Personal Data

The so-called personal data refers to information which can be used to identify or reasonably lead to the direct or indirect identification of a living individual and, when combined with any other standalone information or any other information held by us, allows a particular individual to be identified. Personal data includes your name, birthday, location, country/region of residence, photograph, email address, etc.

Purpose and Type of Personal Data Collected

1. When you register a user account

   Each user is required to register an account before using the XRSPACE Service. When you register a user account on Service, we will require that you provide your email address or mobile phone number and set up an account password. You can register a user account with a third party account (such as Apple or Google account), and we may obtain your personal data from the third party within the scope of your consent. In addition, we will also collect your date of birth and account nickname.

2. When you create an avatar

   After creating the user account, each user is required to create his/her own avatar. We will collect the information of the photos or pictures you use for creating the avatar. You may edit the avatar with the default ones.

3. When you sign in to Service

   After you successfully sign in to and use XRSPACE Service, we will collect the information of your wireless network or communication network and IP address. We will collect the information of your voice, facial expressions, gestures, motions, body movements to enable your created avatar(s) to act and speak in real time in Service. In relation to the status of your use of Service, we will also collect information relating to your sign-in time, sign-out time, and your user behaviors and activities in Service.

   When you create Mood, 3D Reel, My Space or My Motion, we will ask you to grant access to cameras, photo albums, videos or microphones of your mobile phone in accordance with the type of feature you use.When you interact with other users in Service

4. You can interact with other users in the XRSPACE Service. We will collect the information of users whom you are following and who are following you, histories of your interactions with other users. When you interact with other users, we will ask you to grant access to camera and microphone of your mobile phone in accordance with the type of interaction feature you use. If you organize events or participate in events held by us or other users in Service, we or the other users may record the events by video recordings or livestream them to any other third one(s). Your or other ones’ avatars, along with your or their facial expressions, actions and voice, will be recorded in video recordings or livestreamed.
   When you share User Content

   Nickname, ID and User Content stored in user profile of all users are public, which will be visible to any user in Service as well as any third one without the user account and may also be accessed or shared by third parties such as search engines or social media.

5. When you use embedded browser in Service

   When you use embedded browser in Service, the browser will record your cookies, browsing history and other usage information, and you can delete the aforementioned usage information in the browser.

6. When you view User Content on Service

   When you view User Content on XRSPACE Service, we will collect your location to ensure that you meet intellectual property rights policy of viewing such User Content.

7. When you make a customer service request or report to the company

   When you think you have questions, system errors or mistreatment during the use of XRSPACE Service, you can submit a customer service request or report to us, and we will collect your name, nickname and ID in your user account, email address and your request or report content. Therefore, your request or report content may include your personal data and the personal data of others. Please pay attention to avoid submitting unnecessary personal data to us.

8. When we update the application

   We may release XRSPACE application updates from time to time to ensure the safety and fluency of your use of XRSPACE Service. We will periodically obtain device information from your device to confirm whether your device needs to be updated.

9. Use of TrueDepth API

   XRSPACE application (iOS version) uses the TrueDepth API provided by Apple Inc. to keep track of your facial expressions and body movements while some specific features are executed. The tracked data is collected and displayed in conjunction with the facial expression and body movement animations registered on your created avatar(s). The information collected by the TrueDepth API is never stored on your device and is not shared with third parties.
   
   

Retention Period of Personal Data

Your personal data collected by us will be retained and shall be deleted or destroyed in a safe manner upon the suspension or deletion of your user account. The aforementioned retention period shall not apply under the following circumstances:

1. When it is within the period required to achieve the aforementioned purpose and develop relevant business; or

2. The law provides for a longer retention period; or

3. When the government or the judiciary refers to materials according to law or when it is within the period required for the establishment, exercise or defense of civil, criminal or administrative claims and lawsuits.
   
   

Where and How Personal Data Is Processed

Your personal data will be collected and processed mainly in the territory of Taiwan, and, if necessary, will be used in the location of the outsourced agency entrusted to handle the affairs of the company, or used in the location of the party which acquires XRSPACE application (in such an event, personal data may be deemed relevant assets related to XRSPACE application and be transferred accordingly. Within the scope of a specific purpose, we will use written, electronic files, electromagnetic records, newsletters, telephones, faxes, electronic or manual search and other legal automated or non-automated methods for processing, utilization and international transmission.

By Whom Personal Data Is Used

We keep your personal data strictly confidential and will only provide it to the recipients below. We will only share your information with third-party controllers outside of us with your consent and you have the right to choose not to share your information with us. We may share your personal data with the following recipients:

1. Other users of Service will see your avatar or hear your voice during or outside the period of using Service.

2. Our group companies, affiliates and branches located around the world which will need access to the personal data to provide you with our services; or for internal management purposes; or for the detection and management of personal data breach, illegal activities or fraud and maintenance to ensure the integrity of our information technology system.

