Active Replica Privacy Policy

At Active Replica Studio Inc., (“Company”, “we”, “us” “our”), we respect your privacy and are committed to protecting your Personal Information by complying with this policy (the “Privacy Policy”).  

This Privacy Policy describes:

  • How we collect, use, disclose, and protect the Personal Information of our customers and users of our Services (“you”).
  • The types of information we may collect from you or that you may provide when you use our services, which includes our websites, www.activereplica.com and www.activereplica.io (each, our “Site”), and our platform for the creation of, and hosting of virtual events in, customized 3D spaces, which may be embedded on the websites of our customers that use our platform (collectively, the “Services”).

By using our Services, or by creating an account on our Services, you signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Services or submit any Personal Information to us.

This Privacy Policy may change from time to time. Your continued use of the Services after we make changes indicates that you accept and consent to those changes, so please check the Privacy Policy periodically for updates. If we make any material changes to this Privacy Policy, we will notify you using prominent means such as by email notice sent to the email address specified in your account or by posting a notice through the Services. The date of the last change will be noted at the top of this Privacy Policy. 

  1. How We Collect Personal Information

When we talk about “Personal Information”, we mean any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. 

  1. When we collect Personal Information

We collect Personal Information when you voluntarily provide it through our Services, or when you provide it to us through other means. The categories of Personal Information we collect depends on how you use our Services. For example, we may collect Personal Information when you:

  • contact us through email or other correspondence;
  • register for or request a service we provide or which we make available to you through our Services;
  • register an account on our Services;
  • upload content to our Services, including your custom avatars and 3D models; or
  • explore and interact with the 3D virtual spaces on the Services (each, a “Room”) or participate in an event hosted in a Room, which includes Rooms which may be embedded on the websites of our customers that use our platform.

We also collect information about you from other sources. We may obtain this information from sources such as:

  • our business partners;
  • third party service providers, including Google analytics and Wolfprint 3D OÜ (Ready Player Me); and
  • publicly available sources.
  1. What Personal Information we collect from you 

The Personal Information we collect from you may include:

  • your email address, if you choose to create an account on the Services;
  • your username on the Services;
  • your custom avatar, which may include your photo or likeness;
  • sounds recorded through your microphone while in a Room, if your microphone is enabled;
  • photos, audio, and videos you take or record while in a Room, to the extent they are uploaded to a Room;
  • your location; and
  • any other Personal Information that you choose to submit to us or upload to the Services.

When you interact with us or other users of the Services we collect certain information. This information may include:

  • information about how, when, and where you use our Services;
  • error logging, event recording and user experience data; and
  • the settings you use on our Services.
  1. Information we collect through technological means

When you use our Services, we may collect information that is automatically sent to us by your computer and/or mobile device which runs our Site. This information may include your IP address. We may also collect other information, such as data about your usage of our Services. Additionally, we may also collect other technical and system log information from you, such as:

  • the type of device you’re using;
  • your operating system and version information;
  • the type of browser you’re using, and your browser settings;
  • mobile network information;
  • content you view on our Services;
  • your unique device identifier;
  • the full Uniform Resource Locator (URL) clickstream to, through, and from our Site, including date and time;
  • your system activity; and
  • software debug and crash information.

We use this information to improve our understanding of how users use our Services, and to improve our Services. The amount of information that is sent to us by technological means depends on your device and settings you use. Please refer to the instructions provided by your device if you want to learn more about what information it sends to Services you use, or how you may change or restrict this.

  1. Our use of cookies

Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).

Our use of cookies is limited to our use of Google Analytics, an analytics service offered by Google. We use Google Analytics to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content, and better understand online activity. For example, we may use cookies to track the number of Rooms you create or enter, interactions with buttons and menus, and session length.  More information about Google Analytics can be found here

We use all options that Google Analytics provides for maximising your privacy including instructing them to anonymise your IP address, transmitting data by an SSL connection only, and manually stripping out any personally identifiable information before transmitting to Google Analytics. 

We obtain your consent to our cookies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make your choice. You have the right to object to the use of cookies. Regular cookies may generally be disabled or removed by tools that are available as part of most devices, and in some but not all instances can be blocked in the future by selecting certain settings. Please be aware that if you disable or remove these Cookies some parts of our Services will not work and that when you revisit our Services your ability to limit cookies is subject to your device settings and limitations.

If you’d prefer to opt out of Google Analytics data collection, you can install the Google Analytics Opt-out Browser Add-on, which stops data transmission to Google Analytics.

