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ARTICLE I.PRIVACY POLICY

Last Updated: October 25, 2022

ARTICLE II.Section 1 – Introduction:

VR.Space (“Website”) is owned and operated by VR Space LLC (“us” or “we”), which provides the VR environments and related features and content for download via the Website, e-newsletters, and other content posted on the Website (collectively, “Content”). The purpose of this Privacy Policy is to explain how we collect, use, store, share, and protect the personal information of users (“you” or “your”) of the Website and our Content.

When we refer to “personal information” we mean information that identifies, or is reasonably capable of being directly or indirectly linked to, a particular individual or household, such as the individual’s name, postal address, email address, social media profile, and telephone number. Personal information includes “personal information” as defined by the California Consumer Privacy Act of 2018 (the “CCPA”) and “personal data” as defined by the European Union’s General Data Protection Regulation (the “GDPR”). When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as personal information. Personal information does not include aggregate information that we collect about the use of our Website or Content or about a group or category of users from which individual identities or other personal information has been removed.  Nor does it include usage information or device identifiers not connected to personal information.

Our Terms of Use governs your access to and use of our Website and Content, the details of which we encourage you to read carefully.

Please note, this Privacy Policy does not apply to privacy practices of those third parties. We encourage you to review the privacy policies of any third-party application or website provider before providing any personal information to or through them. Additionally, we use third-party service providers to (i) host the Website, (ii) maintain our subscriber list and send out the e-newsletters, and (iii) analyze data; and we may provide links to third-party websites.  In addition to our Terms of Service and Privacy Policy, your interactions with these vendors and third-party websites will be subject to their respective terms of use/terms of service and privacy policies, which we encourage you to review.  

ARTICLE III.Section 2 – Information We Collect:

ARTICLE IV.Information You Provide to Us Directly:

  1. Information collected when you register for the Subscription: When you first register for the subscription to gain access to all Content (the “Subscription”), you must provide us with your first name, last name, and email address, and create a user name and password, which we use to setup your user account and provide you with information about the Subscription. Additionally, you will be required to provide your payment information, which can include your name, card number, expiration date, security code, and billing address. We do store your payment information to allow your Subscription to auto-renew.

  2. Information collected when you edit your profile: We give you the option to populate your profile by entering additional information about yourself. You can limit the amount of information you provide in your profile.

  3. Information collected when you communicate with us electronically: When you contact us through email, our social media accounts, SMS, or other means of communication, we, or our third-party support service provider, may collect and store personal information you provide, such as your name, email address, phone number, mailing address, physical address, and the contents of your communication.

  4. Information collected when you sign up to receive emails: You have the option to sign up for our e-newsletters by providing us with your email address. If you do so, we use the email address you provide to send you information related to the Website and its Content that we think might be of interest to you. Please note if you elect to unsubscribe from emails, it may take up to 30 days for us to process your request to unsubscribe.

ARTICLE V.Information We Receive from Other Sources:

  1. Payment Processors: When you purchase a Subscription Service or featured product, your payment information is provided directly to our third-party payment processor. We store your payment information in order to automatically renew your Subscription Service membership each year and allow for processing future purchase of featured products.

  2. Third-Party Service Providers: We use third-party service providers to (i) host the Website, (ii) maintain our subscriber list and send out the e-newsletters, and (iii) analyze data. These service providers often use cookies and tracking technologies, broadly referred to as tags, to store your information and track your activities on or in connection with our Website. Through the use of tags, such as cookies, our third-party service providers may obtain and share with us information such as: (i) when you open emails or click on certain links; (ii) details about your interaction with the Website and its content, such as the date, time, length of your visit, the specific pages accessed, and search terms used; (iii) information about your device, such as your IP address or other device identifier, hardware model, operating system, and browser type; and (iv) your general location, inferred from your IP address.

