Privacy Policy
Last updated: 8 December 2025
In this policy, “Zero Latency” (or “we”, “us” or “our”) refers to Zero Latency Pty Ltd (ABN: 71 168 651 885).
The following Privacy Policy applies to users of our:
Free Roam Virtual Reality (FRVR) services
Booking services, website, player account, and survey functionality on the domain of https://www.zerolatencyvr.com/ For the purpose of UK and EU data protection laws, Zero Latency is the controller of the personal information we process about you in connection with the above services.
For any information connected to the domain https://www.zerolatencyvrgeelong.com including enquiry forms, this is managed wholly by the Zero Latency VR Geelong venue.
We regard customer privacy as an important part of our relationship with our customers. This policy sets out how we will use your personal information in connection with the above services and the rights you have in respect of our processing of your personal information. If you have any questions about this policy, please contact us as per the Contact section in this document.
When we refer to “personal information” in this policy, we are using the term as it is defined in the Privacy Act 1988 (Cth) (Privacy Act), provided that where the term (or a similar term, such as “personal data”) is interpreted more broadly under the laws applicable to you, that interpretation shall apply. Under the Privacy Act, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
-
whether the information or opinion is true or not; and
-
whether the information or opinion is recorded in a material form or not.
WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
We generally collect or receive your personal information in the following three ways, which are described in further detail below:
-
When you voluntarily provide information to us – such as when you make a booking, create your player profile, or sign up for email updates;
-
Automatic recording/collection of your information – such as through cookies on our website or game logs from your use of our FRVR services; and
-
Information collected from third parties – such as those who provide us analytics and advertising tools to support our marketing and other activities.
We generally only ask you for your personal information to provide the services you request. You can always choose to not provide the information and also request we delete your information. However, in some instances this will mean that we are not able to provide the services you have requested, such as making a booking or playing a game.
1. Information you provide
We collect the following information when you provide it to us through our website or at our FRVR venues as outlined below:
-
your name, email, language, and phone number (when you make a booking to use our FRVR services)
-
in addition to the above, your player display name, date of birth, dominant hand, height, and gender (when you create a player account to use our FRVR services)
-
your feedback and ratings (when you complete a survey provided by us or otherwise provide us with feedback)
-
your enquiries or support requests, including your message and account or order details (when you contact us with an enquiry or request help)
You don’t have to share this information with us. However, it may be required to book or play our FRVR services.
Please note, when you use our FRVR services some of your information will be publicly accessible to others, such as your player display name and your game performance statistics (e.g. this information will be visible on the public scoreboard at the end of a game, but only within the facility where you played).
2. Information we automatically collect
When you visit our website or use our FRVR services we collect the following information automatically through cookies and game log files:
-
the site location of your booking;
-
your IP address;
-
the general and non-specific location of your device (e.g. at a city or post-code level) from your IP address;
-
website behavior information, such the website pages you’ve visited, which website you came from before or went to after, and what device you were using;
-
game play information, such as the games you have played through our FRVR services, when you have played them, how many times you have played, and information about your performance in these games; and
-
error reports, such as if your equipment fails, or your game experiences errors or issues.
Although we are able to identify individuals from this information, we typically aggregate this information and use it to determine trends among groups of players.
3. Information we receive from third parties
We may also collect information from third parties who provide us advertising and analytics tools (e.g. Facebook Business, Google Adwords and Google Analytics).
Additionally, we may derive information or draw inferences about you based on other types of information we collect. For example, we may infer your location based on your IP address, or that you are interested in participating in an event based on your browsing behaviour on our website.
Also refer to our Cookies Policy for further information about the types of Cookies we use.
