Last update: 22 December 2022
Welcome to VRROOM!
To let you take the best part of our experience, at VRROOM we are particularly committed to protecting the privacy of your personal information. This document (the “Privacy Policy”) aims to provide you with the utmost transparency about the processing of your personal data. It applies to all users of the Platform, either registered Users or Guests.
We invite you to carefully read our Privacy Policy and to contact us for any question about the collection and processing of your Personal Data at the following e-mail address: [email protected].
Please note that the Privacy Policy is an integral part of the Terms of Use and that the definitions set forth therein are fully applicable to this document.
1. Scope and Platform
The Privacy Policy details the Personal Data collected and processed when using our Platform, the purposes for which Users’ Personal Data is processed, how VRROOM uses it, and the features offered to allow Users to access and update their Personal Data.
Personal Data is defined as any information relating to a natural person who can be identified, directly or indirectly. It is for example: the name, first name, email and postal address of a physical person, his/her image on a photograph or a video, an IP address, a location data, etc.
2. Acceptance and Changes to this Privacy Policy
By accepting the Terms of Use, you confirm that you have read and accept without reserve this Privacy Policy, which forms an integral part of the ToU. In case of disagreement with one or more of its conditions, the User is free not to use or no longer to use our services (especially in case of modification of the terms of the Privacy Policy).
This Privacy Policy may change from time to time, but any substantial modification will not be enforced without letting you know. VRROOM will make its best efforts to post any new version of the Privacy Policy on the Platform at https://vrroom.world/privacy-policy/ and will alert you with an information displayed at the following connection to the Platform.
As a rule, the Privacy Policy is always easily accessible at https://vrroom.world/privacy-policy/ or from your Account settings.
3. Identification of the Data Controller
The processing of your Personal Data is subject to European Union and French law, including Law No. 78-17 of January 6, 1978, as amended (known as the Data Protection Act) as well as the EU Regulation 2016/679 of April 27, 2016, known as the General Data Protection Regulation (GDPR).
According to the regulations in force, VRROOM – Perpetual Emotion; a French company with registered offices at 12 avenue Jean Jaurès 66270 Le Soler (FRANCE), enrolled in the Trade and Companies Register of Perpignan under the number B 834 566 580; is the Data Controller for the processing of your Personal Data.
In this quality, VRROOM undertakes to comply with the legal provisions in force and to carry out a lawful, fair and transparent processing of Personal Data of Users. VRROOM also guarantees to the Users that this processing is in accordance with the explicit and legitimate purposes determined in the Privacy Policy. The duration of processing does not exceed the time necessary for the purposes for which the Personal Data are collected and processed.
4. Categories of Personal Data Processed When Using the Platform
a) Which Personal Data Is Processed?
In order to provide access to the Platform, VRROOM may collect several categories of Personal Data about you, for different purposes and legal bases, and also for different retention periods. We offer a summary of all this information in the table below.
If you wish to know more about the Data collected and the purposes of processing you can also read the details below the following table.
| Purpose of the Processing | Personal Data Processed | Legal Ground for the Processing | Retention Period |
| Account creation and User identification – Account management | Mandatory profile data (Full name, ID, email address, date of birth, password, avatar) | Performance of the contract between You and VRROOM | Duration of the use of the services increased by 3 years after the last connection to the service or until the request for removal |
| Optional profile data (customizations, friends, voice chat, bodytracking data) | Consent | Duration of the use of the services increased by 3 years after the last connection to the service or until the withdrawal of consent | |
| Purchase of paid features | Transaction Data | Performance of the contract between You and VRROOM | Duration necessary for the execution of the transaction increased by the legal retention period for accounting purposes |
| Proper functioning of the Platform and its Services | Data related to your activity on VRROOM, Communications with VRROOM, Data related to devices and equipment used | Legitimate interests of the Data Controller | 2 years from collection date |
| Data sent by your device during the experience, Geolocation Data, depending on the device used | Consent | Duration of the use of the services increased by 3 years after the last connection or until the withdrawal of consent | |
| Administrative management of the Platform, complaints and reports from Users, Moderation of content in accordance with our ToU | Content Data (upload of shot pictures and videos, 3D models of worlds and avatars), Communications with VRROOM | Performance of the contract with the User | Duration of the use of the services + applicable statutory limitation |
| Management of the website security | Data related to navigation on websites (time stamps, IP address, technical data related to the equipment and browser used by users) | Legitimate interest of the data controller to ensure the security of its website and platform | 6 months |
| Moderation of content in accordance with the law (prevention of illegal activities, fraud, cyber harassment, …) | Content Data, Data about your activity on VRROOM | Compliance with our legal obligations | 1 year from collection for metadata 5 years (statutory limitation) for data retained for dispute prevention purposes |
| Newsletter | e-mail address subscription date statistics related to the newsletter service. | Consent | VRROOM keeps the e-mail address as long as the data subject does not unsubscribe (via the unsubscribe link integrated into the newsletters). |
| Connection with other Users | Contact data from your device | Consent | Duration of use of services or until withdrawal of consent |
| Geolocation |
● Details On The Personal Data Collected and Processed
VRROOM collects two different types of Data:
(i) Data that you provide to us
Profile Data: This is the Data that you are required to enter when you sign in: your name, date of birth, username, avatar, email address, and password.
