Last Updated: May 23, 2018
The Purpose of this Document
Who is Who
Third Party Service Providers.Our Services may contain links to third party websites, plug-ins, or applications. Our Services may be provided through and/or utilize features operated by these third-party service providers.We may share and receive information about you from these third parties in order to provide you with the Services or support our business. We do not control these third-party service providers and their policies regarding the handling of information may be different from ours. You are responsible for reviewing the privacy statements and policies of those other websites and service providers you choose to link to or from the Service, so that you can understand how those third parties collect, use, and store your information.
Data Controller and Data Processor
Data Controller.SpringboardVR is the Controller and responsible for your personal information.
Data Processor.We may collect, use and disclose certain personal information about Customer Users when we act as the Customer’s service provider.Our Customers are responsible for making sure that the Customer User’s privacy rights are respected, including ensuring appropriate disclosures about third party information collection and use. To the extent that we are acting as our Customer’s data processor, we will process personal information in accordance with the terms of our agreement with the Customer and the Customer’s lawful instructions.
Other Important Information
If you disagree with the practices described in this policy, you should (a) take the necessary steps to remove cookies from your computer after leaving our website, and (b) discontinue your use of our Services.
You must be of legal age to enter into a contract to access or use our Services, and in any event, must be over the age of 13.
Information We Collect
Personal Information.We call information that identifies, or that could reasonably be used to identify, you as an individual “Personal Information”.Personal Information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.The information that we collect automatically, including statistical data, may not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.
The Personal Information that we may collect includes:
- Identity Data including personal contact details such as name and title.
- Contact Data including postal addresses, telephone numbers, Skype numbers, personal email addresses
- Technical Data including usernames, passwords and login credentials, IP addresses, URLs, geographic location, and language
- Financial Data such as your billing address, credit or debit card numbers, bank account information, or payment processor account information, tax identification numbers, VAT and GST numbers
- Transaction Data including your billing and payment history, products and services you use, and other information related to your account
- Marketing and Communication Data including information you provide when signing up for our mailing list, and your preferences in communicating and receiving marketing material
- Employment Data including your date of birth, photo, resume, education credentials, passport information, and Identity and Contact Data as described above
Non-Personal Information. We also collect information that is not Personal Information, and we call it Non-personal Information.
Non-personal Information includes:
- Platform Usage Data including information regarding specific use of our platform such as the dates, times, duration, status of the content launcher, station monitor and booking feature, and calls for help
- Content Usage Data including information regarding specific content use such as the dates, times, duration and station that specific content on the platform is accessed, played or reviewed; content or games on Customers’ computers and stations
- Customer Support Data including information regarding technical and administrative assistance
- Content Data including information regarding content description, pricing, and related marketing material
- Device and Software Date including information about your computer hardware and software that may be automatically collected by us such as your internet protocol (IP) address, device type, operating system, browser type, domain name, access time, working directories, certain software installed or stored by you within the Services or on game stations and computers, operating system, and any referring website addresses
- Cookie Data including tracking technology data such as time spent on the Services, pages visited, and other anonymous traffic data
- Business Data such as your business name and entity structure, jurisdiction, tax classifications, content or product offerings and materials, hours of operation, location, and licensing agreements.
How We Collect Information
Directly from You.The information we collect may come directly from you when you provide it to us:
- By filling in forms in person, or on our website or our platform
- By communicating with us through email, text, phone calls, business cards, and electronic communications between us
As You Use Our Services.As you use or interact with our Services, we may collect information certain information that may contain Personal Information or Non-Personal Information that we may tie to Personal Information collected from other sources.
- Through Automatic Data Collection Technologies.Tracking technologies such as browser cookies and web beacons.
- Through Third Party Service Providers or publicly available sources.We may receive Personal Information and Non-Personal Information from third parties such as our service providers or publicly available sources.
We may also use a web beacon to collect information.A web beacon is small electronic file that may be contained on pages of our website and our emails that allow us, for example, to count users who have visited those pages or opened an email and to gather other related website statistics.
If You Fail to Provide Personal Information.Where we need to collect Personal Information under the terms of a contract we have with you or by law, and you fail to provide that information when requested, we may not be able to perform the contract we are trying to enter into with you.In that event, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.It is important that the Personal Information we hold about you is accurate and current.Please keep us informed if your Personal Information changes during your relationship with us.
How We Use Information
We will only use your Personal Information when the law allows us to do so.Most commonly, we will use your Personal Information on the following legal bases:
- Where we need to perform the contract we have entered into with you
- Where we need to comply with a legal obligation
- Where we have your consent
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do no override those interests.
- And in rare cases, where we need to protect your interests or it is needed in the public interest.