  • WordPress. Our Website is hosted by WordPress. To learn more about WordPress’s collection and use of your personal information, click here: https://wordpress.org/about/privacy/

  • WordPress’s Cookie Policy. You can also learn more about WordPress’s Cookie Policy here: https://wordpress.org/about/privacy/cookies/  

ARTICLE VI.Do Not Track Signals:

We do not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

ARTICLE VII.Section 3 – How We Use Information We Collect or Receive:

We may disclose your personal information, as well as non-personal information, such as aggregate user statistics, to companies and individuals who perform business functions on our behalf or to other third parties to support the development and functionality of our Website and Content.  Such functions may include hosting our Website, e-newsletter database, or analyzing data, providing technical assistance, customer service, or marketing assistance, or other support services.  All such parties are required to keep your personal information secure and only process it in accordance with our instructions. We may also disclose your personal information if required by law. We, or our third-party service providers, use the personal information we collect or receive to do the following:

  • enhance our Website and Content;

  • provide content, services, products, or information you request, including processing your purchases and identifying you when you sign into an account;

  • provide notifications;

  • recommend content or websites we think would be of interest to you;

  • communicate with you about content, products, services, promotions, and events we offer;

  • solicit your feedback;

  • post testimonials;

  • respond to your emails, submissions, questions, inquiries, request, and comments;

  • monitor and analyze views and trends and otherwise measure the appeal and effectiveness of our Website and Content;

  • verify your account or monitor suspicious or fraudulent activity;

  • identify, fix, and troubleshoot bugs and service errors;

  • send you confirmations, updates, security alerts, and support-related messages; and

  • protect against, identify, investigate, and respond to misuse of our Website or other unlawful behavior.

With your consent, we may use your personal information for a specific purpose not listed above.  

ARTICLE VIII.Section 4 – Retention of Your Personal Information: 

We retain your personal information for so long as we have an ongoing legitimate business or legal need to do so. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

ARTICLE IX.Section 5 – Security:

We strive to maintain adequate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We are not liable for unauthorized disclosure of information that occurs through no fault of our own.  If we learn of a data breach that is likely to result in a high risk to your rights and freedoms, we will immediately notify you of such data breach and inform you of (a) the nature of the data breach, (b) the point of contact regarding the data breach, (c) the likely consequences of the data breach, and (d) the measures being taken to address the breach and mitigate its possible risks.

ARTICLE X.Section 6 – Accuracy of Your Information:

Although we work to ensure that the information we hold about you is accurate and up-to-date, unless we receive an indication otherwise, we can only assume that the information you provide to us is accurate. If you inform us that any of your information processed through our Website is incorrect, or if we learn that any such information is incorrect, we will work to promptly correct, or if appropriate, erase, such information.

ARTICLE XI.Section 7 – Your California Privacy Rights and Notice at Collection:

This portion of the Privacy Policy is provided under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), and supplements this Privacy Policy by providing certain disclosures to California residents and explaining the privacy rights of California residents.

ARTICLE XII.Categories of Personal Information Collected and Disclosed:

We have collected the following categories of personal information and shared them with the following categories of third parties.

  • A. Identifier, such as, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • Advertisers and marketing-related service providers (IP address and online identifier only)

    • Operating systems and platforms

  • B. Commercial information, including user engagement with the Website, the Content, and other content.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • Advertisers and marketing-related service providers

    • Operating systems and platforms

  • C. Internet activity and network activity, including user interactions with the Website, the Content, or content and what led you to the Website.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • Advertisers and marketing-related service providers

    • Operating systems and platforms

  • D. Geolocation data provided through location enabled services such as WiFi and GPS.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • Advertisers and marketing-related service providers

    • Operating systems and platforms

  • E. Inferences, including information about user interests, preferences, and favorites.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • Advertisers and marketing-related service providers

    • Operating systems and platforms

  • F. Additional Information, that you choose to share with us through our Website or on social media platforms.

  • Parties with whom we disclose this category of personal information:

    • Service providers that perform services on our behalf

    • With other users – when you share your personal information or otherwise interact in public areas, such as third-party social media platforms, with other users, such information may be viewed by all users and might be shared by other users.

