Privacy Policy Addendum 

General Data Privacy Regulation (GDPR)

This policy (this “Privacy Policy Addendum”) is an addendum, and supplements, our privacy policy (accessible here) (“Privacy Policy”) and shall apply only to personal data or personal information, as such terms are defined in the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) that is collected or processed by Aysu LLC  and affiliates (collectively, “Company”, “we”, “us”, or “our”) within the scope and coverage of the GDPR and applies to us to the extent that we are deemed to be a data controller within the meaning of the GDPR. This Addendum shall supplement or supersede our Privacy Policy or parts thereof only to the extent that the GDPR imposes obligations on personal data that we process or collect. We endeavor to apply data privacy best practices and adopt policies consistent with the GDPR only if, and to the extent, the GDPR, applies to us. For the purposes of this Addendum, the terms “personal data” or “personal information” shall have the meanings ascribed to such terms in the GDPR.

  1. 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 or other electronic network activity information, 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, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services, geolocation data, including precise device location if you choose to allow us to collect it, sensory data, audio or visual information, including photos and videos, if you choose to provide such information.
  • 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 process the combined data as personal data which will be used in accordance with this Privacy Policy Addendum.

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.

  1. The data we collect about you and how we collect it

Please consult our Privacy Policy for details on the data we collect about you and how we collect it.

  • How does InfiniteVR use personal data?

We will only use your personal data when applicable 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 (for example, to process your order and provide you with an online account);
  • 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 (such as where it is necessary for the administration of our business, our legal risk management and managing the performance of our website);
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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. If you withdraw your consent this will not affect the lawfulness of any processing carried out before you withdrew it.

  1. For what purpose will InfiniteVR use your Personal Data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, the types of data that may be involved, and which of the legal bases we rely on to process it. 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 in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To identify and/or register you as a new customer or supplier (a) Identity
(b) Contact		 Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) To enable you to partake in a prize draw, competition or complete a survey		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (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 use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile		 Necessary for our legitimate interests (to develop our products/services and grow our business)
  1. 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.

  1. Third-party marketing

We will share your personal data with any third party for marketing purposes only if we obtain your prior express opt-in consent.

  • Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

  • Disclosures of your personal data

We may share your personal data with third parties, including the parties set out below, for the purposes set out in the table above.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to process it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. 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, contractors and other third parties 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.

 

  1. Will Personal Information be transferred outside the EEA?

Sometimes we may transfer your data outside the EEA, however, we will only do so where there are adequate safeguards in place. We may share information within our company headquarters in the US. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  1. How long will InfiniteVR retain my Personal Information for?

We will only keep your data for as long as is necessary and justified. We take steps to ensure that we only keep the minimum data we need for the purposes of our legitimate interests (in the management of our business and its risks) and in line with our legal obligations.

We will normally keep your information for a maximum of seven years. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data. In some circumstances we may 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.

If you would like more information about how long we retain specific data, you can contact us using the details set out in this Privacy Policy Addendum by contacting us: [email protected]

  • What are my Legal Rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • 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, including to object to direct marketing.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
  • Right to lodge a complaint with the Supervisory Authority. If you would like details about which Supervisory Authority to contact, please contact us at the email address listed below.

We may provide you with a standard form to help you specify your request. You are not required to use the standard form we provide, but it may be helpful and save time if you do.

If you wish to exercise any of the rights set out above, please contact us at the following:

5301 Polk Street, Building 14-B6 Houston TX 77023
+1 (855) 504 07 07
Email: [email protected]

  • 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 as soon as possible and in any event within one month. Occasionally it may 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. In such cases it may take up to two further months to process your request.