TRANSFRVR Privacy Policy

Key Information

  • We collect the personal information set out in the "What Information We Collect" section of this Privacy Policy below. This includes registration details such as name and email, classroom data, Module interaction data, survey information (where you provide it), and other information about your use of our Product and Services.
  • We use your personal information for the purposes set out in the "How We Use the Information" section of this Privacy Policy below, including providing our Product and Services to you, ensuring the security and performance of our Product, conducting research relating to Training Offerings, sharing information with our partners, direct marketing, and performing statistical analysis of the use of our Product and Services.
  • You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the "Updating or Deleting Your Personally Identifiable Information" section of this Privacy Policy below

You can find information about us and how we collect, use and store your personal data in each section of this Privacy Policy:

Key Information

Purpose and who we are

What Information this Privacy Policy Covers

What You Agree to by Using Our Product

What Information We Collect

How We Use the Information

Retention of Personally Identifiable Information

Confidentiality & Security of Personally Identifiable Information

Updating or Deleting Your Personally Identifiable Information

Questions, Suggestions, and Complaints

International Privacy Practices

No Information from Children Under 13

Related Third-Party Privacy Policies

 

Purpose and who we are

The purpose of this Privacy Policy is to describe how TRANSFR, Inc. ("TRANSFR”, "we”) collects, uses, and shares information about you through our online interfaces (e.g., virtual reality applications, websites and mobile applications), including but not limited to transfrvr.com and TRANSFR virtual reality application(s) operated on TRANSFR-owned and/or customer owned virtual reality devices (collectively referred to herein as the "Product"). Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at privacy@transfrvr.com. TRANSFR, Inc. is a Delaware corporation with a principal place of business at 425 East 86th St. Suite 2F, New York, NY 10028. 

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Product. Some of our Product’s functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to Classes or Modules, “Personally Identifiable Information” (i.e., information that can be used to identify you)(may also be referred to as “personal data” or “personal information”) is required. Personally Identifiable Information can include information such as your name, email address and IP address, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to TRANSFR. Inaccurate information may affect your ability to use our Product, the information you receive when using the Product, and our ability to contact you. For example, your email address should be accurate because that is one of the primary manners in which we communicate with you.

What You Agree to by Using Our Product

We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:

  • our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Product or to comply with our contract to provide Services to you); or
  • our use of your personal information is necessary for complying with our legal obligations; or
  • use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
    • run, grow and develop our business;
    • provide our Product and Services;
    • build relationships with partners and academic institutions;
    • carry out research and statistical analysis;
    • carry out marketing and business development; and
    • for internal administrative and auditing purposes.
  • consent, to send you certain communications or where you submit certain information to us.

Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@transfrvr.com and requesting the change, or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our Services to you.

What Information We Collect

We gather two types of information about users through the Product:

  1. Information relating to your use of our Product. When users use our Product, we may collect and aggregate information indicating the IP address of each user of the Product.
  2. Personally Identifiable Information provided directly by you. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Training Offerings or other Services within our Product. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Training Offering and/or Services you select, send you updates about Training Offerings or other events, and send you email messages about Product maintenance or updates.
  • Account Registration. If you register for an account with our Product, you may be required to provide us with Personally Identifiable Information such as your name and email address.
  • Participation in Training Offerings. TRANSFR offers registered users the opportunity to participate in Training Offerings through the Product. If you desire to participate in a Training Offering, you will be asked to provide us with certain information necessary to conduct such a Training Offering. This information may include, among other things, your name and email address. We may collect from you data that may be generated based on whether you participate in such an Offering as an instructor or as a student. For instructors, this may include data on which classes you created, what trainees interacted with a module as a part of a class and statistical information relating to the class performance. For trainees, we will also collect data on how you interacted with the Module (e.g. detailed information on the usage such as full recordings of the experience in the virtual reality device), when these interactions occurred and your results from working with these modules. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person in the course of the virtual reality experience (for example through conversations with the virtual coach), except for information required to participate in and complete a Module in the virtual reality setting.
  • Communications with TRANSFR. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
  • Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us.

How We Use the Information

  1. Information relating to your use of our Product. We use information relating to your use of the Product to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users. We may also use this information to ensure the security of our Services and the Product.
  2. Personally Identifiable Information provided directly by you. Except as set forth in this Privacy Policy or as specifically agreed to by you, TRANSFR will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below.
  • Providing the Product and our Services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Product and in order to provide any information, deliver Training Offerings, or Services that you request from us.
  • Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our Services and the Product.
  • Participation in Training Offerings. We use the Personally Identifiable Information that we collect from you when you participate in a Training Offering through the Product for processing purposes, including but not limited to tracking attendance, progress, and completion of a Training Offering. We may also share your Personally Identifiable Information and your performance in a given Training Offering with the instructor or instructors who taught it and with organizations under whose auspices the training was conducted. We may also use the information generated when taking a Training Offering or using the Services for predictive analysis of your performance in the Training Offerings. We may share your performance(s) in specific Training Offerings with our partners and customers for the purposes of providing them with contractually obligated Services. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
  • Communications with or from TRANSFR. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. 
  • Communications with TRANSFR Business Partners. We may share your Personally Identifiable Information with business partners of TRANSFR as a part of delivering our Product or Services. Our business partners may use this information to contact you if they are legally permitted to do so.
  • Research. We may share information about your activity with our Product with business partners for research related to online and virtual reality based education.
  • Disclosure to TRANSFR Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Product or the Training Offerings. Access to your Personally Identifiable Information by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
  • Government Authorities; Legal Rights and Actions. TRANSFR may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of TRANSFR, the Product, our users, customers, or others; and in connection with our Terms of Use and other agreements.
  • Disclosure to Acquirers. TRANSFR may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of TRANSFR to which your Personally Identifiable Information relates.

Retention of Personally Identifiable Information

We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is collected and processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personally Identifiable Information

You have certain rights in relation to your Personally Identifiable Information. You can contact us via privacy@transfrvr.com at any time to request information on data we possess about you and we will furnish whatever data we are required to provide by law. 

Questions, Suggestions, and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via privacy@transfrvr.com. 

 

California Privacy Rights

Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to privacy@transfrvr.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

Under the California Consumer Privacy Act (“CCPA”), California residents have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. TRANSFR does not sell any of the data we collect about you. If you’d like to exercise any of the other rights afforded to you, contact us at privacy@transfrvr.com.

International Privacy Practices

TRANSFR’s Product is operated and managed on servers located and operated within the United States. If you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred.

 

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Product webpage. We will notify you of any material change to this Privacy Policy by posting a notice on our Product’s homepage for a reasonable period of time following such update, and by changing the effective date (located at the top and bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

No Information from Children Under 13

TRANSFR strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information in our Product from persons under 13 years of age, and no part of our Product is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access our Product at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected in our Product without verified parental consent upon learning of the existence of such Personally Identifiable Information.

Related Third-Party Privacy Policies

TRANSFR’s virtual reality application(s) may be operated on virtual reality devices manufactured by third-parties. Use of these devices are also subject to the Terms of Use and Privacy Policies of the device manufacturer(s). The below third-party privacy policies also apply

 if our Product is used on devices created by the below manufacturers: