Last Updated: July 9, 2019
This Privacy Notice is meant to explain how information is collected, processed, used and disclosed by us, Jaunt, Inc., with respect to your access and use of services that we offer through any of our websites, emails, and mobile applications (collectively the “Service”). In addition, if you participate in filming as part of our XR Cast product or other related products (collectively, “XR Cast”), then the “Service” shall, as applicable, also include XR Cast. This Privacy Notice doesn’t apply to any third-party websites, services or applications accessed through our Service.
Information You Provide
We will collect personal information from you when you use our Service. When you use our Service, you consent to our collection, processing, use, and disclosure of information about you as described in this Privacy Notice.
Note regarding children: We do not knowingly collect personal information from children. If we learn that we have collected personal information of a child under 16, then we will take steps to delete such information from our files as soon as possible.
Note regarding international users: Your information will be transferred to and maintained on computers located in the United States (or the United Kingdom) and processed there.
How Do We Collect Information?
We collect information (both automatically and when we ask you to provide it) when you use the Service. We may also acquire a business that has information about you.
What Information Are We Collecting?
Information you give us. Information we ask you to provide us may include, for example, your name, address, email address, phone number, and demographic information. If you participate in filming as part of XR Cast, then information may also include racial or ethnic origin as well as biometric data for the purpose of uniquely identifying you (e.g., measurements or inferences about your physical characteristics, such as joint locations). The decision to provide any of this information is optional. However, if you choose not to provide the requested information, then you may not be able to use some of the features of the Service. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information we get from your use of our Service. Information we automatically collect about the services you use and how you use them may include, for example, information that your device sends when you use our Service, such as the type of device you use, app installation identifier, user settings, Internet service provider, operating system type, application version number, content viewed, time spent using our Service, as well as other information about your use of our Service.
We also collect certain information that your web browser sends when you visit our websites, like the Internet Protocol (“IP”) address, browser, referring/exit pages and URLs, pages viewed, and similar information. Some of this information may be collected using “cookies” (cookies are discussed further below), which allows us to identify your browser and to improve your use of our Service. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, some features of our Service may not function properly if the ability to accept cookies is disabled.
Please note that this Privacy Notice only applies where Jaunt is the controller of your information. Where Jaunt is a processor (i.e., processing information on behalf of a business customer), then the controller (i.e., our business customer) is responsible for the collection and use of your data and their privacy notice will apply. In such circumstances, you should refer to the customer’s privacy notice and direct any queries to the relevant customer.
Tracking and Cookies
Please note that our websites do not currently respond to automated browser signals regarding tracking, including “do not track” instructions. As explained in our Cookie Notice, some of our service providers may use their own cookies and clear GIFs in connection with the services they perform on our behalf. For example, we may use Google Analytics which manages “do not track” instructions from your browser in accordance with its own privacy policies located here.
We may create de-identified or anonymous data records from personal information by excluding information that makes the data personally identifiable to you. We use this anonymous data in many ways, including analyzing request and usage patterns, and creating reports and performing analytics so that we may report on and enhance the performance and content of our products, services, and marketing efforts.
How We Use the Information We Collect about You?
We may use the information that we collect to provide, analyze, administer, enhance and personalize our Service, provide technical and customer support directly to you or through your app provider or service provider (if applicable), notify you of changes to our policies or products, notify you of offers that may interest you, identify or troubleshoot issues, conduct surveys, improve the products and services we provide to you, and otherwise operate our business.
For example, we may use information to:
- determine your general geographic location, provide localized content, determine your Internet service provider, mobile carrier, operating system, and platform, and to help us quickly and efficiently respond to inquiries and requests;
- prevent, detect and investigate potentially prohibited or illegal activities, including fraud and enforcing our terms;
- analyze and understand our audience, improve our Service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;
- communicate with you concerning our Service, including so that we can send you news about Jaunt, details about new features and content available on our websites, and special offers, promotional announcements and consumer surveys, and to assist you with operational requests. Please see the “Your Choices” section of this Privacy Notice to learn how to set or change your communications preferences.
- build datasets for training a model, such as the model(s) used for XR Cast.
- create a rendering of you for XR Cast, for viewing by you and others.
Legal Basis for Processing Personal Information (EEA visitors, customers or users only)
If you are a visitor, customer or user of our Service located in the European Economic Area (“EEA”), then, unless we are processing information on behalf of a business customer, we are the data controller of your personal information.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information in order to comply with a legal requirement or to perform a contract with you, then we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), then we will make clear to you at the relevant time what those legitimate interests are. If the information to be provided is about your racial or ethnic origin, or is biometric data for the purpose of uniquely identifying you, then we will make clear to you the purposes for the use of such information and will obtain your explicit consent prior to collecting or processing such information.
If you have any questions regarding our grounds for processing your personal data or would like to find out more information then please contact us using the details at the bottom of this Privacy Notice.
