined), and means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information", "personal information" or "personal data" under applicable U.S. data privacy laws, rules, or regulations.

We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as set out below. 

Personal Data you give to us

• Contact and Account Information: We collect your name, email address, phone number, shipping address, and billing address when you make purchases, create accounts, sign up for our newsletter, or contact us through our Services.

• Order and Purchase Information: We collect details about your purchases, including order history, payment information (processed through third-party payment providers), and unique order identifiers.

• Gaming and User Information: For our Apps, we collect:

• User ID and profile information 

• User settings and language preferences

• Account ownership and play history

• Content you have purchased, downloaded or unlocked 

• Reports you make on other players and game-related queries you make

• Communication Information: We collect information about your communications with us, such as your email address, phone number, mailing address, or social media handle, when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us. We also collect any Personal Information contained in the contents of your correspondence with us. 

• Payment information: When we take a payment from you (for example, if you make a purchase from our website), we don't process your credit or debit card information. This is handled by a third party (such as Stripe), but we may be provided with some parts of your financial information related to the transaction, such as the last four digits of your card and your billing address. See the Payment Processing section of this Privacy Notice for more information. We will not be able to fulfil your order unless you provide certain payment-related information. 

Personal Data we receive about your use of the Services

• Technical Information: We automatically collect technical data including the Internet Protocol (IP) address used to connect your device to the Internet, browser type and version, browser plug-in types and versions, operating system, your device make and model (e.g. your VR headset, mobile or other device used for accessing the Services), App ID, App version, platform version, device tracking information (e.g. hand tracking and head/eye tracking – where required to enable full functionality of our Apps). As well as the content of a request, we also receive information associated with the request, such as time zone setting, date and time and http status code associated with your device.

• Usage and Analytics Information: We collect information about how you use our Services, including gameplay analytics, launch times, daily active user data, navigation and interaction data, time spent using our Services (and the features within them), who you interact with when using the Services (for example who you enter into a Private Match with).

• Location Information. We may derive your approximate regional location from your IP address. We do this in order to localise our Services to you (for example, to provide you with your local currency and language), and make sure the services displayed to you are accurate for your location.

• Cookies and Similar Technologies: We use cookies and similar technologies. For more information about how we process your Personal Data, please see the Cookies and Other Technologies section of this Privacy Notice.

Personal Data we receive from other sources

• Reporting Information: We may receive reports about your use of our Apps from other users. For example, if they believe you are cheating or violating rules applicable to your game play or other activity within our Apps.

• Social media: We may receive the following information from your interactions with our social media accounts on Facebook, Instagram, Twitter, and Discord. For example, if you tag us in a social media post or otherwise interact with our social media adverts and accounts (for example, by liking or providing a comment on our post on a social media platform), we may collect Personal Data such as your social media profile name, content you post (including likes and reactions to your posts). We will only be able to see the content you post to your social media account if your profile is set to "public" or if we are "following" you.

HOW WE USE YOUR PERSONAL DATA

We use your Personal Data for the following purposes:

• Service Delivery & Operations: We use the Personal Data that you give to use and that we collect through your use of the Services to: provide you with access to our Services, take steps to fulfil a contract which you have requested (for example, sending our products to you), administer our Services (including any account you may have with us), allow you to participate in interactive features of our Services (when you choose to do so), facilitate payment to be taken from you (processed by a third party) and record the transaction in our records, understand where you are accessing our Services from to deliver location specific content to you, ensure that content is presented in the most effective manner for you and for your device(s).

• Customer Support & Communications: We use your Communication Information, Contact and Account Information, and any other category of Personal Data mentioned above to respond to your queries and feedback, provide technical support, address game-related issues, and enable you to exercise your legal rights (see the "Your Rights" section of this Privacy Notice).

• Safety & Security: We use your Gaming and User Information, Technical Information, Usage and Analytics Information and Reporting Information to keep our Services safe and secure, maintain game safety, enable reporting functionality, and protect users against abuse.

• Analytics & Improvement: We use Usage and Analytics Information to manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, analysing your use of the Services and interaction with us, improving our products and Services, analysing your interaction with social media platforms and our content. We also use Cookies and Other Technologies.

• Marketing & Communications: We use your Communication Information to send marketing communications, including updates relating to products and services offered by us through our newsletter. When we send you emails, we track whether you open them to learn how to deliver a better customer experience and improve the Services. We will only send you marketing communications where lawfully permitted. You can opt out of receiving marketing communications at any time. (see the "Your Rights" section of this Privacy Notice) 

• Legal & Compliance: We will use your Personal Data where required to take steps to meet our legal obligations and protect our rights and interests.

