Privacy Policy

Last revision date: July 2023

CloudSail Virtual Reality takes the privacy of its users very seriously. If you have any questions or concerns about our privacy policy, please feel free to contact us via our support form.

If you would like to opt out of data use, please select the "Don't use my data" option. For more information on how your data is used for interest-based advertising, please click here.

I. General Terms

This is the privacy policy of CloudSail Virtual Reality Technologies Ltd ("we" or "us"). This policy outlines our data protection practices and describes the types of information we may process when you use our mobile application chat box ("App", "Our App"). This Policy applies to all users ("Users") who access our App.

The term "personal data" or "personal information" means any information relating to an identified or identifiable natural person.

Personal data means any information relating to a natural person who can be identified, directly or indirectly, in particular by means of an identification number or one or more unique factors relating to his or her physical, physiological, psychological, economic, cultural or social status.

Under the GDPR, we are the data controller, unless otherwise specified.

California Consumer Privacy Act (CCPA) Privacy Statement 2018

California residents have the right under the CCPA to request

Categories of personal information processed;

The categories of sources from which personal information is obtained;

The purposes for which the user's personal data is processed

The categories of third parties with whom we may share your personal information;

The specific personal information we may obtain about a particular user if the data provided in the request is sufficiently reliable and identifies the user.

Please take the time to read this Privacy Policy carefully. By using the App, you acknowledge that you have read, understand and agree to these terms.

To view this Privacy Policy, please use the link provided.

Personal Data

Learn about the categories, sources, processing methods and purposes of personal data >> in this section.

Please note that under the CCPA, personal data does not include de-identified or aggregated consumer information.

Data Sharing

Learn about the methods of sharing your information in this section >> .

Please note that all third-party processors of user data are service providers who use such information under contractual agreements and for business purposes.

To prevent sharing of device identifiers and geolocation data with service providers, see your device settings for instructions on opting out, as described >> below.

Sale of Data

We do not sell any of your personal data to third parties.

Opting out

If you would like us to stop processing your personal data, please contact us using the contact form. Please note that in many cases the App cannot operate without functional data. In this case, we may recommend that you remove the App from your device.

Consumer Inquiries

If you wish to request access to, port or delete your personal information, please contact us using the contact form provided.

Please note the following when submitting your request:

If applicable, please include the words "Your California Confidentiality Rights" in the text of your complaint.

Please describe your request in sufficient detail for us to understand and respond appropriately.

Please provide sufficient information to allow us to reasonably verify your identity. This may include your name, address, city, state, zip code, and e-mail address. We may use this information to ask you security questions to verify your identity. If you make a request through an authorized agent, they must provide written authorization or a power of attorney signed by you confirming that they have the authority to act on your behalf.

In order to fulfill your request for personal information or deletion, we must be able to verify your identity and confirm that the personal information pertains to you. If we are unable to verify your identity or the authenticity of your request, we may not be able to fulfill your request or respond to your request. In order to verify your identity, we may ask you to provide additional information or documents. We may also conduct identity checks, including through third party verification services. These measures are designed to protect the security and privacy of your personal information from unauthorized disclosure or modification.

We will handle any personal information provided in verifiable consumer requests with care and ensure that it is used only for the purpose of verifying the identity of the requester or the authorization to make the request. We will retain this information for as long as is reasonably necessary for the above purposes and dispose of it once the purposes have been achieved.

We aim to respond to your verifiable consumer request within 45 days of receipt. If we need more time to respond, we will notify you in writing of the reason and the extended period. It is important to note that we are only obligated to fulfill two requests per customer per year.

Payment Information

Our e-commerce provider, Apple, is responsible for securely processing and charging for in-app purchases, as well as handling your personal information in a safe and secure manner. We cannot access or use your credit or debit card information because it is part of your contract with Apple. You can access the rules and policies for In-App Purchases directly from the App Store.

You can access the rules and policies governing In-App Purchases directly from the App Store.

Children's Privacy

Our App is designed for individuals who are 18 years of age or older, and we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under the age of 18, please do not use or provide any information on the App or through any of its features. If we learn that we have collected personal information from a child under the age of 18 without verifiable parental consent, we will delete that information as soon as possible. If you believe that we may have collected information from a child under the age of 18, please contact us immediately.