ARTICLE XIII.Categories of Sources of Personal Information:

We collect personal information from the following categories of sources:

  • Directly from you

  • From cookies and similar technologies

  • From third-party sites or apps, content distribution channels, and platforms

  • From third-party service providers, data suppliers, and business partners

  • From social media platforms and similar services

  • From third-party payment processors

  • From internet service providers

  • From operating systems and platforms

ARTICLE XIV.Business or Commercial Purposes for Collecting or Sharing Personal Information:

See Section 3 – How We Use the Information We Collect or Receive above for the business or commercial purposes for which we collect or share personal information.

ARTICLE XV.Sale of Personal Information:

In the preceding 12 months, we have not sold our users’ personal information. However, the term “sale” is defined broadly under the CCPA. As explained above, we do share with our service providers personal information that is necessary for such service provider to perform a business purpose. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us (see below for our contact information). 

To our knowledge, we do not sell the personal information of individuals under 16 years old.

ARTICLE XVI.Notice of California Residents’ Rights:

If you are a resident of California, you have the following rights under the CCPA with respect to your personal information:

  • The right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions.  

    • We may deny your deletion request if retaining the information is necessary for us or our service provider to: complete the transaction for which the personal information is collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech or ensure the right of another user to exercise his or her free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with applicable laws; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

  • The right to opt-out of the sale of your personal information to third parties. We do not sell the personal information of users of our Website or Content.  However, the term “sale” is defined broadly under the CCPA. We do share with our service providers personal information that is necessary for such service provider to perform a business purpose. This Privacy Policy describes the limited circumstances in which we share your personal information with third parties. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us as provided below. If, in the future, we do sell users’ personal information to a third party, we will provide users with the opt-out and opt-in rights required under the CCPA. 

  • The right to request that we provide you with information regarding the processing of your personal information over the preceding 12 months, including the categories of personal information we have collected about you, specific pieces of personal information we have collected about you, sources from which it was collected, categories of personal information disclosed, the business or commercial purpose for collecting or disclosing personal information, and categories of third parties with whom your personal information is shared.

  • The right to request that we disclose to you the categories and specific pieces of personal information that we have collected in the preceding 12 months.

  • The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred under the CCPA.  Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services, based on your exercise of your rights under the CCPA.  If we do choose to offer you financial incentives permitted under the CCPA that result in different price rates, or quality levels, such CCPA-permitted financial incentives will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.  Participation in any financial incentive program requires your consent, which you may revoke at any time.

  • The right to correct inaccurate personal information.

  • The right to opt-out of sharing personal information for cross-context behavioral advertising purposes.

  • The right to limit the use and disclosure of sensitive personal information.

To request information regarding our processing of your personal information or request that we delete personal information about you that we have collected, you must submit a verifiable consumer request to us via email to [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Thus, your verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.

  • Describe your request in sufficient detail that allows us to properly understand, evaluate, and respond to your request.

We will acknowledge receipt of your request and advise you on how long we expect it will take to respond if we are able to verify your identity.  We will work to process your request within 45 days pursuant to the CCPA.  If we need additional time in order to process your request, we will provide you with an explanation for the delay. If we are unable to honor your request, we will advise you of this fact and provide the reason why. 

We will not provide social security numbers, driver’s license numbers, account passwords or security questions and answers, or any specific pieces of information that could lead to unauthorized access, result in identity theft, fraud, or impose an unreasonable risk to data or systems and network security.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that your request warrants a fee, we will inform you of the reason for this decision and provide a cost estimate before completing your request.

ARTICLE XVII.Section 8 – UK and EU Residents’ Rights:

If you are located in the European Economic Area or the United Kingdom, you have the rights outlined below with respect to your personal information. When we use the term “processing” or “processor” this refers to the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, use, transmission, dissemination, combination, erasure, or destruction of information.

Right to Information Regarding the Processing of Your Personal information:  You have the right to obtain the following information:

  • confirmation of whether and where we are processing your personal information;

  • information about the purpose of the processing of your personal information;

  • information about the categories of personal information being processed;

  • information about the existence of, and an explanation of the logic involved in, any automated processing of your personal information that has a significant effect on you;

  • information about the categories of recipients with whom your personal information may be shared; and

  • information about the period for which your personal information will be stored or the criteria used to determine that period.

This Privacy Policy is intended to provide much of the information listed above.