Some of the legal basis or grounds for processing information will overlap and there may be several grounds to justify our use of your Personal Information.The situations in which we will use your Personal Information and the lawful basis for processing that information are listed in the table below:
Use or Purpose | Type of Personal Information/Data Processed | Lawful Basis for Processing
To provide and maintain our Services | Identity, Contact, Technical, Financial, Transaction, Marketing and Communication | Performance of a contract Your consentNecessary for our legitimate interest
Monitor and analyze use and functionality of our Services | Technical, Transaction, Marketing and Communications | Performance of a contractNecessary for our legitimate interest
Gain a better understanding of your usage patterns for our Services | Identity, Technical, Transaction, Marketing and Communications | Performance of a contractYour consentNecessary for our legitimate interest
Improve your user experience with our Services | Identity, Contact, Technical, Financial, Transaction, Marketing and Communication | ConsentNecessary for our legitimate interest
Provide customer, technical and administrative support | Identity, Contact, Technical, Financial, Transaction, Marketing and Communication | Performance of a contractNecessary for our legitimate interest
Process e-commerce transactions | Identity, Contact, Financial, Transaction, Employment | Performance of a contractNecessary for our legitimate interest
Communicate information about us and our Services | Identity, Contact, Technical, Marketing and Communication | Performance of a contractYour consentNecessary for our legitimate interest
To notify you about changes to our Services and to make recommendations to you about products or services that may be of interest to you | Identity, Contact, Technical, Transaction, Marketing and Communication | Performance of a contractNecessary for our legitimate interest
Streamline your onboarding process and the use of our Services | Identity, Contact, Technical, Financial, Marketing and Communication | Performance of a contractYour consent
For the administration of files and records including accounting | Identity, Contact, Technical, Financial, Transaction, Employment | Performance of a contractNecessary for our legitimate interestNecessary to comply with a legal obligation
To engage, hire and onboard consultant, contractors and employees | Identity, Contact, Technical, Financial, Employment | Performance of a contractNecessary for our legitimate interestNecessary to comply with a legal obligation
To prevent fraud or comply with applicable laws, regulations, and enforcement agency requests | Identity, Contact, Financial, Transaction, Technical | Necessary for our legitimate interestNecessary to comply with a legal obligation
To fulfill any purpose described with your consent | Identity, Contact, Financial, Transaction, Technical, Marketing and Communication | Your consent
Marketing and Promotional Offers From Us.We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you.This is how we decide which products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or registered an account with us or if you provided us with details when you signed up for our mailing list, and in each case, you have not opted out of receiving that marketing.
Opting Out.You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.Please note that we may still send you important administrative messages, notices or alerts that are required to provide you with our Services.
Disclosure of Information
We do not give away, sell, rent or lease Personal Information to any merchant, advertiser, or web publisher. We may disclose aggregated information about you and the use of our Services, and information that does not identify any individual without restriction. We may disclose information relating to the use, performance, sales, downloads, uploads, installations of our Services and content on our platform without restriction, as long as such information does not include your Personal Information.
- Our subsidiaries and affiliates
- Our third-party service providers, contractors, consultants, vendors, suppliers, employees, and third parties we use to support our business
- Our Customers to fulfill our contractual reporting obligations
- A buyer of our company or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- Lawful authorities in order to comply with the law or a legal process or cooperate with investigations
- Appropriate authorities if we believe disclosure is necessary to protect the rights, property, or safety of you, SpringboardVR or others.
We use have implemented reasonable organizational, technical, and administrative measures to protect your Personal Information within our organization. We limit access to your Personal Information to those employees, contractors, consultants, or third parties who have a business need to know.They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.Unfortunately, even with these measures, no data transmission or storage system can be guaranteed to be totally secure.By using our Services, you acknowledge and agree that we make no such guarantee, and that you use our Services at your own risk. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].
We will retain Personal Information for the period necessary to fulfill the purpose we collect it for unless a longer retention period is required or permitted by law.To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means, and the applicable legal requirements. By law for tax and business purposes, we may have to keep basic data about our Customers for 7 years even after they cease being Customers.
Rights of Access, Correction, Erasure and Restriction
In regard to your Personal Information, under certain circumstances, by law you have the right to:
- Request access to your Personal Information (commonly known as “data subject access request”).This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Information that we hold about you.This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Information.This enables you to ask us to delete or remove Personal Information where there is no good reason for use continuing to process it.You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your Personal Information.This enables you to ask us to suspend the processing of Personal Information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Information to another party.
If you want to review, verify, correct or request erasure of your Personal Information, object to the processing of your Personal Information, or request that we transfer a copy of your Personal Information to another party, please contact us by email at [email protected].
We may need to verify your identity before acting upon your request and we may have to retain certain information for legitimate business or legal purposes.In addition, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.Generally, we will respond to your request within 30 days from the date you contact us.
Right to Withdraw Consent
In limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consentfor processing at any time.To withdraw your consent, please contact us at[email protected].Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Service-Specific Privacy Terms.
Children Under the Age of 13.
Our Services are not intended for children under 13 years of age and we do not knowingly collect Personal Information from children under 13. No one under age 13 may provide any Personal Information to the Services. You shall not disclose to us any personally identifiable information from anyone 13 or under unless you have express parental permission to do so. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
Jurisdiction and Cross-Border Transfers.
European Union Data Protection.If you are located in the European Union ("EU") or the European Economic Area ("EEA"), transfer of personal customer data outside of the EU or EEA is regulated by certain EU data protection laws.SpringboardVR has adopted the EU Model Clauses which are standardized contractual clauses used to ensure that personal data leaving the EEA will be transferred in compliance with these laws.
Notice to California Residents/Your California Privacy Rights.To opt out of sharing your Personal Information with third parties for their direct marketing purposes, please e-mail us at[email protected] and clearly state your request, including your name, mailing address, e-mail address and phone number.
Data Supervisory Authority
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues (www.ico.org.uk).We would, however, appreciate the chance to deal with your concern before you approach the ICO so please contact us in the first instance.
3334 West Main Street #389
Norman, Oklahoma 73072