Last Updated and Effective: July 4, 2022
- What kind of information do we collect?
- How do we use information?
- How is information shared?
- Cookies and Other Tracking Technology
- How do we respond to legal requests and prevent harm?
- Information for California Residents
- How will we notify you of changes to this policy?
- Contacting Us
1. WHAT KIND OF INFORMATION DO WE COLLECT?
Personal information is information that relates to or can be used to identify you, either alone or in combination with other information. The personal information collected through the Products include:
- Information Automatically Collected. We collect information automatically when you are connected to the Products. Depending on how you access and use Products, we collect information such as:
- Information about your interactions with Products, like information about the content, apps, features, or other experiences you interact with, including information collected through or from content provided by our third-party partners;
- Information collected in or through cookies, local storage, pixels, and similar technologies on the website (additional information about these technologies is available below in the section titled Cookies and Other Tracking Technologies);
- Information about how you access our website, including information about the type of device you're using (such as a computer, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing;
- Information about the features you interact with on the Products. For example, we receive information about your Products usage, such as interactions with recommended pages, which browser features you use, and other statistics related to your Products usage. Note that personally identifiable information from your mobile device is used by the app to function properly. This information is only accessed real-time while the app is in use and never leaves the mobile device to be stored elsewhere (exceptions apply: see section 3.3).
- Location-related information, which can be derived from information such as your device’s IP address. If you’re using a mobile device, some of our Products collect information about the device’s precise location, which is derived from sources such as the device’s GPS signal and information about nearby Wi-Fi networks and cell towers. Note that personally identifiable information from your mobile device is used by the app to function properly. This information is only accessed real-time while the app is in use and never leaves the mobile device to be stored elsewhere (exceptions apply - see section 3.3);
- Information about your environment, physical movements, and dimensions when you use the AR experience. Note that personally identifiable information from your mobile device is used by the app to function properly. This information is only accessed real-time while the app is in use and never leaves the mobile device to be stored elsewhere (exceptions apply - see section 3.3); and
- Information we receive through device settings you choose, such as app permission to access your camera or location, which we will process in real-time to make all features of the app available to you.
- Information You (and others) Provide. We collect the information you (and others) give us when using Products. For example:
- We collect information about the content, and experiences you connect to and how you interact with them across our Products.
- When you communicate with us, you provide us with information like your email address and location.
- Camera and Photos. Some of our services require permission to access your device's camera and photo gallery. For example, you won't be able to take selfies and upload photos to your camera roll unless we can access your camera and photo gallery. Note that when using these features in the app, personally identifiable information is only accessed real-time while the app is in use and never leaves the mobile device to be stored elsewhere (exceptions apply - see section 3.3).
- Information From Third Parties. We also receive information from third parties, including third-party apps, developers, other online content providers, and marketing partners that provide us statistics about the effectiveness of advertisements prompting to the website or app store to download our app.
The following provides examples of the type of information that we collect from you when you visit our website and how we use that information:
|Context||Types of Data||Legal Basis for Collection and Use of Data|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback or issues.|
|Website interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.|
2. HOW DO WE USE INFORMATION?
In addition to the uses set forth above, we use personal information as set out below and to provide our Products to you and our partners for the following purposes:
- To provide and personalize our Products. We have a legitimate interest in using the information we collect to provide you with our Products. For example, we use this information to:
- Provide you with content, apps, and other experiences;
- Provide technical support; and
- Customize your experiences on our Products based on your activities, including the content, activities, apps, and other experiences you interact with, the other online services you use, and other information we collect. This allows us to make your experience unique and relevant to you, for example by showing you content that is most relevant to you based on your behavior in the app. Note that personally identifiable information collected by the app will be stored on your mobile device only and will not be stored by us elsewhere (exceptions apply - see section 3.3).
To improve and develop your experience and our Products. We have a legitimate interest in using the information we collect to understand and improve our Products and to develop the AR ecosystem. For example, we use the information to:
- Identify and address technical issues on our Products; and
- Improve and develop our features.
Note that personally identifiable information from your mobile device is used by the app to function properly. This information is only accessed real-time while the app is in use and never leaves the mobile device to be stored elsewhere (exceptions apply - see section 3.3).
- To communicate with you. We have a legitimate interest in using the information we collect to respond to your inquiries, provide customer services, and otherwise as needed to manage and administer your use of the Products.
- To promote safety, integrity and security. We have a legitimate interest in using the information we collect to verify activity, combat harmful conduct, detect and prevent bad experiences, maintain the integrity of our Products, and promote safety and security on and off our Products. For example, we use information collected to investigate suspicious activity or violations of our terms or policies, detect when someone needs help, and protect our or others’ rights or property.
3. HOW IS INFORMATION SHARED?
Our Products help you engage with the AR ecosystem and others that interact with it. To provide and support our Products, information we have about you is shared in certain circumstances. Here is who can see information about you when you and others use our Products.
- People and accounts you share and communicate with on our Products. When you share, interact, and communicate using our Products, you choose the audience for what you share. For example, when you share a photo or other content in a public virtual space, other people who visit the space may be able to see it.
- Apps, Developers, and Other Online Content Providers on our Products. You can interact with third-party content, activities, apps, and other experiences through our Products. We share information about you with these partners, so they can provide you with the experiences you've requested, such as:
- Information about how you use our Products.
- Information about your interaction with the third-party service, such as how long you have interacted with content.
