1. Controller
- Controller
- Vasas József, individual entrepreneur
- Studio name
- Seventh Head Games
- Registered office
- 9735 Csepreg, Kossuth utca 17., Hungary
- [email protected]
2. Data processed by this website
The website has no user accounts, forms, analytics, advertising, marketing tracking, or marketing cookies. It does not operate a proprietary backend or database.
When you visit, technical request data such as your IP address, requested URL, date and time, browser or user-agent information, and security-related request metadata may be processed by Cloudflare to deliver the site, maintain availability, prevent abuse, and protect the service. Seventh Head Games does not use this information for profiling or marketing.
If you contact us by email, we process the address you use, the message and its metadata, and any information or attachment you voluntarily include. Please avoid sending information that is not needed to answer your request.
3. Data processed by Orbital Divide
Orbital Divide has no user account and no proprietary backend. The audited version stores the following information in the application’s private local storage on the Meta Quest device:
- campaign progress, completion results, scores, times, stars, coverage and wall-attempt information;
- endless-mode records, difficulty, wave, score, random seed, ruleset version, duration, completion reason and related time;
- unlocked and selected visual themes and tutorial-seen indicators;
- gameplay and accessibility settings, including dominant hand, play-area settings, haptics, audio levels, high contrast, VR/MR mode and endless difficulty;
- whether the studio intro has been viewed;
- local startup and XR/passthrough diagnostic information, including timestamps, app version, platform, graphics and XR state, device name, a one-time technical HMD/camera transform, status flags, errors and stack traces.
In Editor or Development builds only, the game may also create a local playtest log containing a random session ID, game mode or stage, seed, result, performance and gameplay measurements. This playtest logging is disabled in non-development Store builds. The random session ID is not a Meta account ID.
HMD and controller poses and button or joystick input are handled in memory for VR interaction. Except for the single technical transform noted above, they are not stored by the game and are not transmitted to a server.
Platform services and network activity
The audited project does not include the Meta Platform SDK and does not perform an explicit Meta entitlement check. It does not request or retrieve a Meta user ID, profile, cloud save, platform leaderboard, achievement, in-app purchase, or other Meta Platform data. It also contains no Unity Analytics, Unity Ads, Unity Cloud Diagnostics, third-party analytics, advertising, or crash-reporting runtime integration.
The audited build declares Android’s INTERNET permission, but the source-code audit found no game-initiated HTTP, socket, WebSocket, or other server request. The About link only asks the Horizon OS system browser to open a website.
Mixed reality and passthrough
Mixed reality mode uses OpenXR passthrough composition provided by the Meta Quest system. The audited app does not request camera or headset-camera permission, access raw camera images, encode image pixels, or save or transmit camera imagery. The Quest system composes the environment view.
Audit scope: these statements are based on the Orbital Divide privacy and SDK audit dated August 14, 2026 for the reviewed Unity project and production-simulation APK. The policy and audit must be reviewed again before release if a platform SDK, entitlement, account feature, cloud save, backend, online leaderboard, analytics, crash reporting, raw camera access, microphone access, shared spatial data, or any server communication is added.
4. Purposes and legal bases
- Website delivery and security: to serve pages, maintain availability and prevent abuse. The legal basis is our legitimate interest in operating a secure and reliable website (GDPR Article 6(1)(f)).
- Email support and enquiries: to respond to your request and retain necessary correspondence. The legal basis is taking steps at your request or performing a contract (Article 6(1)(b)), our legitimate interest in handling studio communications and support (Article 6(1)(f)), and, where required, compliance with a legal obligation (Article 6(1)(c)).
- Local game data: to save progress and preferences, provide the requested gameplay, and diagnose startup or XR issues locally. The data remains under the device user’s control and is not received by Seventh Head Games unless the user chooses to send it for support. Where the GDPR applies, the relevant basis is performance of the game service requested by the user (Article 6(1)(b)) and our legitimate interest in providing stable software (Article 6(1)(f)).
5. Storage location and retention
- Website: this static site has no application database. Cloudflare may process and retain technical request and security information in its infrastructure according to the service configuration and Cloudflare’s applicable terms and policies.
- Email: messages are stored in the relevant email systems for as long as needed to handle the request, protect legal claims, meet legal obligations, or maintain necessary business records, after which they are deleted or archived according to applicable retention requirements.
- Orbital Divide: save data, preferences and technical logs remain in the app’s private storage on the Meta Quest device until changed or deleted. The startup log is overwritten at launch and may then be extended during that session. Local backups or diagnostic files remain until the app data is cleared or the app is removed.
6. Recipients, processors and international transfers
Cloudflare provides the website hosting, content-delivery and security infrastructure and may process technical request data. Email delivery and storage are handled by the sender’s and recipient’s email service providers. We do not sell personal data and do not share it for advertising.
These service providers may use infrastructure in the European Economic Area and other countries. Where personal data is transferred outside the EEA, the provider is responsible for using an applicable transfer mechanism and safeguards under its contractual and privacy terms. Meta Quest, Horizon OS, the Meta Store and the system browser are separate services operated by Meta under Meta’s own terms; the audited game does not request Meta Platform user data.
7. Deletion
To request deletion of email correspondence or other personal data held by Seventh Head Games, email [email protected] and provide enough information to identify the relevant correspondence. We may need to retain limited information where required by law or necessary for legal claims.
In Orbital Divide, RESET PROGRESS resets active progress but intentionally keeps gameplay and accessibility settings. To remove all local save files, backups and diagnostic logs, clear Orbital Divide’s application data in Meta Quest settings or uninstall the app. Local data cannot be deleted remotely by Seventh Head Games because the audited game does not send it to our systems.
8. Your rights and complaints
Subject to the GDPR and its conditions, you may request access to, correction or deletion of your personal data, restriction of processing, data portability, and you may object to processing based on legitimate interests. Where processing relies on consent, consent may be withdrawn at any time without affecting earlier lawful processing.
Send requests to [email protected]. We may ask for information necessary to verify your identity and locate the relevant data.
You also have the right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH): 1055 Budapest, Falk Miksa utca 9-11, Hungary; postal address: 1363 Budapest, Pf. 9.; email: [email protected]; website: www.naih.hu. You may also contact the supervisory authority in the country of your habitual residence, workplace, or the place of the alleged infringement.
9. Children
The website is not designed to collect personal data from children and has no account, form, analytics or advertising. Orbital Divide stores the game information described above locally and the audited version does not send it to Seventh Head Games. If a parent or guardian believes that a child has sent personal data to us by email, they may contact us to request its deletion.
10. Contact
For privacy questions or data requests, contact Vasas József / Seventh Head Games at [email protected].