Right to Access to Your Personal information:  You may request a copy of your personal information that we, or our third-party processors, collect and maintain. Similarly, you have the right to, when technically feasible, have your personal information transferred to another entity to determine the purpose and means of processing your personal information.

Right to Have Errors Corrected:  You have the right to rectification of inaccurate personal information.  If you notify us that any of your personal information is inaccurate or incomplete, we have the responsibility to, either directly or through our third-party processors, ensure that such personal information is erased or corrected.

Right to Have Personal information Erased or Processing Restricted: You have the right to have your personal information erased when (i) the personal information is no longer needed for its original purpose and no new lawful purpose exists; (ii) the personal information is being processed based solely on your consent and you withdraw your consent; or (iii) the personal information is being processed unlawfully.  Similarly, you have the right to limit our use of your personal information when (i) the personal information is no longer needed for its original purpose, but we still need to maintain the personal information to establish, exercise, or defend legal rights; (ii) the personal information is being processed unlawfully; or (iii) the accuracy of the personal information is contested, but then our use of the personal information is restricted for only so long as it takes to verify the accuracy of the personal information. 

Right to Object to Processing of Your Personal information: You have the right to object to our processing of your personal information if the basis for that processing is (a) public interest; or (b) our own legitimate interests in doing so.  Additionally, you have the right to object to the processing of your personal information for the purpose of direct marketing or statistical purposes.

Right to Lodge a Complaint with a Supervising Authority:  You have the right to lodge a complaint concerning the processing of your personal information with your country’s independent public authority designated to act as its data protection “supervising authority” under the GDPR.

Right to Withdraw Consent to the Processing of Your Personal information:  You have the right to refuse to consent to, and to withdraw your consent to, the processing of your personal information.  To the extent we rely on your consent to collect and store your information, when you withdraw such consent we must cease collection and retention of such information.  Note, however, we do not require your consent to collect or otherwise process your personal information if (a) such information is not personal information or (b) such information is personal information and we have another lawful basis for processing the information (for instance, processing of such information is necessary for the purpose of a legitimate interest of ours that is not overridden by your interests or fundamental rights and freedoms).

Responses to your requests to us regarding your personal information will be provided free of charge (including copies of materials), except that we may charge a reasonable fee for any repetitive requests, manifestly unfounded or excessive requests, or further copies.  Similarly, we may refuse to act upon requests that are manifestly unfounded or excessive.  

ARTICLE XVIII.Lawful Basis for Processing Personal information:

We process personal information, whether directly or through third-party processors, as needed for the performance of a contract or in order to take steps prior to entering into a contract.  We also process personal information, whether directly or through third-party processors, as needed for purposes of our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of our Website visitors or subscribers. Our legitimate interests include enhancing Content, informing you of content, services, and products that might be of interest to you, responding to communications initiated by you, and protecting the security of our Website and your personal information. In some instances, we might request your consent to process personal information for a particular purpose and in such instances the lawful basis for such processing is your consent.

ARTICLE XIX.Section 9 – Notice to Non-U.S. Residents:

Our Website and servers are operated in the United States. If you are located outside of the United States, please be aware that your personal information may be transferred to, processed, maintained, and used on computers, servers, and systems 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 use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States.

ARTICLE XX.Section 10 – Children:

Our Website is for a general audience and is not directed to children under 13, nor are children under 13 permitted to use our Website. See our Terms of Service. We will not knowingly allow anyone under the age of 13 to use the Website or provide us with personal information.  If you become aware that your child has provided us with personal information, please contact us immediately.  Parents have rights under the Children’s Online Privacy Protection Act (“COPPA”) to control what information is collected from their young children online and we respect those rights.

ARTICLE XXI.Section 11 – How to Contact Us:

If you have any questions, concerns or requests related to this Privacy Policy, our practices related to our Website, or your personal information, please contact us via email at [email protected]

If we have reasonable doubts about the authenticity of any request to us, we may request additional information necessary to confirm your identity.

ARTICLE XXII.Section 12 – Updates and Changes to Our Privacy Policy:

We may modify this Privacy Policy from time to time.  We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.  If we have your email address, we might notify you of any changes to our Privacy Policy when they occur. 

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