Virtual Reality Company Privacy Policy

 

The Virtual Reality Company Privacy Policy

 

At the Virtual Reality Company (“VRC”) we are committed to protecting the privacy of users of the virtual reality (“VR”) and other content it makes available through our web and mobile applications (collectively, the “Services”), as well as through our website  (www.thevrcompany.com) (the “Site”). This Privacy Policy explains how we treat information from or about our users, including how we collect, use, and share information in connection with our Services. Please note that these guidelines are subject to change by VRC and any such changes will be posted on our Site. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they may be accessible through, or linked to by, our Services or our Site. If you have questions about this Privacy Policy, please contact us at legal@thevrcompany.com.

 

  1. Information we collect from you. 

 

We collect two basic types of information through the use of our Services – Personal Data (defined below) and Anonymous Information (defined below) (collectively, the “Service Data”). We will retain your personal information for as long as you are using the Services.   

 

Personal Information (the “Personal Data”)

We collect limited information that may be used to personally identify you, we may also receive your personal information through third party companies or agents we work with.  Such information includes: 

  • any email addresses you provide to us on the Site; 
  • your Oculus VR user name (if you access our content through Oculus VR and choose a user name that includes your personal information) (the Oculus Privacy Policy can be located here: https://www.oculus.com/legal/privacy-policy/);
  • your Oculus VR user ID name, if you are accessing our Services through Oculus VR; 
  • information about how you use the Oculus VR services, if you are accessing  our Services through Oculus VR;
  • your Internet Protocol (IP) address and the domain name of your Internet service provider;
  • time that an email sent by us was read by you; and
  • your location information, which we may collect by converting your IP address into an approximate geo-location (though if you do not want us to collect this information, you may disable this feature on your mobile device or computer).

 

European Union users: We comply with the Data Protection Act no 2472/1999, Law no 3471/2006 and the 25 May 2018 the General Data Protection Regulation (EU) 2016/679 (the “EU Privacy Laws”) when gathering, using, disclosing, or otherwise processing personal data about you.  As VRC processes your personal information,  we are considered the data controller of your personal information in connection with the EU Privacy Laws.

 

Anonymous Information (the “Anonymous Information”)

We collect various types of anonymous and non-personally identifiable information, including:

  • information about the computer or device you are using to access the Services or Site (including your browser type, client type (browswer or mail program); operating system, computer and device type and model number, your device’s locate (language and country), your screen resolution, and your device’s battery information (battery status and battery level));
  • anonymous information about your viewing habits (including which VRC VR content you have watched, where you have paused or resumed such VR content, and where you are looking during your viewing of the VR content);
  • purchases you have made within the Services (including the price of any purchases and how any in-app purchases are used); 
  • information about the pages or features of the Site, or applications making available our content, you have visited or browsed, including the time spent on any such pages or features, which buttons were pressed, links which were accessed, and the date and time in which the Site and/or application was being used; 
  • anonymous crash reports; and
  • anonymous demographic information about you

 

  1. Why we collect your information

 

We collect your personal information to conduct our business and to provide you with the best possible services.

 

We also use your personal information to: 

 

  • personalize your experience; 
  • communicate with you about the services you have asked us to provide; 
  • provide you with marketing and offers from us (where we have your permission to do so); 
  • improve our services; 
  • comply with our security obligations; and
  • for industry research and analysis. 

 

We may also use Service Data in order to detect, investigate and prevent activities that may violate our other policies (http://www.thevrcompany.com/terms-of-use) or which may be illegal. 

 

If you do not want VRC to use your Personal Data to contact you for these purposes, please follow the instructions in “Your consent” below.

 

  1. Who else may have access to your information

 

To best serve you, we may share your personal information with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from VRC. 

 

We also share your personal information with third parties who deliver services either to you or to us, such as companies that provide us with analytics concerning how our Services are used.

 

We use Google Analytics in connection with performing industry research and analysis, demographic profiling and similar other purposes. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. We also use Retinad in connection with gathering information about how our Services are used.  For more information about Retinad, please visit https://www.retinadvr.com.

 

We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law.

 

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, the Service Data, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.

 

  1. Collecting your personal information

 

We are able to legally collect and use your personal information either because:

 

  • you have provided us with your consent to do so as explained above; and/or
  • collecting and using your personal information is necessary for us to:
    • carry out our legitimate business interests in order to carry out any requests or orders made by you via our Site.

 

  1. How we collect your information.

Our Website uses “cookie”, “tracking pixels” and “web beacon” technology.  We use cookies, track pixels and web beacons to distinguish you from other visitors, track your IP address and usage of our site, and to identify the name of the website from which you linked to our website.  This information is used to help us serve you better by improving our website design, as well as our products, services and promotions.  We do not otherwise track any information about your use of other websites.  Non-personal information or anonymised/pseudonymised information obtained through cookies, tracking pixels and web beacons may be shared with or obtained by service providers on our behalf.