Communications with VRROOM : When you report a problem with the Platform (inappropriate content, bugs, errors), respond to a survey about the quality of our Services, request assistance, or make a request to exercise your rights, we record the information you agree to share with us or that we need to respond to your request.
(ii) Data we collect when you use our Services
Data related to your activity on VRROOM: this notably includes:
– Connection Data: IP address, date of registration, date of your last connection;
– Data about how you interact with other Users: the number of friends, login and multimedia sharing via embedded browser, Ready Player Me Avatars management; Data about how you use our Services, including use in-App purchases to buy tickets and customizations, data about current and future events.
You can also fill in optional Data: customizations, friends, voice chat, bodytracking data.
Content Data: We process content that you create through our Services such as photos, videos, connection to external services providing these features (e.g. Vimeo) and comments.
Device and Equipment Data: We collect information about and from the devices and equipment you use to access VRROOM. This includes your IP address, device type, Platform crashes, operating system version, language used.
● Details of the legal basis and purposes of the processing
We process the above-described Data in accordance with the requirements of the GDPR for various purposes on the bases of:
– Contract performance where the processing enables VRROOM to provide the Services as described in the Terms of Use. This includes:
o Access to the Platform and related services;
o The proper functioning of Users’ accounts;
o Notifications about the events;
o Notification of changes to our services;
o User support services;
o Administration of the Platform, repair and correction of bugs, updates;
o The provision of services for sharing User Content and interacting with other Users;
– Our legitimate interests where the processing allows us to provide you with an efficient and dynamic Platform. This includes:
o Monitoring User Content, comments, messages and associated metadata for administrative purposes and to verify their compliance with our Terms of Use;
o Verifying the compatibility of the content presentation methods with respect to the type of device used;
o The understanding of the modalities of use of the Platform by the Users for the purposes of improvement, development and commercial promotion of the Platform;
o Verifying the stability and security of the Platform;
o Identifying criminal activities, fraudulent behavior, misuse of the Platform;
o Sending surveys and requesting feedback in order to improve the Services offered.
– Compliance with our legal obligations where the processing of Data is aimed at preventing and combating abusive, fraudulent, and illegal activities.
b) Cookies
A “cookie” (or “tracker”) is a connection indicator that designates a text file that may be recorded in a dedicated space on the hard disk of your terminal (computer, tablet, or smartphone), when you consult a service available online. A cookie allows its issuer to identify the terminal in which it is stored, during the period of validity or storage of the cookie. The cookie does not identify the User as such; it is used to record your browsing information on the Website.
When you connect to the Website, information relating to your browsing is likely to be recorded in “Cookies” files installed on your terminal, according to the choices you may have expressed concerning cookies and which can be modified at any time. These cookies allow personalized navigation and are also used for analytical purposes (audience measurement).
The existence of cookies and their purpose(s) will be indicated to you when you connect to the Website, by the presence of an information banner placed at the bottom or top of the home page.
The deposit and reading of cookies on your terminal generally require your prior consent, which, if applicable, is obtained by clicking on “I accept”. The consent given for the use of cookies is valid for 13 months. After this period, we will ask you to renew your agreement.
