Weave ICO privacy policy

Last updated: June 13th 2019

WEARVR respects your privacy and is dedicated to protecting your personal data. This privacy policy document describes what information we collect, why we do so, and how we use it and store it. It also outlines your rights as they relate to the information we collect, and how to exercise those rights.

This policy document may be amended from time to time to reflect changes and additions to the Weave ICO privacy policy. Any changes to our policy will be posted to the website and we will notify you of these changes, for example, by email, when it is appropriate and technically feasible to do so.

Who we are

WEARVR brand operates internationally and provides a marketplace for virtual reality and augmented reality applications to Users.

Non-public personal data is controlled by WEARVR Ltd, a Maltese company with company registration number C-90279 and having its registered office at 60/2 Melita Street, Valletta VLT1122, Malta. Your information is accessible to all group entities and processed by any one or more of such group entities. All entities within the WEARVR brand follow and adhere to appropriate safeguards in line with EU law for the processing of non-public personal data.

What Information We Collect & How It Is Used

WEARVR Ltd acts as a Controller in terms of the General Data Protect Regulation (“GDPR”) 2016/679 of the European Parliament and Council of the 27 April 2016, and shall comply with the GDPR principles as stipulated in Section 5 (2) of the GDPR wherein it is stated that “the Controller shall be responsible for and be able to demonstrate compliance with the GDPR principles relative to the personal data as outlined in Section 5 (1) of the GDPR”. Personal Data shall be processed fairly and in a transparent manner and collected only for legitimate purposes. Personal Data collected by WEARVR Ltd shall be accurate and up to date and shall not be retained for longer than necessary.

WEARVR Ltd shall protect Personal Data of the Data Subject and shall not transfer the Personal Data outside the EEA, unless the appropriate level of protection is ensured.

General usage

WEARVR Ltd logs technical and usage data such as IP addresses, device ID, user agents, and operating system name and version, when you view or interact with our website(s), information, or services related to the Weave ICO. We do this to improve our services; detect abuse or misconduct; and to ensure the security and availability of those services. We also use this data to measure service traffic and the efficacy of marketing and outreach campaigns, and to diagnose and resolve technical issues or disruptions. We use aggregated, randomised or anonymised data to achieve these goals where it is procedurally and technically reasonable to do so.

Your device’s public IP address may be used to show you localised or customised information or service functionality based on your location, including your exclusion from registering interest or participating in the ICO where you appear to reside in a country that is ineligible to do so.

Registering interest in the Weave ICO

WEARVR Ltd processes information provided by users who submit data to us via forms on our website(s). Particularly, we securely store the information users submit to us when they register interest in participating in the Weave ICO: this includes name, email address, phone number, country of residence, nationality, chosen language and potential contribution amount. This information will be used to contact you regarding the Weave ICO and the Weave coin. It will also be aggregated to create summary data indicating interest and participation in the ICO.

You can unsubscribe at any time using the unsubscribe link included in every email or by contacting us at privacy@wearvr.com

Participating in the Weave ICO

To take part in the Weave public or private sale, or to otherwise receive Weave, you will be required to pass certain identity checks to comply with anti-money laundering legislation. WEARVR Ltd contracts a third party for these identity checks, who collects information such as: name, user name and password, email address, telephone number(s), mailing address, social security number, account numbers, payment information, government issued identification documents (e.g., passports, driver’s license, etc.), selfie image, biometric information, IP Address, utility bills and statements to prove your current residence (e.g., bank statements). At the completion of these checks, WEARVR Ltd is provided with confirmation of your eligibility to receive Weave and information necessary to complete the transfer of Weave to you.

To facilitate the sale or transfer of Weave coins to you, we need to process financial details such as bank or cryptocurrency exchange account details, or cryptocurrency wallet addresses. These will be used to ensure the correct and secure transfer of Weave to you and to comply with any applicable legal requirements.

You can request we cease processing your personal data at any time by contacting us at privacy@wearvr.com. If this occurs, WEARVR Ltd will continue to process data it is legally required to - but it will only do so to the extent and for the purpose of fulfilling these legal obligations. The cessation of processing of your personal data upon your request may result in your inability to participate in the Weave ICO.

Weave Air Drops

WEARVR Ltd will store user account data and any social media account information you choose to provide us when registering for Weave airdrops. We do so to validate user participation in the airdrops, as set out in our Airdrop Terms and Conditions.

We will store your airdrop-related data until you indicate to us that you are no longer interested in participating in any further airdrops by deleting the information from your account. If you choose to remove your social media or other account details before an airdrop has taken place, it may prevent WEARVR from being able to validate your participation in the airdrop. This could mean you will receive fewer Weave tokens (or none at all) in that airdrop.

