PRIVACY POLICY

Privacy Policy

This Privacy Policy is applicable to the ZenVR(TM) app, a Commercial application developed by Satori Studios, Inc. ("Satori Studios," "we," "us," or "our") as well as the ZenVR website. By using this service, you agree to the collection and utilization of information as outlined in this policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at https://www.zenvrapp.com/terms-and-conditions unless otherwise defined in this Privacy Policy.

Information Collection and Use

For optimal user experience, our Service may require you to provide certain personally identifiable information. This information will be retained and used in accordance with this privacy policy.

Personal Information

The app may utilize third-party services that collect data for identification purposes. For further details on these third-party services, please refer to their respective privacy policies.

Information Collected through the Game

Access and interaction with various game features and content may necessitate the creation of an account with platform/service providers. During registration, mandatory information such as name, email address, and account login is required. Financial information may also be collected for payment processing, strictly following the terms outlined in this Privacy Policy and the platform/service providers' own Privacy Policies.

Additionally, we may collect and process information such as browser type, operating system, IP address, and unique identifiers associated with the devices used to access or play the Game. We may also process other user-related data, including personal profiles, messages, groups, events, and applications used within the Game.

Information Collected through Other Sources

We may gather information from various sources, including third-party sites, platforms, and interactions within the Game, to enhance your gaming experience and provide you with more relevant information.

Log Data

Whenever you use our Service, Log Data is automatically collected in case of errors in the app. This may include device IP address, device name, operating system version, app configuration, timestamps, and other relevant statistics.

Cookies

"Cookies," small data files used as unique identifiers, may be sent to your browser from third-party code and libraries utilized by the app. These cookies help collect data and enhance their services. You have the option to accept or refuse these cookies.

Service Providers

We may engage third-party companies and individuals to assist in providing and analyzing the Service. These parties may have access to your Personal Information to perform their designated tasks but are obligated not to disclose or use the information for any other purpose.

Security

While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee absolute security due to the inherent limitations of internet transmission and electronic storage.

Links to Other Sites

Our Service may contain links to external sites. We advise reviewing the Privacy Policy of these sites, as we have no control over their content, privacy policies, or practices.

Children’s Privacy

Our Service is not intended for users under the age of 13, and we do not knowingly collect personal information from such individuals. If you believe that your child has provided us with personal information, please contact us to take necessary actions.

Your Choices and Controls

You have rights regarding your Personal Data, including the right to request access, object to processing, correct or erase data, restrict processing, withdraw consent, and obtain data portability. For inquiries or to exercise these rights, contact us at privacy@zenvrapp.com.

Information you provide or is collected from you in or in relation to the Game and information from other sources

Information is provided by you or collected in or in relation to the Game and/or collected from other sources in order to:

provide, operate, improve and maintain the Game, game experience and services, your account(s);
personalize the Game, content, loyalty programs and related services to you;
send technical notices, updates, security alerts,
for support and troubleshooting reasons;
send support and administrative messages
provide news and information about the Game and/or about our games and products;
monitor the end users playing of the Game and activities in the Game;
facilitate sharing on social networks;
provide adults with advertising in accordance with given consent and/or permissible laws;
provide children reasonable contextual advertisements in the Game accordance with permissible laws;
identify, fix, and troubleshoot bugs and service errors, provide software updates etc;
resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies;
survey end users opinions about the game and related matters through surveys or questionnaires;
communication reasons related to the Game and related matters;
to store, process and use User Created Content in accordance with our Terms of Use;
to comply with applicable laws or respond to legal process (like requests from law enforcement or other public or government authorities);
to administer, process and examine claims of copyright infringements, or other violations of our Terms of Use;
manage the Game and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties;
present offers and/or information relating to the Games and other games that you might like;
make recommendations to you; and
personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

Processing of this information is necessary for the purpose of performance of a contract to which you are a party, in order to support the operation of the Game, facilitate the delivery of requested products and services, enable maintenance and update of the Game under Article 6(1)(b) of the GDPR, and purposes justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (“the balancing-of-interest rule”). Disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of Personal data

With respect to processing of Personal Data Satori Studios Inc. is Data Controller. Satori Studios Inc. shall (i) Not keep the Personal Data for longer than is necessary for the purposes of performing the Agreement unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules; (ii) Store, process and use the Personal Data for the sole purpose of performing the Agreement; and (iii) Ensure that their employees and employees of their affiliates and subcontractors involved in the performance of the Agreement comply with the provisions of this agreement (iv) Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access, (v) Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of your Personal Data, (vi) Refrain from exporting or transferring your Personal Data to any Third Country, and from collecting, using or Processing Personal Data within any Third Country, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented in accordance with the terms and conditions stated in section 9 of this Agreement (International Data Transfers). Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ended.

You have the following rights regarding your Personal Data:

The right to request access

In accordance to Chapter III, Article 15 of the GDPR a Data Subject may request access to processed Personal Data. This includes confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

the purposes of the processing;
the categories of Personal Data concerned;
the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the Personal Data are not collected from you, any available information as to the source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

You shall be provided a copy of the Personal Data undergoing processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Please note that the access may be restricted due to intellectual property rights or trade secrets.

The right to object

You have the right to object to the Personal Data processing on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Article 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your Personal Data for direct marketing purposes at any time. We will cease the processing of your Personal Data for this purpose after the objection. Please note that if you exercise this right, your user license to use the Game and related services will cease automatically.

Right of correction and erasure

You have the right to have inaccurate Personal Data rectified, in accordance with Article 16 of the GDPR.

You have the right to have your Personal Data erased where one of the following grounds applies, see Article 17 of the GDPR:

The Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
if you have withdrawn your consent and there are no other legal grounds for the processing,
if you have objected to the processing and there are no overriding legitimate grounds for the processing,
the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law,
the Personal Data have been unlawfully processed or
the Personal Data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

The right to restriction

You have the right to obtain restriction of processing in certain circumstances, in accordance with Article 18 of the GDPR. If you have the right to restriction, we will only process your Personal Data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
The right to withdraw consent

If we have asked for your consent to our processing of your Personal Data, you have the right to withdraw your consent at any time, in accordance with Article 7 of the GDPR. You may at any time opt out of and/or unsubscribe from emails from Satori Studios Inc. and our service providers, or withdraw consent to Personal Data storage, either via the unsubscribe link included in the emails, or by emailing privacy@zenvrapp.com. If you withdraw your consent, we will cease processing of the Personal Data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your right to play the Game and related services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability

You have the right to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hinderance if the processing is based on consent or contract performance, sin accordance with Article 20 of the GDPR.
Changing or Removing Account Information

Access and control over most Personal Data in the Game is readily available through the profile editing tools on your account with the applicable platform/service provider that you are accessing the game through. End Users may modify or delete any or all of their profile information at any time by logging into their accounts. Information will be updated as soon as possible. End Users who wish to deactivate their Game account may do so in their accounts with the applicable platform/service provider that you are accessing the game through. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other End Users or visitors of the Game. You cannot however remove communications made in any communication features in the Game, which might have been shared with other End Users (for example sending personal messages to another End Users).

If you wish to invoke any of the rights described above, you may contact us at any time by emailing us at privacy@zenvrapp.com. We will process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Changes to This Privacy Policy

We may update this Privacy Policy periodically, and any changes will be reflected on this page. It is advisable to review this policy for updates.

Effective Date: December 14, 2021

Last Update: September 24, 2023

If you have any questions or suggestions about our Privacy Policy or would like to request your data be deleted, do not hesitate to contact us at privacy@zenvrapp.com .

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