In case of refusal of cookies, objection to those stored by default, or deletion of the cookies, the User is informed that he/she can no longer benefit from a number of features that are nevertheless necessary to navigate in some areas of the Website. Where appropriate, VRROOM disclaims any responsibility for the consequences related to the degraded operation of its Services resulting from the inability of VRROOM to record or view the cookies necessary for the proper functioning of the Website and that you have refused or deleted.
Finally, it is important to distinguish the cookies issued on the Website from those issued by third parties. In this respect, we inform you that cookies may be placed from time to time on certain pages of the Website by third parties (advertisers or others). Please be aware that VRROOM has no control over the use of cookies by third parties.
VRROOM uses the following cookies and trackers:
● On the website www.vrroom.world :
○ Cookies that are necessary for you to use the Services, such as allowing you to stay logged into your account;
○ Cookies analyzing your use of the Platform to generate statistical reports, without identifying you;
○ Cookies necessary for the proper and efficient operation of the Platform, for example by saving your user preferences.
VRROOM Cookie Policy describing all the cookies used on the Website is available here: https://vrroom.world/cookie-policy/.
5. Conditions of use of Personal Data
Any change in the use of Personal Data as described in this Privacy Policy will require the prior acceptance of the User.
VRROOM undertakes to keep the Personal Data of the Users only for as long as is strictly necessary for the declared processing of the data for the above-mentioned purposes or for the exercise and establishment of its legal rights, and in any case within the limits imposed by the law.
VRROOM undertakes to delete the Personal Data from its databases at the end of these various periods. In case of request for deletion of your account, it will be effective within 30 (thirty) days. All of our backups are automatically deleted after 90 (ninety) days.
However, VRROOM may retain certain information for a period of time after the closure of the User’s personal account in order to meet legal, accounting and tax obligations and, in particular, to prevent possible unlawful behavior after the deletion of a User Account (reuse of an old account by a third party). In this case, the Personal Data will be deactivated and will no longer be accessible online.
6. Sharing of Information with Third Parties
a) Disclosure of Personal Data to third parties
Your information and Personal Data may, where appropriate, be transmitted to third party contractors involved in the provision of the Services (technical and hosting providers, sending notifications, publishing and sharing content, user tracking and satisfaction surveys, management of security incidents or fraudulent activity, etc.). When occurring, VRROOM shares such information with third parties either in their quality of Data Processor, or because their features are integrated within the Platform.
VRROOM undertakes to communicate Users’ Personal Data only to authorized and trusted service providers, who process it on our behalf, according to our instructions, in accordance with this Privacy Policy and in compliance with any other appropriate security and confidentiality measures.
Such disclosure is framed by a Data Protection Agreement with each third party, and they commit to respect the same level of protection than the one offered by VRROOM regarding the protection of your Personal Data.
b) Disclosure of Personal Data outside the European Union
Processing of Personal Data as described in the Privacy Policy may involve transferring your Data to one or more other countries, inside or outside the European Economic Area, including the United States.
Where applicable, we use standard contractual clauses and/or other mechanisms approved by the European Commission to maintain a level of protection for your Personal Data equivalent to that guaranteed by the GDPR.
c) Disclosure for Legal and Statutory Purposes
Information and Personal Data may also be disclosed to a third party if VRROOM is required to do so by law, regulation, or court order, or if such disclosure is necessary for the purposes of an investigation, court order or legal proceeding, either domestically or abroad.
In addition, VRROOM may share information and Personal Data with third party companies, consultants or individuals in order to:
● Enforce the Privacy Policy and the Terms of Use of the Platform in force, including to ascertain any breach thereof;
● Protect against any infringement of the rights, property or safety of its users, in accordance with and in compliance with the law.
7. Security of Personal Data
We implement technical and organizational measures, such as encryption of Data or restriction of access to authorized personnel, to ensure that your Personal Data is processed securely in accordance with the Privacy Policy. However, the transmission of information via the Internet involves irreducible risks that do not allow us to guarantee perfect security of the information transmitted via the Platform. Consequently, any transmission of Personal Data is made at your own risk.
8. Respect of the rights of the Platform Users
At VRROOM, we value the privacy and security of our customers’ data. We collect and use personal information only for the purpose of providing our services to our customers. We do not share or sell any personal information to third parties without explicit consent. Our customers have the right to request access to their personal data, as well as the right to request deletion of their data. If you would like to exercise these rights, please contact us at [email protected]. We will promptly respond to your request and take necessary actions to ensure compliance with GDPR regulations. We take all necessary measures to protect the confidentiality, integrity, and availability of our customers’ data, and we continuously review and update our privacy policy to ensure that we remain transparent and compliant with all relevant laws and regulations.