II. Processed Information:

a. Functional Data

In order to provide you with the services you have requested and to fulfill our contractual obligations, we require functional data. Without this information, we cannot guarantee the full functionality of the App.

User Content: This includes any text or other content that you enter in the message fields and send through the App, as well as any text or other content generated by AI through the App. You may use, share and otherwise utilize your User Content for your own purposes, subject to the rules and restrictions outlined in our Terms of Use. However, the use of User Content is entirely at your own risk and you assume all risks and liabilities associated with such use. You are solely responsible for ensuring compliance with applicable laws when using User Content. Please note that we use a third-party service provider, OpenAI, L.L.C., to process and create artificial intelligence-generated User Content. Please see Section IV to learn more about OpenAI, L.L.C.'s privacy policies and practices.

Contact Information: This includes your name, email address, and any other content you provide when you contact us via email or support form. We use our cloud storage provider, Amazon.com, Inc. to store and process this information. We use this information to respond to your inquiries, fulfill your requests, and provide you with requested services or communications.

b. Automatically Processed Information

We may be able to use third-party automated data processing technologies, such as advertising or analytics tools, to analyze specific information (e.g., advertiser ID for iOS devices/advertising ID or Android ID for Android devices) transmitted by your device through our App. Some of these integrated tools (see list in Section IV) may perform automated processing of your personal data, including profiling. Profiling involves any form of automated processing of personal data for the purpose of evaluating certain personal aspects relating to you and, in particular, analyzing or predicting aspects relating to your personal preferences, interests, behaviors, location, or movements (please see the list of data below). As soon as you allow our App to track your activities, the automatic data processing technology will start processing the information. You can revoke your permission at any time by reviewing the opt-out options in Section VIII below.

In order to improve the performance of our App, we may process information about your device and user behavior based on our legitimate interests (see the subsection "Information processed automatically" for more details). This data is usually non-personal, i.e. it cannot be directly linked to any particular individual, and we only access it in aggregate form. The information we collect may include

Mobile device data, including "device identifiers". A device identifier is a small data file or similar data structure stored on or associated with your mobile device that uniquely identifies your mobile device (but not your personality). Device identifiers enable third parties to provide generic reports or personalized content and advertising. We automatically process information about the device itself (device type, operating system type and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage), information about the Internet connection (mobile operator, network provider, network type, IP address, timestamps and session durations, speed, browser), location-related information (IP address, country code/region/state/city associated with your SIM card or device, language settings, time zone, neighboring business points of interest (e.g. "coffee shops")), other information." ("Coffee Shop"), other device identifiers: e.g. user identifier (if set by the developer of the application).

Application Information. The name, API key (identifier of the application), version and properties of the application can be reported for automated processing and analysis. Some services also record a list of applications and/or processes installed or running on your device.

Cookies and Similar Technologies. Cookies and similar technologies (pixels, web beacons, scripts) may be used when you use the App.A cookie is a text file containing a small amount of information that is downloaded to your device when you access the App. This text file is sent back to the server each time you use the App. This allows us to operate the App more efficiently; for example, we will know how many users visit specific areas or features within our App and what links or advertisements they click on. We use this aggregated information to understand and optimize use of the App, to improve our marketing efforts, and to provide content and features that are of interest to you. We may ask advertisers or other partners to serve advertisements or services to the App, which may use cookies or similar technologies.

Log File Information. Log file information is automatically generated and reported when you access the App. This information may also be provided when you install the App on your device. When you use the App, our analytics tools automatically record certain log file information, such as the start and stop times and dates of use and how you interact with the App.

Ad-Related Information. Information related to the ad you viewed, such as the time and date the ad was displayed, whether you clicked on the ad or whether the ad resulted in a conversion event, the content and type of the ad (e.g., text, image, or video), where the ad was displayed in the App, and your response to the ad, may be reported.

In-App Events. Analytics tools integrated into our App automatically capture and store data related to your in-App activities, such as completing tutorial steps, making in-App purchases or payments, triggering customized activities, progressing through levels or stages, and any opt-out mechanisms used to limit data processing.