HOW WE USE YOUR INFORMATION
Your information is generally collected and used to provide you with the products and/or services you’ve requested and to improve our services and the customer service we provide to you. The table below sets out full details in respect of how we use your personal information together with our lawful basis for processing of such personal information (information relating to our lawful basis for processing will only be relevant if you reside within the EU or UK):
|
How we use your information? |
What information is used? |
Our lawful basis for such processing |
|
To satisfy your booking request and contact you if we have trouble processing your order. Note: this may involve the transfer of your personal information to one of our business partners which operates under the Zero Latency brand so they can administer your booking or respond to your enquiry. Please see the ‘Business Partners’ section of this policy below. |
Your name, email, language, phone number and credit/debit card details. |
Processing is necessary for the performance of a contract entered into with you or (where we have not entered into the contract with you) is necessary for our legitimate interests of providing our services in accordance with customer requests. |
|
To develop and improve our website, products and services. |
Your feedback and ratings, your support requests, your website behaviour information, your gameplay information and error reports relating to your browsing or gameplay. |
Processing is necessary for our legitimate interests of reviewing and improving the products and services we provide so we can continue to grow our business. |
|
To communicate with you to provide updates or information in relation to your booking or enquiry. |
Your name, email, language, phone number and site location of your booking. |
Processing is necessary for the performance or anticipated performance of a contract entered into with you |
|
To respond to your enquiries or support requests. Note: this may involve the transfer of your personal information to one of our business partners which operates under the Zero Latency brand so they can administer your booking or respond to your enquiry. Please see the ‘Business Partners’ section of this policy below. |
Your name, email, language and phone number and details of your enquiry/support request |
Processing is necessary for the performance of a contract entered into with you or (where we have not entered into a contract with you) is necessary for our legitimate interests of responding to enquiries or requests from potential customers in order to provide quality customer service and grow our business. |
|
To personalise your experience, remember your preferences, and pre-populate settings to streamline your experience on our website or at our FRVR centres. Note: this may involve the transfer of your personal information to one of our business partners which operates under the Zero Latency brand so they can administer your booking or respond to your enquiry. Please see the ‘Business Partners’ section of this policy below. |
Your name, player display name, date of birth, dominant hand, height, and gender. |
Processing is necessary for our legitimate interests of providing an enjoyable and immersive gameplay experience to our customers. |
|
To provide you with news and promotional emails via email and measure the effectiveness of such emails, as outlined in the ‘Direct Marketing’ section below. |
Your name, email address, language, site location of your booking and your gameplay information. |
Your consent. |
|
To provide advertising to you on social media sites, as outlined in the ‘Social Media Marketing’ section below. |
Your name, email address, site location and website behaviour information. |
Your consent. |
|
To ask you to leave a review or take a survey |
Your name and email address. |
Processing is necessary for our legitimate interests of providing an enjoyable and immersive gameplay experience to our customers. |
|
To ensure and improve the security of our website. |
Your IP address, website behaviour information and error reports. |
Processing is necessary to comply with legal obligations to which we are subject. |
|
To comply with our legal, regulatory, tax and accounting obligations. |
Your name, email, phone number, credit/debit card details, IP address, website behaviour information and gameplay information. |
Processing is necessary to comply with legal obligations to which we are subject. |
HOW WE DISCLOSE YOUR INFORMATION
Our Licensees
We may share all of your personal information that we collect with our Licensees who operate Zero Latency FRVR venues to allow them to:
-
operate the FRVR venues;
-
provide you with our FRVR services;
-
respond to requests you provide them about your account history (e.g. bookings and game results); and
-
improve the FRVR venues they operate (e.g. through reviewing your survey responses and feedback).
With your consent or subject to their privacy policies, our Licensees may also send you other communications related to their local site operations, which you may opt out of at any time.
Where you provide any personal information directly to our Licensees, their collection, use and disclosure of your information will be governed by their own privacy policy that they will make available to you.
If you have any questions about their use of your personal information, you can ask the venue/Licensee directly by speaking to their staff on site, or contacting them directly. You will be able to find the contact details on their website.
Other Disclosures
-
Save in relation to disclosures to our Licensees as set out above, we will only disclose your personal information to:
-
companies within the Zero Latency corporate group for internal business purposes such as management, accounting and marketing;
-
our booking platform providers, payment gateway and payment service providers;
-
other third-party suppliers, including business partners and sub-contractors for business administration, support, processing, services, or IT purposes;
-
analytics or search engines, that enable us to optimise and improve your experience of our website;
-
third-party suppliers for marketing and advertising purposes;
-
our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters;
-
our professional advisors (including without limitation tax, legal, insurance, or other corporate advisors who provide professional services to us); and
-
regulators as necessary to comply with our legal and regulatory obligations.