You have certain rights regarding your Personal Data, as follows:
1. Right of access: it allows you to access free of charge the Personal Data collected about you.
2. Right of rectification: it allows you to update or correct the accuracy of your Data. You can exercise this right directly from your account settings.
3. Right of deletion: it can be exercised when the processing of Personal Data is no longer necessary for the purposes for which they were collected or, if applicable, when you withdraw your consent to the processing.
4. Right to object to the collection and processing of all or part of your Personal Data: this right is not absolute and applies only to Personal Data collected for commercial prospecting purposes, including profiling when it is linked to commercial prospecting activities. When you choose to object to such processing we ask you to indicate the reasons for your objection so that we can balance our legitimate interests against your request.
5. Right to limit the processing of Personal Data. This right is not absolute, and can only be applied when:
● a request for rectification has been made under the right of rectification described in 8.2. You may then request that the processing of your Personal Data be stopped for the time necessary to verify the accuracy of the requested rectification.
● you wish to object to the deletion of your Personal Data whose processing was unlawful;
● VRROOM no longer needs the Personal Data in accordance with the purposes of processing but they are still necessary for the establishment, exercise or defense of legal claims;
● You wish to exercise your right to object as described in 8.4. You may then request that the processing of your Personal Data be stopped for the time necessary to balance our legitimate interests against your request.
6. You may also let us know your instructions regarding the preservation, erasure and disclosure of your personal data after your death and modify these directives at any point in time.
Before we can respond to a request to exercise one or more of your rights, we may ask you to confirm some of your Account information to verify your identity. In case of reasonable doubt, we may ask you for identification.
9. Information Regarding Children
VRROOM is not intended for children under the age of 13. If you believe that we have Personal Information about a child or that it has been collected from a child under the required age, you may report your concerns to us by reporting the content or the User Account.
10. Information About Users Located In the USA
This clause is only valid and legally binding if you are a party to the VRROOM Terms of Use. This clause regarding U.S. users, including California and Virginia residents, applies to Personal Information (as defined in applicable regulations) provided to VRROOM by the User.
In light of the California Consumer Privacy Protection Act of 2018 (“CCPA”), we are providing this information to you as a service provider required to process your Personal Information (as defined in the applicable law), to confirm that we have adequate contractual terms in place. The term “applicable law” refers to all laws, regulations, standards, regulatory guidance and self-regulatory guidelines that may apply in relation to the management of your Data. Applicable laws include, but are not limited to, the California Consumer Privacy Protection Act (Cal. Civ. Code §1798.100 – 1798.199), or the Virginia Consumer Data Protection Act (SB 1392).
As a service provider, we will collect, hold, use, disclose and process your personal information only to fulfill our obligations to you under our agreement, for operational purposes previously stated in this Policy, to the exclusion of any other purpose.
We will not sell your personal information or disclose your personal information for commercial purposes.
We certify that we understand and comply with the restrictions and obligations set forth in Cal. Civ. Code § 1798.140(w)(2) as well as Va. SB 1392. In the event of any inconsistency or conflict between the terms and conditions of this clause and the ToU or Privacy Policy, the ToU or Privacy Policy shall govern with respect to Data of individuals in the European Economic Area.
If you have any questions about the CCPA or other U.S. regulations at VRROOM or to exercise your rights under them, you may contact us as set forth in Section 11.
11. Contact
You can exercise these rights at any time in one of two ways:
● By mail to the following address: VRROOM – Perpetual eMotion, 12 Avenue Jean Jaurès 66270 Le Soler, France;
● By e-mail to: [email protected]
VRROOM undertakes to respond to your requests concerning the Privacy Policy or the exercise of your rights, as soon as possible and no later than the time limit set forth by applicable legislation.
You may also exercise some of these rights directly through your account on our website or by using the appropriate links in our newsletters or in our cookie banner with respect to withdrawing your consent.
If you consider that your rights have not been adequately respected, you are entitled to lodge a complaint with any Data Protection Authority (in France, the CNIL – Commission Nationale de l’Informatique et des Libertés).