  1. How We Use and Disclose Information Collected from You
  1. Our use of Personal Information

The information we collect from you may be used by us for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. We may use and disclose information collected from you as follows:

  • to deliver our Services to you;
  • to register your account on the Services;
  • to verify and authenticate your account information;
  • to provide you with information, products, or services that you request from us;
  • to send you informational or administrative communications;
  • to communicate with you and to enable other users to communicate with you;
  • to respond to your inquiries and provide you with customer support;
  • to increase the security and safety of our Services and users;
  • to notify you about changes or updates to the Services;
  • to send you marketing and advertising communications, in accordance with your choices and communications preferences; 
  • to share your username and avatar with the public, including by displaying it on our Services; 
  • to serve you relevant advertisements and content;
  • to perform analytics on our Services;
  • for any other purposes that are disclosed to you and to which you consent; and
  • for any purpose required by law.
  1. Our disclosure of Personal Information

Generally, we do not disclose your Personal Information to third parties without your consent. However, in order to provide you with the Services, we may need to transfer your Personal Information to our subsidiaries, parent companies, employees, contractors, consultants, government agencies and regulators, and other parties who require such information to assist us with managing and administering our relationship with you, including: 

  • third parties that provide services to us or on our behalf; 
  • third parties that assist us in the provision of Services to you; and 
  • third parties whose services we use to conduct our business. 

Additionally, in order to provide you with the Services, we may need to transfer your Personal Information to third party technology companies for the purposes of processing and storing your Personal Information. Our business necessitates using: (a) cloud storage and hosting providers; (b) email services providers; and (c) payment processors. We consider these services, platforms, and applications to be integral to our delivery of the Services to you.

Under certain circumstances, we may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We reserve the right to transfer Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.

We may disclose your Personal Information in the good faith belief that such action is necessary:

  • to protect and defend our rights or property;
  • to prevent or investigate possible wrongdoing in connection with our products or services;
  • to protect the personal safety of our customers or the public;
  • to comply with our legal obligations;  or
  • to protect against legal liability.
  1. How We Protect Personal Information

The security of your Personal Information is important to us. We are committed to ensuring your Personal Information is protected and will use industry-standard security measures, including Secure Socket Layer (SSL) technology, to do so. If you create an account on the Services using your email address, we store only a hashed version of your email address. Personal Information may only be accessed by persons within our organization who require such access to provide you with the services indicated above. 

While we endeavour to keep your Personal Information safe, our collection, use, and disclosure of your Personal Information is not without risks. For example, our security safeguards may be compromised by viruses, hacking attempts, or physical break-ins. Consequently, we cannot guarantee the security of your Personal Information. If your Personal Information was wrongfully accessed, there is a risk that you may suffer a harm, such as identity or credit card theft or financial loss.

Please be careful whenever sending Personal Information to us via email. Email is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and we encourage the use of email encryption or other encrypted services to communicate with us. 

  1. Data Storage, Retention, and Deletion

The Personal Information we collect from you is stored in our servers located in the United States.

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

  1. Processing and Transfer of Information

We may need to transfer your Personal Information to our service providers for processing. This processing supports our business. For example, we may transfer your Personal Information to our cloud hosting provider for storage and retention purposes. We ensure that these recipients of your Personal Information are contractually obligated to keep your Personal Information confidential, to use it only for the purposes for which we transfer it to them, and to process the Personal Information with standards at least as stringent as those set out in this policy.

Personal Information may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Information to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Information By using any of our Services, or by sending us any Personal Information, you consent to such transfers.

We will endeavour to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to a third party organization unless such organization is obligated to maintain adequate security safeguards over your Personal Information.

  1. Third Party Collection of Information

The Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

  1. Personal Information of Children

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below. 

  1. Access and Rectification

You have a right to challenge the accuracy and completeness of your Personal Information and to have it amended, as appropriate. You also have a right to request access to your Personal Information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal Personal Information about another individual, your request for access may be limited or denied. 

To request access or to amend your Personal Information, please contact us using the contact information provided below. 

  1. Withdrawal of Consent

You may withdraw your consent to our collection, use, and disclosure of your Personal Information at any time, subject to legal and/or contractual restrictions and reasonable notice. Your withdrawal of consent to our collection, use and disclosure of your Personal Information may impact our ability to provide you with products and services and may impact your ability to use the Services. To withdraw consent, please contact please contact us using the contact information provided below. 

  1. How to Contact Us

If you have any questions or concerns about this Privacy Policy or the handling of your Personal Information, if you wish to withdraw your consent to our use or disclosure of your Personal Information, or to request access to or update any of your Personal Information we have on file, please contact our Privacy Officer at info@activereplica.com