Last Updated: 7/7/2017
Introduction and Scope of Practices
This Policy explains:
• how we collect, use, and share information from or about you;
• how our online advertisements (such as banner ads) on third party sites treat data;
• your choices about our use of your personal information; and
• how you can access and update your information.
Types of Information We Collect
Personally Identifiable Information (“PII”). PII means information or a combination of information that can be used to identify, contact, or locate a specific person. We may collect the following types of PII from you:
• Contact information, such as name, email address, mailing address, fax or phone number;
• Payment and financial information, such as credit or other payment card information, bank account, or billing address;
• Social Security Number or other national tax ID number
• Device geolocation (geographical location)
• Unique identifiers such as user name, account number, or password; and,
• Preference information such as product wish lists, order history, or marketing preferences.
Sometimes, we may combine PII you provide with information from third-party sources. For example, we may confirm your address with the postal service or verify your personal information with a credit-reporting agency. We will treat the combined information in accordance with the terms of this Policy.
Other Information (“OI”). OI is any information other than PII that does not reveal your identity or directly relate to a person. We may collect the following OI from you:
• Information about your business such as company name, company size, or business type;
• Demographic information, such as age, gender, interests and ZIP code;
• Device and other tracking information, such as browser information, device identifiers, operating system, or information gained from cookies, pixels or other tracking technologies.
OI may also include PII we have de identified or aggregated to the point where it no longer identifies a particular individual. If we ever combine OI with any PII, we treat it as PII is treated under this Policy. In some jurisdictions, some OI may be considered PII by law. In those cases, we will treat the information as PII is treated under this Policy.
How We Collect Personally Identifiable Information
We collect PII when you provide it to us. This can occur when you fill out applications, create accounts, complete a purchase, add money to your account, send in forms, take surveys, or fill in various online fields on our Sites. We also collect PII when you contact us with inquiries, customer support requests, or employment applications.
How We Use Personally Identifiable Information We Collect
We may use PII we collect for the following purposes:
• to provide you with the Services you requested;
• to verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your PII;
• to send you important information, such as changes to terms, conditions, and policies and/or other administrative information;
• to respond to your inquiries and fulfill your requests;
• to track referrals from partner websites;
• to personalize your experience on a Site by presenting content or offers tailored to you;
• to send you marketing communications you have signed up for or that we believe may be of interest to you;
• to allow you to use various Site features.
o Please note that some features require that you provide PII in order to use them (eg. many of the features at www.renewvr.com) whereas other tools do not. You may request that certain information that you enter into our Sites be stored for future access and use. You have the option not to save the information;
• to assist in verifying your identity and account status when we deal with you through our social media pages. We may combine this information with information we already have;
• to enable you to post your profile, preferences, and contact or be contacted by NewPathVR for projects or work;
• for business purposes, including data analysis, audits, developing and improving products and services, enhancing our Sites, identifying usage trends and determining the effectiveness of promotional campaigns; and.
• for risk control, fraud detection and prevention, and compliance with laws and regulations.
Newsletters: If you subscribe to our newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account.
How We Share Personally Identifiable Information We Collect
Affiliates: To the extent permitted by law, we may provide information about your transactions and experiences with other affiliated NewPathVR entities, including parent companies and subsidiaries.
Service providers: We may provide your PII to companies that provide services to help us with our business activities, such as shipping your order or offering customer service. These companies are authorized to use your PII only as necessary to provide these services.
Additional Disclosure: We may also disclose your PII:
• As permitted or required by law, such as to comply with a subpoena, or similar legal process;
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• If NewPathVR is involved in a merger, acquisition, or sale of all or a portion of its assets. You will be notified by email and/or by a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your PII;
• to any other third party with your prior consent.
How We Collect and Use Other Information
We and certain third party service providers with whom we have agreements may collect OI in a variety of ways, including:
Log files: Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files. We may link this data to PII we have collected about you.
You can refuse to accept cookies. Most devices and browsers offer their own privacy settings for cookies and HTML5 local storage. You will need to manage your cookie settings for each device and browser you use. However, if you elect not to accept cookies, your use of the features on our Sites may be limited or impaired, and you may not be able to access certain features of our Sites at all.
Our third-party partners use Local Shared Objects, such as Flash cookies, to embed features on our sites. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Social Media Widgets: Our Sites include social media features, such as the Facebook “Like” button. These features may collect your IP address, identify the page you are visiting on our website, and set a cookie to enable the feature to function properly. Social Media Widgets are either hosted by a third party or hosted directly on our website. The privacy statement of the company providing it governs your interactions with these Widgets. We will comply with any legal obligations placed on the use of these technologies by certain jurisdictions, which may affect how these Widgets function.
Security and Retention
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Image Submissions and Public Directories
User Access and Choice
NewPathVR acknowledges that you have the right to access your personal information. NewPathVR may have no direct relationship with some individuals whose personal data it processes. In those situations, an individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to NewPathVR’s partner who has the direct relationship (the data controller). If requested to remove data we will respond within a reasonable timeframe.
“Do Not Track” Preferences
Many browsers provide you an option to request that a web application disable either its tracking and/or cross-site user tracking of an individual user. We do not track your online activities across different Sites, and we only track your activity within a Site to the extent you log into your account.
Therefore, our practices remain the same whether or not you enable the “Do Not Track” feature.
Protecting Children’s Privacy Online
Our Sites are not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through our Sites. We do not knowingly collect information from children under 13.
If you live in the European Economic Area (“EEA”) or in Canada, the data that we collect from you may be transferred to and stored at a location outside the EEA and Canada. It may also be processed by staff operating outside the EEA and Canada who work for us or for one of our service providers. Among other things, such staff may process and store your information and provide support services. By submitting your personal data, you agree to this transfer, storing or processing. We will ensure that your data is treated securely and in accordance with this Policy.
EU-U.S. Privacy Shield
NewPathVR (and its subsidiary companies including RenewVR) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. NewPathVR is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
NewPathVR is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. NewPathVR complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, NewPathVR is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, NewPathVR may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
U.S. – Swiss Safe Harbor Framework
NewPathVR complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. NewPathVR has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view NewPathVR’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
Updates to This Policy
This Policy is subject to change. Please review it from time to time. If we make changes, we will revise the “Late Updated” date at the top. Any changes will become effective when we post the revised Policy. If we make any material changes we will notify you by email or by means of a notice on this Site prior to the change becoming effective.
1390 Market Street #2710
San Francisco, CA 94102