We may also use your Personal Data and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, and information about the device from which you access our Services.

EU/UK: LAWFUL BASIS FOR PROCESSING PERSONAL DATA

If we process your Personal Data and EU or UK data protection law applies (for example, if you are accessing our Services from the EU or UK), we will only process your Personal Data where there is a lawful basis under UK and European data protection law. Lawful bases for processing include consent, contractual necessity, our “legitimate interests” or the legitimate interests of others, and compliance with a legal obligation. 

Below we set out examples of why we process your Personal Data and lawful bases for doing so:

• Contract: Where Personal Data is needed to fulfil our contract with you, including:

• Processing your product and game purchases (including downloadable content).

• Account management and making our Services available to you. 

• Delivering customer support and technical assistance.

• Keeping a record of orders, including receipt of payment, returns or refunds

• Notifying you about changes to our Services.

Where we need your Personal Data to fulfil a contract with you (or take steps to fulfil that contract), if you do not provide some Personal Data, we may not be able to progress or fulfil that contract with you.

• Legitimate Interest: "Legitimate interest" is a legal term used in UK and European data protection law. When we rely on legitimate interest, we mean in pursuing our own interests, we have considered your rights and interests at the same time, and concluded that these are not overridden by your rights. We rely on our legitimate interest for:

• Ensuring content from our Services is presented in the most effective manner for you and your device 

• Providing relevant and tailored content to you

• Analysing how the Services are used, and which products, games and features are most popular to improve our Services.

• Providing the information you request from us, including responding to any queries you have submitted.

• Ensuring the security and integrity of our Services.

• Where permitted in our legitimate interest, or with your prior consent where required by law, we will use your Personal Data for marketing analysis or to provide you with promotional update communications by email about our products, events, and Services.

• Consent: If we rely on your consent to process your Personal Data, we will ask for this before processing. We will ask for your consent (where required by law) to:

• Send you marketing communication (such as our newsletter). 

• Deploy certain Cookies and Other Technologies when you use our Services.

COOKIES AND OTHER TECHNOLOGIES

We use cookies and other similar technologies to collect and store certain information about you, which includes Personal Data. These technologies may include cookies, pixels, web beacons and JavaScript (together "Cookies"), typically involve storing pieces of information or code transferred to or accessed from your device to store and, sometimes, record information about your interaction with online services from your device. 

Cookies and similar technologies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content. They allow us to distinguish you from other users of our Services which helps us to provide you with a good experience and also allows us to improve our Services and see how they are performing. 

A number of Cookies and similar technologies we use last only for the duration of your online session and expire when you close your browser. Others are used to remember you when you return to our Services and will last longer. Some Cookies will also record where you came to our Services from and where you visit once you have left. 

We use Cookies and/or other similar technologies, either alone or in combination with each other, to create a unique ID which corresponds to you. 

When you first interact with our Services, you will be notified that we use Cookies. We also give you information about how to disable Cookies below. Where you change your browser settings to generally disable all Cookies, you may not be able to take full advantage of our Services; some aspects may not work without some Cookies being used.

We use these Cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), or where you have consented to their use.

We use the following types of Cookies: 

We work with the below third-party providers to deliver Cookies:

LINKS TO OTHER WEBSITES

Our Services may, from time to time, contain links to external websites, plug-ins and applications, including social media platforms such as Facebook, Instagram, X, and Discord. This Privacy Notice does not apply to such third-party services, and we are not responsible for the privacy notices or practices or the content of any third party. Please review third-party privacy notices and, where applicable, your privacy settings of such third parties.

We provide more information about the Personal Data we may collect through third parties above (see the section on "Personal Data we may receive from other sources"), including information we may receive as a result of your engagement with social media channels.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your Personal Data with the following categories of recipients:

• Our group companies, which may also process your Personal Data for the purposes set out in this Privacy Notice.

• Organisations that process your Personal Data on our behalf and in accordance with our instructions. This includes supporting our services, in particular data hosting services such as AWS, fulfilment services, communications providers, fraud detection services, advertising services, marketing services, facilitating feedback on our Services and providing IT support services from time to time. These organisations (which may include third-party suppliers, agents, sub-contractors and/or other companies in our group) will only use your Personal Data to the extent necessary to perform their services we ask of them. 