Please note that we have no control over the information that is automatically provided to advertising or analytics tools and therefore cannot be responsible for the processing of such information. It is important to note that certain services analyze personal data and may obtain information related to your personality or device through technologies that are not within our responsibility. If your user ID is associated with your Facebook account, Facebook may use information about your device in conjunction with categorized data already recorded in its database, such as your age, gender, or other demographic indicators. We do not supervise, control or guarantee how third parties process your personal data collected through means other than our applications. If you have any questions about the disclosure of your personal data, please direct them to the relevant third party (see Section IV).

III. Purposes of data processing

We use your information for the following purposes:

Provision of the App and its services: We use your information to provide you with the App and its services. This includes processing functional information and automatically processing information to ensure that you can access and use the App as intended.

Improving the App: We use automatically processed information to analyze how users interact with the App, identify areas for improvement, and test new features and functionality. This helps us to continually improve the App and provide a better user experience.

Personalize Your Experience: We may use automatically processed information to personalize your experience in the App. For example, we may use this information to show you content customized to your interests or to recommend features or services that may be of interest to you.

To communicate with you: We may use your contact information to communicate with you about the App, such as to provide you with updates, respond to your inquiries, and provide customer support.

To enforce our policies and protect our rights: We may use your information to enforce our policies and protect our rights, including to investigate and prevent fraud, spam or other unauthorized activity and to comply with legal obligations.

If we use your information for any other purpose not listed here, we will notify you and obtain your consent as required by applicable law.

IV. Data Sharing

When we integrate external services, we carefully select third-party providers to ensure that appropriate technical and organizational measures are implemented to protect your personal data. However, we cannot guarantee the security of any information transmitted to third party providers. We are not responsible for accidental loss of or unauthorized access to your personal data due to the actions of third party providers.

We do not rent or sell your personal data to third parties, but we may share information from tools such as cookies, log files, device identifiers, and location data with third party organizations that provide automated data processing technology for the App. We have no control over these third party tracking technologies or their use.

We may also share certain information, such as cookie data, with third-party advertising partners. This information enables third-party ad networks to deliver targeted advertisements that they believe will be of most interest to you.

In order to provide us with the necessary infrastructure to deliver and improve our services, we may engage the following third-party service providers:

Services Provided Entity Name Entity Location Privacy Policy Link

OpenAI, L.L.C. (U.S.A.), a provider of artificial intelligence-generated content, please review the OpenAI Privacy Policy at https://openai.com/privacy/.

To learn more about the applicable license terms for user content, please visit https://openai.com/terms/

Analytics service provider Amplitude Inc. (U.S.A.) Please review the Amplitude Privacy Policy at https://amplitude.com/privacy

AppsFlyer Inc. (USA), a provider of analytics services, please review the AppsFlyer Privacy Policy at https://www.appsflyer.com/legal/services-privacy-policy/

Firebase (Google LLC) (US), a provider of user authentication, analytics and marketing services Please review the Firebase (Google LLC) Privacy Policy at https://policies.google.com/privacy

and

https://firebase.google.com/support/privacy?hl=en

In-app subscription implementation and revenue analytics service Qonversion Inc. (USA) Please review the Qonversion Privacy Policy at https://qonversion.io/page/privacy.

If you would like to learn more about our App's privacy options and services, including how to opt out, please see the relevant website and privacy policy.

Our App may contain links to third-party websites or services, or you may access our App from a third-party website.Please note that we are not responsible for the privacy practices of these third-party websites or services, including the information or content contained therein. Any risk arising from your use of these third party websites or resources is at your sole risk.

We may disclose your personal information where there is a legitimate reason, such as the public interest, or other unforeseen circumstances as required by law. We may also disclose your personal information in good faith to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to government requests.

In addition, if we are involved in a merger, acquisition, or sale of all or a portion of our assets, we will inform you of any change in ownership or use of your personal information and any choices you may have regarding your personal information through a prominent notice in our App.

V. International Data Transfers

We and third party organizations that provide automated data processing technology to the App or our third party advertising partners may transfer automatically processed information across borders from your jurisdiction to other countries or jurisdictions around the world.