A cookie is a small data file that is placed on the hard drive of your computer when you visit a website.  A “session cookie” expires immediately when you end your session (i.e., close your browser).  A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available

When you visit our website, we may use both a session and a persistent cookie.  This VRC-placed cookie may contain information ( such as a unique user ID) that is used to track your usage of our website and in some cases, your email address.  Your email address is only saved in this VRC-placed cookie if you register with us.  If you register with us, this VRC-placed cookie allows us to recognise you when you return to our website and provides you with access to your account information.  

You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your purchases or enable you to make a purchase from our Website.  In addition, we will not be able to recognise you as a registered user to allow you access to your account information. You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/, www.aboutcookies.org or www.allaboutcookies.org.

“Web beacons” are small pieces of data that are embedded in images on the pages of our Site and the applications through which we make our content available. The web beacon allows us to capture certain additional types of information about a visit’s actions on a website, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and the details about any items that were purchased. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use Web beacons to bring together information we collect about you. 

“Tracking pixels” are analytics tools that allow us to track the actions people take on our Site. For example, it allows us to see how many video views, comments, or Facebook “likes” we receive.  It also allows us to view some anonymous demographic information about you, including your sex and geolocation.

We may also acquire information such as demographic and geolocation information from other trusted sources to update or supplement the information we have for you so that we can improve your experience and our Services. Local law may require that you authorize a third party to share your information with us before we can acquire it.  Please note that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by such third-party site or platform. The information we collect is covered by this Privacy Policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.  We are not responsible for the content, privacy or security practices and policies of any third-party site or platform. To protect your information we recommend that you carefully review the privacy policies of all third party sites or platforms that you access

  1. Your consent

 

When you came to our website, you were asked to check a box confirming you have read this privacy policy and that you agree to us collecting your personal information and using it in the ways and for the reasons explained in this privacy policy. You can view this notice again by clicking here: www.thevrcompay.com.

 

You can tell us to stop collecting and using your personal information at any time by emailing us at legal@thevrcompany.com, or by mail on 5700 Wilshire Blvd. Ste 560, Los Angeles, CA 90036, United States of America.

 

If you tell us to stop collecting and using your personal information, the consequences of doing so are that:

  • we will be unable to update you on our promotions and product news;
  • we will be unable to provide you with customer service;
  • we will be unable to provide you with the best user experience possible to our Site; 
  • you will receive limited functionality for our Services; and
  • we may need to implement alternative transaction mechanisms for transactions taking place through our Services or the Site.

 

  1. Your rights

 

You have the right to:

 

  • be informed about the personal information we collect from you and use, which this privacy policy seeks to do;
  • obtain confirmation from us that your personal information is being collected and used by us and to access the personal information held about you by us;
  • have your personal information corrected if it is inaccurate or incomplete at any time;
  • erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time;
  • block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;
  • obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from VRC to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
  • object to us collecting or using your personal information where this is based on:
    • a legitimate interest or the performance of a task in the public interest; or
    • direct marketing.

 

To make any requests as listed above, please contact us at legal@thevrcompany.com or by mail on 5700 Wilshire Blvd. Ste 560, Los Angeles, CA 90036, United States of America.

We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

 

  1. Marketing

 

We would like to send you information via email about our Services and special offers which may be of interest to you. 

 

We will only ask whether you would like us to send you marketing email messages when you check the relevant boxes when you provide your email address to us. If you have consented to receive such marketing emails from us, you can opt out at any time. Please see “Do not contact, review, edit or removal of your Personal Data” below.  

 

  1. International transfer

Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your Personal Data to us, we may transfer your Personal Data to the United States and process it there. 

  1. Security of your information

 

We will implement appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including:

 

  • the pseudonymisation and encryption of your personal information where appropriate;
  • ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and
  • regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure. 

 

We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our Website.  

 

  1. Responding to legal requests

 

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.

 

  1. Use of the Services by Minors

 

We do not knowingly collect the Personal Data of any individuals under the age of 13 (“Minors”). 

 

If you are a Minor, do not use or provide any information on this website or on or through any of its features/register on the website, make any purchases through the website or provide any information about yourself to us, including your name, address, telephone number or email address.

 

If we learn that we have collected Personal Data of a Minor we will delete such information from our files.

 

If you believe that we might have any information from or about a Minor, please contact us at legal@thevrcompany.com

 

  1. Links to other websites

 

Our Site may include links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties (“Linked Sites”).  We provide Linked Sites to you solely as a convenience, and the inclusion of Linked Sites does not imply endorsement by us of the Linked Sites.  You access Linked Sites at your own risk and by accessing them you leave our website.  Linked Sites are not under our control and we are not responsible for the contents of any Linked Site, including the privacy policies or tracking technologies they may use.  We encourage you to check the applicable privacy policy to determine how they will handle any personal information they collect from you.

 

  1. Complaints

 

If you are an EU user and wish to raise a complaint because you believe that the processing of your Personal Data by us infringes the General Data Protection Regulation, you may email us at legal@thevrcompany.com.

 

If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is +44 (0)303 123 1113.

Last updated: May 25, 2018