• Gaming platform providers, including Meta, Steam, PlayStation, and Apple to the extent necessary to facilitate your access to and use of our Services. Where our Service is the provision of a multiplayer game, we will also make your Personal Data available to other players that you play the game with to the extent necessary to facilitate your use of the game (for example, we may make available your user ID to another player so they know who they are playing with).

• Analytics and search engine providers such as Unity, that assist us in the improvement and optimisation of our Services and advertising and are subject to our Cookies policy.

• Payment processing providers who provide secure payment processing services. Your payment card details are not shared with us by the provider (see the "Payment Processing" section for more information).

• Other third parties, such as professional advisors, including banks, accountants, and lawyers.

We will also disclose your Personal Data to third parties in the event that:

• we sell our business or assets or a part of them to which your Personal Data relates, in which case we will disclose your Personal Data to the prospective buyer of such business or assets, subject to the terms of this Privacy Notice.

• such disclosure is requested by law enforcement or other public authorities, where required or legally permitted to establish, exercise or defend legal rights; in order to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of Mighty Coconut, our customers, or others. This includes exchanging Personal Data with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime

PAYMENT PROCESSING

Where our Services take the form of the provision of playable games, the applicable platform that the game is hosted on will be responsible for processing any payments. 

Where you have made a purchase through our website, payments are processed through third-party payment providers. You will be providing credit or debit card information directly to such payment provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to these third parties is not within our control and is subject to their own privacy notice and terms and conditions.

Our payment processors include:

• Stripe

Each payment processor operates secure servers and has their own privacy notices governing how they handle your payment information.

PROCESSING YOUR PERSONAL DATA OUTSIDE THE UK AND THE EEA

As a company located in the U.S., most of our operations are conducted in the U.S. and your Personal Data will be processed in the U.S. to provide our Services and fulfill our contract with you. Your Personal Data may also be transferred to or accessed from other countries where data protection laws may be less stringent than UK and European Economic Area laws.

Third parties that we work with may also process your Personal Data in the U.S. and / or facilitate the transfer of or access to your Personal Data outside of the U.S. We will take steps to require them to process your Personal Data subject to appropriate safeguards (for example, implementing standard contractual clauses where appropriate).  

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR

We retain your Personal Data:

• for as long as we are legally required or otherwise permitted to meet our reason for collection (for example, for as long as we are providing Services to you and as necessary after that to anticipate, resolve or document any issues);

• relating to any account or transactions with us, in order to meet our contractual obligations to you and / or any purchase of products to identify any issues, resolve any legal proceedings and for tax and accounting purposes.

CHILD SAFETY

Some of our Services are intended for use by those who are at least 13 years of age. We will communicate this to you where this is the case.  If you are under the age of 13, your parent or guardian must first consent on your behalf, where we ask for consent in relation to the use of your Personal Data. We may also rely on platform-specific age verification systems for these purposes.  

YOUR RIGHTS

Rights under EU and UK Data Protection Law 

If you have any questions about our processing of your Personal Data, please contact us at privacy@mightycoconut.com and state Privacy Query in the subject line.

If we process your Personal Data and EU or UK data protection law applies (for example, if you are accessing our Services from the EU or UK) you have the right under certain circumstances:

• to find out what Personal Data we hold about you;

• to be provided with a copy of your Personal Data;

• to request the correction or deletion of your Personal Data;

• to request that we restrict the processing of your Personal Data (while we verify or investigate your concerns with this Personal Data, for example);

• to object to the further processing of your Personal Data; and

• to request that your provided Personal Data be moved to a third party.

Where the processing of your Personal Data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at privacy@mightycoconut.com and state Privacy Query in the subject line. You can change your preferences and object to receiving further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to privacy@mightycoconut.com and state Privacy Query in the subject line.

Other choices you may make

You may opt out at any time from allowing further access by us to your location data by updating your device settings.

You can un-install the App, which will stop information from being collected from the App. You may use the standard uninstall processes as may be available for your device.

Your right to make a complaint 

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Data, as well as deal with any complaints that you have about our processing of your Personal Data.

If you are based in the EEA, you can find your supervisory authority here https://edpb.europa.eu/about-edpb/about-edpb/members_en.

CHANGES TO THIS PRIVACY NOTICE

Any changes we make to our Privacy Notice in future will be posted on this page and, in relation to substantive changes, will be notified to you where we have your contact details. This Privacy Notice was last updated on the date mentioned at the top of it.

CONTACT US

Questions, comments and requests regarding this Privacy Notice are welcome and should be addressed to: privacy@mightycoconut.com