VOLOGRAMS LIMITED (we) are committed to protecting your personal data and respecting your privacy.
This policy (together with our terms and conditions of use as set out at https://www.volograms.com/volu-terms-and-conditions (T&Cs)) our Cookie Policy as set out at https://www.volograms.com/volu-cookie-policy, and any additional terms of use incorporated by reference into the T&Cs, together our Terms of Use) applies to your use of:
This policy is provided in a layered format so you can click through to the specific areas set out below.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
SHARING OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
CALIFORNIA RESIDENTS
GLOSSARY
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
VOLOGRAMS LIMITED (company registration number: 618950) with registered office at Suite 33, Guinness Enterprise Centre, Taylor’s Lane, Dublin 8, Ireland, D08 FN36, is the controller and is responsible for your personal data (collectively referred to as the "Company", "we", "us" or "our" in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish regulator for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on May 25th, 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data. Please check these policies before you submit any personal data to these websites or use these services.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data here.
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 App feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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) or information about your criminal convictions and offences when you capture/record videos with your Device through the App. We do not require this information and it is for you to decide whether you want to share such information in the contents you create/generate through the App and share with others. This information is subject to special protections under EU law.
We will collect and process the following personal data about you:
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
Lawful basis for processing
Type of data
Purpose/activity
To install the App and register you as a new App user
Profile
Contact
Your consent
To deliver Services including converting the videos you capture/record through the App into VOLOGRAM™ Model(s), enabling you to share VOLOGRAM™ Model(s) and VOLOGRAM™ Experience(s)
Profile
Contact
Content
Marketing and Communications
Device
Location
Your consent
Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App or any Services and contacting you directly in relation to any query you have raised about the App and its Services
Profile
Contact
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition, avail of special offers or complete a survey
Profile
Contact
Device
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To notify you of new content and when someone has shared VOLOGRAM™ Model(s) with you
Profile
Contact
Device
Marketing and Communications
Your consent
Necessary for our legitimate interests (to improve our customers user experience and their use of our products/Services and to develop them and grow our business)
To administer and protect our business and this App including content review, troubleshooting, data analysis and system testing
Profile
Contact
Content
Location
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, Cloud services)
Necessary to comply with legal obligations (to remove inappropriate and/or unlawful contents)
To improve quality, stability and secutiry of the App and our Services
Content
Device
Location
Usage
Performance of a contract with you
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, Cloud services)
To improve existing features of the App and develop new ones
Content
Device
Marketing and Communications
Usage
Necessary for our legitimate interests (for running and grow our business, provision of administration and IT services, network security, Cloud services)
COOKIES
You can adjust the preferences in the App to refuse all or some cookies. If you disable or refuse cookies, please note that some parts of the App may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data when required with the third parties set out below and for the purposes set out in the table Purposes for which we will use your personal data:
Many of our External Third Parties and service providers are based in Ireland but sometimes we may need to store and process your personal data outside of Ireland and the European Union.
Whenever we transfer your personal data out of the European Union, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Ireland.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using appropriate encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict and appropriate procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Certain Services include social networking features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.
In some circumstances we will 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.
In the event that you do not use the App for a period of 12 months (or delete your account) then we will treat the account as expired and your personal data may be deleted.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You may have the right to:
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at volusupport@volograms.com.
This section applies to our collection and use of personal data if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). When we use the term personal data in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (this is called “personal information” under the CCPA). Please note that the CCPA is experiencing further changes as part of the rulemaking activity process. As a result, please check back often as this section may change to comply with future CCPA requirements.
If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 1 above.
A. Categories of Personal Data Collected, Used, and Shared
In accordance with California law, we may have collected and share the following categories of personal data within the past 12 months:
Categories of Personal Data Collected & Shared
Identifiers: Username, password and e-mail address.
Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Username and e-mail address. Some personal data included in this category may overlap with other categories.
Internet or other similar network activity:
Device Data: Information about your hardware, includes information about your hardware, for example the model of the Device you use, your Device’s operating system version, your carrier, your time zone within which your Device is located (country/city).
Usage Data: Information details of your use of our App including but not limited to login information, how you interact with our App, which VOLOGRAM™ Models and/or VOLOGRAM™ Experiences are your favourite, what Superpower(s) you apply, what tags you select, information about your sharing of VOLOGRAM™ Models and VOLOGRAM™ Experiences with other App users, number of VOLOGRAM™ Models you recorded/captured, the resources that you access on the App, whether this is required by us to improve the App and/or user experience, fix usability issues, dimension our infrastructure or otherwise.
Marketing and Communications Data: includes your communication/correspondence with us (via emails or otherwise). This information includes any interests, preferences, feedback or survey responses that you provide to us.
Audio, electronic, visual, thermal, olfactory, or similar information:
Content Data: Information about any video captured, recorded or otherwise made available by you within the App, including sound recordings and ambient noise embodied therein, the VOLOGRAM™ Model created from it (including sound recordings and ambient noise embodied therein) and the VOLOGRAM™ Model(s) shared with you (including sound recordings and ambient noise embodied therein) from other users within the App.
Geolocation Data: The time zone within which your Device is located (country/city).
We share each of these categories of personal data to our service providers to the extent necessary for them to facilitate our business purposes. We also share these personal data for the purposes set forth in Section 4 above. In the last 12 months, we have not knowingly sold any personal data of California consumers, nor do we have actual knowledge that we sold the personal data of California consumers under the age of 18 years old. The CCPA defines “sale” as: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal data to another business or third party for monetary or valuable consideration. If we do sell your personal data, we will notify you, and if you submit to us a verifiable consumer request we will disclose to you a list containing the categories of personal data that we sold in accordance with the CCPA’s requirements.
B. Your California privacy rights
If you are a resident of California, you may have the following rights:
Privacy Right
Description
Notice
You may have the right to be notified of what categories of personal data will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access
You may have the right to request the categories of personal data that we collected in the previous twelve (12) months, the categories of sources from which the personal data was collected, the specific pieces of personal data we have collected about you, and the business purposes for which such personal data is collected and shared. You may also have the right to request the categories of personal data which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal data.
Data Portability
You may have the right to receive the personal data you have previously provided to us.
Erasure
You may have the right to request to have your personal data deleted, and request that we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your personal data for one or more of the following categories of purposes: (1) to complete a transaction for which the personal data was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our App’s integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.
To Opt Out
You may have the right to request to opt out of us selling your personal data.
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to volusupport@volograms.com or call us toll-free at: +1 (866) 921-7789.
We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal data you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
We may deny certain requests, or only fulfil some in part, as permitted or required by law. For example, if you request to delete personal data, we may retain personal data that we need to retain for legal purposes (e.g., tax accounting). You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights. The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.
LAWFUL BASIS
EXTERNAL THIRD PARTIES
Professional advisers including lawyers, bankers, auditors and insurers based in Ireland (or elsewhere) who provide consultancy, banking, legal, insurance and accounting services.
The Irish Revenue, regulators and other authorities based in Ireland (or elsewhere) who require reporting of processing activities in certain circumstances.
Volograms Limited Guinness Enterprise Centre, Taylor’s Lane Dublin 8 D08C2F1 office@volograms.com
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