Information about Vicinity Virtual Reality

Privacy Policy

PRIVACY POLICY – VICINITY VIRTUAL REALITY

INTRODUCTION: 

Welcome to Vicinity Virtual Reality Limited’s Privacy Policy.

Your privacy is very important to us. We recognise that when you choose to provide us with information about yourself you trust us to act in a responsible manner. We believe this information should only be used to help us provide you with better service. That’s why we have put policies in place to protect your personal information.  Our Privacy Policy is intended to inform you how we gather, and use your personal information. It is also intended to assist you in making informed decisions when using our website and our products and services. Please take a minute to read and understand the policy. 


1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how Vicinity Virtual Reality collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter(s) or purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.

 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

CONTROLLER  

Vicinity Virtual Reality Ltd. is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy or our privacy practices, please contact us by the following methods:

Email address: joel@vicinityvr.com

Postal address: 11 Hangmans Lane, Welwyn, Hertfordshire, AL6 0TJ, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

We keep our privacy policy under regular review. This version was last updated on 05/07/2018. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2.  THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our products or services;
  • Create an account on our website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.


4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.


Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

  • i) To register you as a new customer.

Type(s) of data: (a) Identity; (b) Contact

Lawful basis for processing: Performance of a contract with you


  • ii) To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.


Type(s) of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction

Lawful basis for processing: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us)


  • iii) To manage our relationship with you which, will include notifying you about changes to our terms or privacy policy.

Type(s) of data: (a) Identity; (b) Contact; (c) Profile

Lawful basis for processing: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers user our products/services)


  • iv) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.


Type(s) of data: (a) Technical; (b) Usage

Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)


  • v) To make suggestions and recommendations to you about services that may be of interest to you.


Type(s) of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and Communications

Lawful basis for processing: Necessary for our legitimate interests (to develop our products/services and grow our business


MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, Technical, Usage and Profile Data 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 purchased services via our website and you have not opted out of receiving that marketing.

 

THIRD-PARTY MARKETING  

We do not share any of your personal data data with any third-party.

 

OPTING OUT  

You can ask us to stop sending you marketing messages at any time.

 

COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies used on our site, please see Sharetribe’s cookies policy at https://www.sharetribe.com/privacypolicy.html.


CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We do not share any of your personal data data with any third-party.


6.  INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area (EEA). 


7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, and contractors 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.


8.  DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. The rights are as follows:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent


If you wish to exercise any of the rights set out above, please contact us using the “Contact Us” facility on our website.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

10.  GLOSSARY  

 LAWFUL BASIS  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal obligation  means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


Sharetribe Ltd:

Registrar

Vicinity Virtual Reality service: Sharetribe Ltd
www.sharetribe.com
info (at) sharetribe.com

Contact person

Antti Virolainen
Kirjurinkuja 3 F 46 02600 Espoo
+358-50-5311793
antti.virolainen (at) sharetribe.com

Name of the register

User register of the Vicinity Virtual Reality service

Use of personal details (purpose of register)

Personal details are collected to make communication and use of service possible. Details can be used for communication between service providers and users and also for direct communication between users. Some personal details are visible on the profile page of the user, but those details are voluntary (except name).

The handling of personal details is not outsourced, but the register data is stored on a server that is rented from a third party company.

Information content of the register

The following information may be stored in the register:

  • Personal details: Name, email address, phone number, street address
  • Account details: username, password (stored in encrypted format)
  • The description text that the user may write about him/herself
  • The offers and requests the user has posted to the service
  • The given and received feedback and badges
  • Statistical data about service usage, e.g. number times the user has logged in

Regular sources of information

Personal details are given by the user on registration to the service or when using it later.

Regular handovers of the information

The information may be handed over for research purposes as described in the Terms of use that the user accepts before starting to use the service. The researchers may not publish any research results so that identifying information would be revealed or that any specific user could be detected.

Information considering users of a single Vicinity Virtual Reality community may be handed over to the client who has founded that community or to the community administrators appointed by that client.

Transfers of the information outside the EU and the European Economic Area

Information may be stored to a server that may be located inside or outside of the EU and the European Economic Area

Register protection principles

The information is stored on computers. The access to the information is restricted with passwords and physical access to the computers is restricted by the server hosting company.