- Any other information you choose to share with the third party.
Third-party content providers may also collect information from you directly through the experiences they provide. Please note that any information you share with these (or other) third parties will be subject to those third parties’ own privacy policies, not this one.
- Service providers. We share the information we collect with vendors, service providers, and other partners, who work at our direction to support the Products (such as hosting our Products, providing an AR experience, or analyzing the way people use our Products,). For example, we utilize a service provider to develop and maintain the Products.
- Law enforcement or legal requests. We share information with law enforcement or in response to legal requests in the circumstances outlined in Section 6 below.
We also share de-identified or aggregate data with others. De-identified data means information where we have removed your name and other data that could reasonably be used to identify you. Aggregate data is data that has been combined with other data so that it doesn’t identify any specific person.
4. COOKIES AND OTHER TRACKING TECHNOLOGY
Products may collect information by using technologies and methodologies, such as tags, web beacons or other similar technologies that enable tracking as you browse the Products. Cookies are small files used by many websites that reside on your computer’s hard drive and store information about your use of a particular site.
Generally, we use first-party and third-party cookies for the following purposes: to make our Products function properly; to provide a secure experience during your use of Products; to collect passive information about your use of Products; to measure how you interact with our marketing campaigns; to help us improve Products; and to remember your preferences for your convenience.
We may use the following types of cookies on our Products:
- Strictly Necessary Cookies – These cookies are essential because they enable you to use our Products. For example, strictly necessary cookies allow you to access secure areas on our Products. Without these cookies, some Products cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Products to work and they cannot be disabled.
- Functional Cookies – We use functional cookies to remember your choices so we can tailor Products to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your preferences. We do not use functional cookies to target you with online marketing.
- Performance or Analytical Cookies – These cookies collect passive information about how you use Products, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize Products. We do not use these cookies to target you with online marketing.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Products by taking the steps outlined below:
- First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of Products may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
- Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
Some jurisdictions give you a right to make the following choices regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you access to the personal information that we have about you.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
- Data Portability. If applicable, request your personal information be ported (transferred) to another company.
To exercise any of these rights, email us at Privacy@jamestownlp.com, submit a request via our Web Form. Please note, not all these rights are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your requests to access, modify, or delete your information, or to revoke consent or object to processing. This may occur because the law permits or requires us to do so.
If you are not satisfied with our response to any of the above, you may have a right to lodge a complaint with your local supervisory authority or appeal our denial of your request by contacting us using the above methods.
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.
5. HOW DO WE RESPOND TO LEGAL REQUESTS AND PREVENT HARM?
We access, preserve and share information with regulators, law enforcement or others in response to a legal request (like a search warrant, court order or subpoena), if we have a good faith belief that the law requires us to do so. This includes responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
Information we receive about you, including your location, web behavior, and financial transaction data related to purchases made on or through our Products, can be accessed, processed and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from Products accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other term violations.
6. INFORMATION FOR CALIFORNIA RESIDENTS
This Section 7 applies only to California residents and contains the information that the California Consumer Privacy Act of 2018 (“CCPA”) requires us disclose. For purposes of this Section 7 only, “Personal Information” has the meaning given in the CCPA, but excludes information exempted from the scope of the CCPA. This Section describes Products’ collection, use and sharing practices in relation to Personal Information of California residents during the twelve (12) months preceding the effective date of this notice, and informs California residents of their rights with respect to that Personal Information. We do not “sell” your personal information.
- Categories of Personal Information we collect may include:
- Internet or other electronic network activity information;
- Location-related information, including precise device location if you choose to allow us to collect it;
- Information derived from other Personal Information about you, which could include your preferences, interests, and other information used to personalize your experience.
Personal Information is used for the purposes described in Section 1, and may be shared for the business and commercial purposes described in Section 2.
- Sources of Personal Information
We receive Personal Information from the information that you and others provide, from your device(s), and from our partners. The categories of sources from which we’ve collected or received Personal Information include:
- You: We collect information about how you use our Products, such as information about the activities, content, apps, features, or other experiences you interact with. App activity is collected in an anonymized form by generating a random number for each app user and tracking activity against that number.
- Your device(s): We collect information from and about the devices you use to access our website, including information about the type of device you're using (such as a desktop, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing.
- Partners: We may receive information about you from partners, including third-party apps, developers, other online content providers, and marketing partners that provide us information.
- How can you exercise your rights provided under the CCPA?
Under the CCPA, you have the following rights:
- Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
- Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
- Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
Please note that to protect your information and the integrity of our Products, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as your name and proof of residence.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must provide either a copy of the signed permission given to you by the individual or a power of attorney executed in accordance with California law.
CALIFORNIA INFORMATION SHARING DISCLOSURE
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in connection with the cookie technology used on our website. In addition, we may disclose information when requested to government entities, auditors, lawyers, consultants, and other parties as required by law concerning any category (e.g., in response to a subpoena). .
|Categories of Personal Information We Collect||To Whom We Disclose Personal Information for a Business Purpos|
|Internet or other electronic network activity information — This may include browsing history, search history, and information regarding an individual's interaction with an internet website or advertisement.|
We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control and limit the collection of personally identifiable information to a minimum. In the event that we are required by law to inform you of a security incident involving your information we may notify you electronically or in writing, if permitted to do so by law.
8. HOW WILL WE NOTIFY YOU OF CHANGES TO THIS POLICY?
9. CONTACTING US