Hot Dark Matter - Privacy Policy

Updated: 10 July 2023

Hot Dark Matter Ltd are creators of an augmented reality platform called Matter AR (from time to time referred to as Matter AR Application, Matter AR App and Matter AR Platform), allowing the exploration, creation and playing of a persistent geo-spatial experience layer that lives over the real world.

In order to deliver the features we need some information about you and your device. This Privacy Policy describes the type of information we collect when you use the Matter AR application for mobile devices (the “App”), and our web domain and subdomains, including (the “Sites”). We refer to interaction with our App and Sites as the “Services”.

Hot Dark Matter Ltd is committed to protecting your privacy through this privacy policy.

What we collect

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

Location data - We collect and use your device location when accessing shared locations as part of our app. Our app enables location experiences where the core feature is to provide a gameplay experience tied to your real world location, so we need to know where you are to operate the experience for you, and to plan the location of in-app resources. We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.

Technical information - information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the Services for you and to personalise your user experience. We will also generate an internal account ID when you use certain Services to associate you with an account. You may assign a username to your account locally on your device.

In-app actions - Our app includes innovative features which allow you and other players to view and interact with the same virtual objects at the same time in a shared physical space. They also allow you to leave persistent virtual objects at real world locations, so other players can see them even when you are not there, and so you can see them when you return. In order to provide you with these AR experiences, we need to collect geospatial data and images from your device camera and sensors during your AR experiences.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Information Shared with Other Players - When you use the Services, and in particular when you use our app, use social features within the app, or take part in competitions, we will share certain Personal Data with other players. This Personal Data includes your in-app actions and username.

Information Shared Publicly - When you use the Services, your in-app actions may be shared on web pages accessible to the public and therefore become publicly available.

Information Shared with Third Parties - We share Anonymous Data with third parties for industry and market analysis. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others - We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions - Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

Cookies (or browser cookies) - a cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Service.

Who we share information with

We engage third party services providers to deliver the services. External service providers may also collect information from you as a Third Party Service in accordance with their own privacy policy.

Niantic Lightship ARDK

The App uses Niantic Lightship ARDK for geo-spatial location features. Niantic Lightship ARDK collects the following data:

In addition to the data outlined above, the following features collect the data outlined below:

For additional information please refer to the Niantic Consumer Privacy Policy -

Google Firebase

The App uses Google Firebase to deliver content to the application and to enable multiplayer functionality. To do this Google Firebase collects IP addresses.

For additional information please refer to the Google Privacy Policy -

Photon Engine

The App uses Photon Engine to enable and host multiplayer functionality. To do this Photon Engine collects IP addresses and gameplay events.

For additional information please refer to the Photon Engine Privacy Policy -

How your Personal Data is transferred

Your Personal Data may be transferred and stored in a country outside of your home country, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the UK or the EEA to other countries, we ensure that a similar degree of protection is provided to your Personal Data as within the UK or the EEA, as applicable, by ensuring that at least one of the following safeguards is implemented:

How we keep your Personal Data safe

We have appropriate legal, organisational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long we will keep your Personal Data

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law. After that your personal information will be deleted.

Your rights and choices

You have certain rights in relation to your Personal Data. This means you can:

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction


These services do not address anyone under the age of 13. We do not knowingly collect personal data from children under 13. If we learn we have collected or received personal data from a child, we will delete that data. If you believe we may possess or have received any information from or about a child without such prior parental consent, please immediately contact us at

Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You are responsible for periodically visiting this Privacy Policy to check for any changes.

Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.


If you have any questions or comments on this policy, you can email us at