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Privacy Policy

PRIVACY POLICY – GYMGAMENT LTD

Last Updated: January 12, 2026

This Privacy Policy describes how GYMGAMENT LTD collects, uses, and protects user data interacting with our web-based platform, our touchless interaction technologies (including the V.I.T.R.U.V.I.A.N. system), and our games.

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1. DATA CONTROLLER

The Data Controller is:

GYMGAMENT LTD

Company Number: 16220623

Registered Office: 9 CHAPEL PLACE, 2ND FLOOR, LONDON, ENGLAND EC2A 3DQ

Contact Email: mkg@gymgamail.com

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2. DATA PROCESSING VIA ARTIFICIAL INTELLIGENCE (MOTION TRACKING)

Our platform utilizes Computer Vision and Artificial Intelligence (AI) technologies to transform physical movement into digital experiences.

  • Nature of Processing: We use AI models (MediaPipe) to detect body keypoints (pose estimation).

  • Local Processing (Edge AI): All video stream processing occurs exclusively in real-time on the user’s device GPU/CPU (browser-side).

  • No Video Retention: No video images or frames are saved, stored, or transmitted to our servers. The system "sees" to act but does not "remember" or send images externally.

  • Extracted Data: The AI extracts only anonymous numerical coordinates $(x, y, z)$ to drive game elements. This data is overwritten instantaneously and does not allow for the unique identification of any individual.

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3. TYPES OF DATA COLLECTED (NON-BIOMETRIC)

In addition to local motion tracking, we collect the following data through our platform (hosted on Firebase):

  • Authentication Data: If the user chooses to create an account (via Auth 2.0: Google, Apple, Facebook), we collect the email address and profile name.

  • Anonymous Access: We support anonymous login for users who do not wish to share personal data.

  • Usage Data: Game scores, levels completed, and sports performance statistics necessary for the service's functionality.

  • Technical Data: IP address (for security purposes), browser type, and device information.

 
4. PURPOSES OF PROCESSING

Data is processed to:

  1. Provide the gaming experience and touchless interaction.

  2. Manage leaderboards and user progress.

  3. Ensure platform security via Firebase Auth.

  4. Comply with legal obligations set by the EU AI Act (Transparency).

 
5. LEGAL BASIS

Processing is based on:

  • Performance of a Contract: To provide the platform's features.

  • User Consent: For webcam access (explicitly requested by the browser) and social authentication.

  • Legitimate Interest: For system protection and technical performance optimization.

 
6. DATA STORAGE AND TRANSFER

Profile-related data is stored on Google Firebase servers. We do not transfer video or biometric data because, as specified in Section 2, such data never leaves the user's device.

 
7. USER RIGHTS

In accordance with the GDPR, users have the right to:

  • Access their data or request its deletion.

  • Withdraw consent for webcam use at any time via browser settings.

  • Object to data processing for statistical purposes.

  • Request the portability of data saved to their account.

 
8. PROTECTION OF MINORS

Given that the platform is frequently used by minors (e.g., Lucca Comics, Sports Festivals), GYMGAMENT LTD adopts a Privacy by Design approach. We do not profile minors or collect sensitive data beyond what is strictly necessary for gameplay.

 
9. CONTACT

For any questions regarding this Privacy Policy or to exercise your rights, please contact: mkg@gymgamail.com

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