-
To the extent authorised by applicable laws, we will disclose your personal information to third parties:
-
to prospective sellers or buyers in the event that we consider selling or buying any business or assets, merging with another business, financing our business, granting a charge over our assets or leasing or licensing our assets;
-
if we are the subject of any insolvency situation (e.g. administration or liquidation);
-
if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
-
to enforce or apply our terms and conditions;
-
to protect our rights, property, or safety, or that of our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation regulators, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
-
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
OVERSEAS DISCLOSURE OF YOUR INFORMATION
Zero Latency is headquartered in Melbourne, Australia. If you are not an Australian resident and you share information with us or use our website or the FRVR services, your personal information will be processed and stored by us in Australia.
When you interact with our services mentioned at the beginning of this document you (to the extent permitted by law) consent to the processing and temporary transfer of your information to countries where our FRVR sites are located, as outlined on our website (here).
The laws of Australia and other countries governing data collection and data use may not be as comprehensive or protective as the laws of the country of your residence.
If you are a resident of the UK or EU, we may transfer your personal information outside of the UK and European Economic Area (EEA), including to any country where our Licensees or service providers are based. If we transfer personal information to countries outside of the UK or EEA, we will ensure (in accordance with applicable laws) an adequate degree of protection is afforded to your personal information by ensuring at least one of the following safeguards is implemented:
-
we may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information;
-
for transfers to the US, any transfers would be under the EU-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework (as applicable). Further information about the EU-US Data Privacy Framework can be found here and the UK Extension to the EU-US Data Privacy Framework can be found here;
-
we may use specific contracts approved for use in the UK and/or EEA which give personal information the same protection it has in the UK and EEA Further information regarding such contracts are available on the ICO’s website here and on the European Commission’s website here.
Personal information collected by third parties (including information collected via cookies set by third parties) may be transferred by those third parties outside of the UK and/or EEA. Please refer to the relevant third parties’ privacy policy for further information.
YOUR RIGHTS IN RESPECT OF YOUR INFORMATION
You may request access to a copy of personal information that we hold in relation to you, or for us to update or delete this information. To make this request please contact us as per the Contact Us section in this document.
In addition to the above, if you are a resident of the EU or UK, you have further rights in certain circumstances in relation to the personal information we process about you, including:
-
You may request that we restrict our processing of your personal information.
-
You may request that we transfer your personal information in a structured, commonly used and machine-readable format to another organization.
-
You may object to our processing of your personal information where we process such personal data for:
-
the purpose of our legitimate interests unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims; or
-
direct marketing purposes.
-
You have the right not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you. We do not carry out any automated processing or profiling.
-
You have the right to withdraw your consent at any time, for example, where we are relying on it for direct marketing purposes.
-
To make any such request please contact us as per the Contact Us section in this document.
Please note:
-
before we process your request we may need to confirm your identity (such as by providing an appropriate amount of personally identifiable information);
-
your right to make any of the above requests may sometimes be limited (e.g. we may need to retain a minimum amount of information for legal purposes).
DIRECT MARKETING
If you opted in to receive news and promotional emails from us, we may use the personal information we have collected to provide this marketing to you.
If you decide you don’t want these, you can unsubscribe by following the instructions in the respective email. This will not apply to non-marketing communications, such as those notifying you of a change to your booking.
SOCIAL MEDIA MARKETING
We may share your name, phone number, email address and any information we collect about your use of our website or social media accounts with social media platforms (who may process your personal data as joint controllers with Zero Latency for these purposes) for the purpose of serving you targeted advertising. We may also allow such social media platforms to use cookies and similar technologies to collect personal information relating to users of our website who may then use information they collect to show you ads on sites across the internet. These social media platforms include:
-
Google – Google Privacy Policy
-
Facebook, and Instagram – Meta Privacy Policy;
-
Pinterest – Pinterest Privacy Policy;
-
LinkedIn – LinkedIn Privacy Policy;
-
Spotify – Spotify Privacy Policy;
-
TikTok – TikTok Privacy Policy; and
-
X – X Privacy Policy.
Once we have shared your personal information with the above entities or they have collected your personal information, they are responsible for ensuring your personal information is processed in accordance with applicable data protection laws. Please ensure you review their privacy policies (as set out above) carefully for further information. We will, however, take reasonable steps in the circumstances to ensure they afford a similar degree of protection to your personal information.
Google. You can opt-out of Google’s use of cookies or device identifiers at any time by visiting Google’s Ads Settings.
Meta. Where you have consented for us to do so, we will collect and share your personal information with Meta Platforms Ireland Limited (Meta Ireland) in order to advertise to you via Facebook, and Instagram, and in certain instances we are the joint controller of your personal data with Meta Ireland.