If you participate in a Weave airdrop, we may email you in the future about new airdrops or related product developments and news. We will also use this email address to provide further instructions or information about how to receive or manage the Weave tokens allocated to you in the airdrop.

We use databases and websites indexed by public search engines to find communities of people who have participated in previous cryptocurrency airdrops (or have expressed an interest in doing so). In these circumstances, we store email addresses in order to send information about Weave and Weave airdrops. In the first email we send to these addresses, we clearly explain where we encountered the email address, why we are sending the email, what information we have access to and how we use it. We also provide a link to remove the email address from our systems. We do not share, distribute, or otherwise make available, these email addresses.

We also work with marketing partners who help us advertise Weave airdrops to their communities or subscribers. In these situations, we do not process any user data until a user registers an account or signs up for an airdrop.

Email & correspondence

If you send us an email, we will store your email address and the information contained in the email, including your name or any other personally identifiable information you may choose to include. We do this in order to correctly address and appropriately respond to your email.

Similarly, if you use some other means of communication to contact us, we will process the information necessary to send you a response. In such an event, we may request additional details from you for the purpose of being able to respond via an alternative medium, such as email.

Who Has Access To Your Information

WEARVR Ltd will not share personally identifiable information with other parties except as described in this policy.

WEARVR Ltd will allow third parties performing services under contract with WEARVR to access and use personally identifiable information, but only to the extent necessary to provide those services.

The types of third party service providers whom we may share your information with include:

These service providers may have servers that store information outside of the EU.

WEARVR may release personally identifiable information to comply with court orders or laws that require us to disclose such information.

We do not pass on your data to third parties for any other purpose, unless you have given explicit permission for us to do so or this is permitted by law.

Cookies

In common with most websites, when you are browsing our site, we use cookies to help keep you logged in, save your place, record your settings or preferences, remember your previous actions or customise your experience. A cookie is an anonymised small file that is placed on your computer's hard drive that helps record your activity only on that site. A cookie in no way gives us access to your computer or any information about you. These cookies are used to help provide the information and services we offer.

WEARVR Ltd also uses analytic tools that use cookies to collect information concerning general usage of our websites, such as referring web addresses, page views and browser types. We use this information for analytic purposes and to measure the success of marketing and community outreach.

You can set your browser to disable or delete some or all of these cookies. If you chose to do so, some areas and functionality of the site may cease to function correctly or become inaccessible.

Retention of Personally Identifiable Information

We will keep logs of technical, usage and analytic data for up to 26 months.

If you have registered your interest in the Weave ICO, we will hold your data for a period of 5 years, unless you request for us to delete it under your Right to Erasure, explained in the Your Rights section below.

If you have provided further information to participate in the public or private token sale, or to receive Weave, then we will retain your information long enough to facilitate this transactions and to satisfy any legal obligations we have.

We retain the personal information that we collect from you only for as long as required for statutory, business, tax or legitimate interest purposes. Your information is retained in electronic or paper format or both. Otherwise, we securely erase your information where we no longer require it for the purposes for which it was collected.

Your Rights

Under GDPR, Data Subjects have a number of rights concerning the data we hold about them including:

Cross-border transfer of personal data

The transfer of the Data Subject’s data may be necessary in order to use the services of the WEARVR Ltd. Since the internet operates in a global environment, the use of the internet to collect and process Personal Data necessarily involves the transmission of data on international or cross - border basis. By using the website and marketplace of WEARVR Ltd, by communicating with us, you acknowledge and expressly consent to WEARVR Ltd’s processing and disclosure of your Personal Data in this way. By participating in the Weave ICO and registering with WEARVR Ltd, communicating with us and using our services, you provide your express consent to WEARVR’s disclosure of your Personal Data to third-party intermediaries (if applicable).

Security

WEARVR Ltd protects information collected using physical, technical, and administrative security measures to reduce the risk of disclosures, unlawful processing, accidental loss, destructions, damage and unauthorised access. Should a security breach take place, WEARVR Ltd will use reasonable endeavours to try to fix it.

Response to personal data breach

When WEARVR Ltd learns of a suspected or actual breach of Personal Data, WEARVR Ltd shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is a suspicion that there has been a breach of Data Subject’s Personal Data, the Company will notify the relevant competent authority within 72 hours from when WEARVR Ltd learns of such breach.

Governing Law

WEARVR Ltd is incorporated in Malta and by using our services and participating in the Weave ICO or providing the information to WEARVR Ltd, you consent of processing and transfer of information in terms of Maltese law.

Contact Details

If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please contact our Data Protection Officer on dpo@wearvr.com.

Complaints

If you’re not satisfied with our response to any complaint or you believe our processing of your information does not comply with data protection law, you can make a complaint to the lead supervisory authority in Malta which is the Office of the Information and Data Protection Commissioner using the following online form: https://idpc.org.mt/en/Pages/contact/complaints.aspx