3. Third-party service providers which represent us or will process personal data on our behalf or for us, under the obligations of this notification and general personal data notifications, for the sole purpose of performing relevant tasks on our behalf. Outsourced third-party service providers include customer service centers, freight forwarders, cloud service providers, voice transmission service providers, automatic program update service providers, payment providers, banks, third-party account service providers, real-time data cascading service providers and other vendors.

4. A party which merges with or acquires all or part of the company’s business assets. In such an event, personal data may be deemed relevant business assets and be transferred accordingly.

5. Governments and/or government-related agencies, courts or law enforcement agencies in order to comply with our obligations under relevant laws and regulations, to implement or perform our policies or contracts with you, to respond to letters or requests from government entities or criminal units in relation to investigations or litigation procedures or in response to suspected fraud or illegal activity which may expose you, us, or any of our other customers to legal liability.

6. A third party involved in legal procedures (if the third party provides us with a court order or has similar legal procedures which requires us to provide personal data).

7. Others who you agree to share personal data with.
   
   

We may provide you with the opportunity to connect to third-party applications or services through our application. We may, upon your consent, provide your personal data if you choose to use any such third-party application or service. However, we do not control these third-party applications or services or how your data may be used and your use of such application or service is not subject to Policy or general personal data notice. Before using third-party applications or services, please check the terms of use and privacy policies of those third parties.

Cross-Border Data Transfer

We are a global company comprised of multiple offices and affiliated entities in numerous jurisdictions. By using XRSPACE Service and providing your personal data to us, you acknowledge and agree that we can transfer your personal data to the abovementioned recipients. These recipients may be located in countries outside your country of residence. Although personal data protection laws of these countries/regions may differ from the laws of your country/region, we will ensure that appropriate protective measures are taken to ensure that your personal data will continue to be protected in accordance with Policy.

The Minor’s Personal Data

XRSPACE Service is not provided for children under 13 years of age. If a person under the minimum age specified by personal data protection laws and regulations of his/her geographic jurisdiction is required to use Service, the explicit consent of their parents must also be provided and verified. If we are notified or finds that the information collected comes from a person under the minimum age, the company will take steps to delete their personal data as soon as possible.

Your Rights

In accordance with the provisions of applicable personal data protection laws in your respective geographic jurisdiction, you can exercise the following rights in accordance with law regarding your personal data collected by the company:

1. Inquire or request reading;

2. Request to make a copy;

3. Request for addition or correction;

4. Request to stop collecting, processing or using;

5. Request to delete; and

6. When feasible, request for the company to transfer the data directly to a third party designated by you.

You can view or revise data or terminate your user account at any given time by signing into or updating your user account. You may also contact us (see "Contact Information" section below) to view or revise data or to terminate your user account.

If you no longer wish to receive letters, emails or other information from us, you can opt-out using the following methods:

1. Choose your preference during account creation.

2. Sign in to your user account settings and update your preferences.

3. Contact us using the contact information provided below (see "Contact Information" section below).
   
   

If you no longer wish to receive letters, emails or other information from a third party, please contact such third party directly.

After you request to terminate your user account, we will disable or delete your user account and information from our activity database. However, we may retain certain information to prevent fraud, for troubleshoot purposes, to assist in any investigations, to enforce our service agreement with you and/or to comply with legal requirements.

Impact of Your Unwillingness to Provide Personal Data

If you do not provide the personal data required for creating a user account and an avatar, you will not be able to use XRSPACE Service; if you do not want to provide other personal data, you may not be able to use certain feature(s) in Service or affecting your user experience. Please refer to Article 2 of Policy "the purpose and type of data collection by the company" for the detailed description.

Data Security

We have implemented technical and organizational security measures in an effort to protect and store your personal data. Such measures include, for example, limiting access to personal data only to staff and authorized service providers on a need-to-know basis for the purposes described in Policy, as well as other administrative, technical, and physical safeguards.

Since the internet is a public, global communication system which poses inherent risks, we will try our best to protect our system, website, various operations and information from unauthorized access, usage, modification and disclosure, However, we cannot guarantee that any data transmitted or stored on our system will never be breached (e.g. attacked by hackers) during this period.

Update of Policy

The company will update Policy from time to time according to the actual situation. The company encourages you to periodically review Policy to ensure that you are aware of the content of Policy update. If necessary, we will also notify you of amendments made to Policy via Service, our website or email.

Contact Information

If you have any questions about Policy or wish to exercise any of the above mentioned rights, please contact support@xrspace.io.