Please note that this means that we may transfer information, including Personal Information, to countries and jurisdictions with data protection laws that differ from those in your jurisdiction. As a result, your Personal Information may be transferred to a third country, territory, or one or more specific regions within that third country, or to an international organization whose data protection and confidentiality laws and regulations may not provide the same level of protection for Personal Information as your jurisdiction.

By using the App, you agree that we may transfer your personal data to any third country, territory, or one or more specific sectors within such third country, or international organization.

For data storage purposes, we use the services of a hosting provider. We take your privacy very seriously and, where possible, we encrypt your personal data before sending it to the hosting service provider for storage. Please note that we only work with hosting service providers that have passed our security and reliability checks.

VI. How long we store and use your data

We only store your personal data for as long as necessary to provide the functional services of the App and to fulfill our legal obligations. If you decide that you no longer want us to use the information we actually access and store about you, you can ask us to delete your personal information and close your account.

However, certain data may still be stored for a limited period of time (but no longer than necessary) if required by law (for example, for tax, accounting or auditing purposes) or in order to maintain the security and backup of the data and to protect it from fraud or other malicious behavior.

VII. Exercising your rights

Applicable data protection laws give you certain rights with respect to your personal information. You have the following choices regarding the personal information collected about you:

Data Access and Portability. You may request a copy of your personal information.

Alteration or Correction of Data. You have the right to request that your data be corrected, changed, updated or rectified if you are unable to update the data yourself through your account.

Data Retention and Deletion. Generally, user data is retained for as long as your user profile exists or is required to provide the related services. However, the exact retention period may vary depending on the context of the processing performed. You have the right to request the deletion of all or part of the personal data concerning you.

Processing Restrictions. In some cases, you have the right to restrict the way in which your personal data is used.

You can exercise any of these rights by contacting us via our contact form. Please note, however, that we can only ensure the above rights for the information we actually access and store.

If your personal information is processed automatically, you have the right to object to this processing in certain circumstances. If your personal information is used for direct marketing purposes, you may request that we stop processing your data for these purposes. To exercise this right, please contact one of the third party services listed in Part IV of this Privacy Policy to find out how to object to the processing of your data. Many third-party services will provide clear instructions on their privacy pages, functional APIs or other options.

VIII. How to opt out

Opting Out of Location Data Processing

If you do not want our third-party service providers to use your precise location data or street-level location information, please follow the instructions below:

iOS 11 or later: Turn off location services for the applicable product via the menu "Settings > Privacy > Location Services". Then select the applicable app and set the "Share my location" status to "Never". See more information here: https://support.apple.com/en-us/HT203033.

Opting Out of Marketing Tracking

If you do not want our third-party service providers to use personalized ads based on your interests, please follow the instructions below:

Select the "Limit ad tracking" option in Settings/Privacy/Advertising on your iOS device, for more information: https://support.apple.com/en-us/HT202074.

Please note that opting out of certain interest-based ads does not necessarily mean that you will no longer receive any ads. You may still receive contextual ads based on non-personal information, such as the content of the digital product you are using.

IX. Data Security

We take the security of your personal information very seriously and have taken steps to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow industry standard practices to protect personal information submitted to us during transmission and while in our possession.

In order to protect your personal data, we have taken technical and organizational measures in compliance with data protection principles. We use encryption algorithms, including hash algorithms where feasible, to ensure the security of your personal data.

However, it is important to note that no method of internet transmission or electronic storage is 100% secure. Although we take appropriate measures to protect your personal data, we cannot guarantee its absolute security. In the event of a security breach that results in the disclosure of your personal data, we will promptly notify you as required by applicable law.

If you have any questions about the security of our App, you can contact us via the contact form.

X. Changes to our Privacy Policy

In order to remain consistent with our practices and legal obligations, we will periodically update this Privacy Policy.

If we make any changes to this Privacy Policy, we will update it and post the revised version on this page and in other relevant locations. Where appropriate, we may also provide you with other forms of notice of the changes.

XI.How You Can Contact Us About This Privacy Policy

If you have any questions about this Privacy Policy, you may contact us using our support form or by contacting us at

concat@paas3d.com.

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