Disclosure of Personal Information
We may disclose your personal information for the following reasons:
- We get your consent;
- We are required to do so by applicable law, legal process, and/or governmental authorities;
- We believe a disclosure is necessary to protect our rights, our customers, or others;
- We are involved in a merger, acquisition, partial or total sale of assets, or other corporate change and need to disclose your information to a potential buyer, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- The party we are disclosing to is a joint venture partner or an entity we own or control (or that owns or controls us) that is either subject to this Privacy Notice or follows privacy practices at least as protective as these (this includes Jaunt International, Limited); or
- The party we are disclosing to provides services to us in connection with the operation of our Service (these service providers may have access to your information but only to the extent necessary to perform services on our behalf and are obligated not to disclose that information or use it for any other purposes). We may disclose de-identified, aggregated, or other non-personal information publicly and with our partners. For example, we may provide reports for usage analytics (to help us better understand who is using our Service and how) and for industry analysis, demographic profiling, reporting, research, and other similar purposes.
Email: You have the right to opt-out of marketing communications that we send you at any time. If you do not want to receive marketing emails from us, then you can change your email preferences by clicking on the included “unsubscribe” link contained in the emails we send you. To opt-out of other forms of marketing, then please contact us using the contact details provided.
How to Access Your Information
If you would like us to update, correct, or delete any inaccuracies in your personal information that we collect and maintain about you in our system, then please contact us as specified below. We will use reasonable efforts to honor your request; however, we may retain an archived copy of your information as required by law and/or for record keeping purposes. We reserve the right (subject to applicable law) to decline requests that are impractical or may jeopardize the privacy of others. When updating your personal information, we may ask you to verify your identity before we can act on your request. In addition, if you are a resident of the European Union, you have further rights. Please see more detail below under “Your EEA Privacy Rights”.
Security Measures We Take To Protect Your Information
We employ appropriate administrative, physical and electronic measures designed to protect your information from unauthorized access. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information, however, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. In the event that your personal information is compromised as a result of a breach of security, we will promptly notify you if your personal information has been compromised, as required by applicable law.
Overseas Transfers and the Processing of Your Information
Some of your personal information may be used by us and our affiliates, subsidiaries and our third party suppliers who may be located in countries outside the country where you are located for the purposes outlined in this Privacy Notice. The data protection laws in those countries may not offer the same level of protection as those in the country where you are located.
Specifically, our servers are located in the United States, and our subsidiaries and third party suppliers and partners may operate in the United Kingdom. This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our affiliates which require these companies to protect personal information they process from the EEA in accordance with European Union (“EU”) data protection law. Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and further details can be provided upon request.
Privacy Shield Notice
Jaunt, Inc., located in the United States, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States. We are committed to subjecting all personal information received from the EU member countries and Switzerland to the Privacy Shield Framework’s applicable Principles. If there is any conflict between the terms of this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the U.S. Department of Commerce and is available at: https://www.privacyshield.gov/list.
Jaunt, Inc. is responsible for the processing of personal information it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You can direct any questions or complaints about the use or disclosure of your personal information to us at firstname.lastname@example.org. We will investigate and resolve any complaints or disputes regarding the use of personal information within forty-five (45) days of receiving your complaint.
Jaunt has committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Jaunt has further committed to cooperate with the panel established by the European data protection authorities (“DPAs”) and the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship. Click here for a list of EU DPAs.
Data Retention and Deletion
We retain personal information that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your California Privacy Rights
If you are a resident of the State of California, then we provide you in this Privacy Notice with information on how to exercise your disclosure choice options such as your right to opt-out (or “unsubscribe”) of our use and sharing of your personal information for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third-party disclosure choices, please send a request by email to email@example.com or by postal mail to Jaunt at 951 Mariners Island Blvd., Suite 500 San Mateo, CA 94404, Attn: Your California Privacy Rights, c/o Privacy Group, Legal Department. All requests must be labeled “Your California Privacy Rights” in the email subject line or on the envelope or postcard. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We are unable to accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Your EEA Privacy Rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, please contact firstname.lastname@example.org.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights email email@example.com.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA are available here.
If you wish to exercise any of these rights or want further information please contact us as specified in the Contacting Us section below.
Changes and Updates to this Privacy Notice
Any information that is collected is subject to the Privacy Notice in effect at the time such information is collected. We may, however, modify and revise our Privacy Notice from time-to-time. We will notify you of such changes by posting the new Privacy Notice online on this page, and if the changes are significant, we will provide a more prominent notice (including, for certain services, by sending you an email or other notification), and we will indicate when such changes will become effective. By continuing to access or use our Service after those changes become effective, you are agreeing to be bound by the revised Privacy Notice. You can see when this Privacy Notice was last updated by checking the “Last Updated” date displayed at the top of this Privacy Notice.
If you have any questions about our Privacy Notice, please send an email to firstname.lastname@example.org, or send a letter to Jaunt, Inc., attn.: Privacy – Legal Department, 951 Mariners Island Blvd., Suite 500 San Mateo, CA 94404. For EEA residents please send an email to email@example.com or send a letter to Jaunt, International, Ltd.., attn.: Privacy – Legal Department: Campden Street, London, W8 7EN, United Kingdom, or send an email to firstname.lastname@example.org.
Last modified: July 9, 2019