We have entered into an agreement with Meta Ireland to ensure that your information is protected, and the steps we each shall take to comply with applicable data protection laws with regard to the joint processing of your information.
To exercise your rights in relation to your information, Meta Ireland will be your primary contact. Please contact Meta Ireland directly to:
-
request access to your personal information;
-
request correction of your personal information;
-
request erasure of your personal information;
-
object to the processing of your personal information;
-
request restriction to the processing of your personal information; and/or
-
request the transfer of your personal information.
Further information regarding how to exercise your rights, together with the following further information, may be found in Meta Ireland’s Privacy Policy and Terms of Service, including:
-
how Meta Ireland processes your personal information in the capacity of a joint controller, including the legal basis that Meta Ireland relies upon for such use;
-
how to exercise your data protection rights against Meta Ireland; and
-
the name and contact details of Meta Ireland’s data protection officer.
Pinterest. Where you have consented for us to do so, we will collect and share your personal information with Pinterest Europe Ltd (Pinterest Europe) to advertise to you via Pinterest, and in certain instances we are the joint controller of your personal data with Pinterest Europe.
We have entered into an agreement with Pinterest Europe to ensure that your information is protected, and the steps we each shall take to comply with applicable data protection laws with regard to the joint processing of your information, pursuant to this:
-
we will be responsible for confirming the purpose for which the collection and transmission of personal information takes place, please see the how we use your information section above.
-
Pinterest Europe is responsible for enable you to exercise the rights set out above with regard to the personal information stored by Pinterest Europe after the joint processing.
Further information regarding how to exercise your rights, together with the following further information, may be found in Pinterest Europe’s Privacy Policy.
X. Please see the information here in respect of how to opt-out of advertising by X.
COOKIES
You may reject our use of certain (non-necessary) cookies through our cookies notice that appears as a “pop-up” when you access our website. In some cases blocking or disabling cookies may cause our services (such as our website) to have reduced or affected functionality. You may also change your internet browsers settings to block, manage, or delete cookies. Please see our cookies policy for further information.
You can seek to opt-out of the analytics and advertising provided by third parties on Zero Latency services at www.aboutads.info/choices/ and www.networkadvertising.org/choices/, or if you are located in Europe http://www.youronlinechoices.eu/ or http://www.youronlinechoices.com/uk/.
HOW WE PROTECT YOUR INFORMATION
We provide appropriate organisational, physical, and technical security measures to protect your information from unauthorised access, use, disclosure, and modification. However please be aware that despite our best efforts no security measures are impervious and completely secure, and we cannot guarantee the loss or misuse of your information. By agreeing to the policy you are acknowledging this risk.
If you are a resident of California, we will notify you if your personal information is compromised.
CHILDREN’S PRIVACY
We request that to individuals under the age of fifteen (15) do not provide Personal
Data through to us.
If you’re the parent or legal guardian of a child under the age of 15 and you believe
they have provided information to Zero Latency, please contact us as per the contact
section in this document, and we will delete any information that may have been
provided to us.
CHANGES TO PRIVACY POLICY
We reserve the right to modify this privacy policy at any time, so please review this policy every time you visit our website, make a booking, or use our FRVR services to ensure that you are consenting to the most recent version of this policy.
We will indicate at the top of this document when the policy was last updated. Any changes will become effective when we post a revised version of this Privacy Policy unless otherwise specified.
COMPLAINTS
If you have any issues with how we collect, use or disclose your personal information, or if you feel that we have breached the Privacy Act or any other applicable data protection laws, you are entitled to make a complaint.
To make a complaint to us, please contact us through our details as outlined below under “Contact Us”. We will endeavour to respond to your complaint within 30 days of receipt.
If you are not satisfied with how we deal with your complaint you may lodge a complaint with:
-
[if you reside in Australia], the Office of the Australian Information Commissioner by visiting oaic.gov.au, calling 1300 363 992 or emailing enquiries@oaic.gov.au;
-
if you reside in the UK, the UK’s Information Commissioner’s Office. Their address is: First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF or you can contact them by other methods as set out at https://ico.org.uk/global/contact-us/contact-us-public/.
-
if you reside in the EU, details of your local supervisory authority and how to contact them can be found here.
CONTACT US
If you have any questions or comments about this policy or would like to enact any of your rights mentioned in this policy, please contact us at info@zerolatencygeelong.com