This Privacy Policy (“Policy”) describes the manner in which VRChat, Inc. (“VRChat”, “we,” or “us”) collect, use, and disclose information about you through our website at www.vrchat.com (our “Site”), along with our related websites, networks, desktop applications (each, a “Desktop Client”), VR headset applications (each, a “VR Client” and together with any Desktop Clients, “Clients”), software development kits for use in connection with any technology or services made available by or on behalf of VRChat (each, an “SDK”), and other services provided by us and on which a link to this Policy is displayed (collectively, including any Clients and SDKs, the “Platform”). This Policy is incorporated into and is subject to the VRChat Terms of Use (available at www.vrchat.com/legal). By using the Platform, you consent to the collection, use, and disclosure of your information as described in this Policy.

1. Information We Collect on the Platform

(a) User-provided Information: When you use the Platform, we may collect or you may provide information about you and we may link this information with other information about you. You may provide us with information in various ways on the Platform. For example, you provide us with information when you register for an account (we will collect your email address, birthday, and allow you to create a username and password), subscribe to our newsletters, use the Platform, make a purchase on the Platform, or send us customer service-related requests.

(b) Cookies and Automatically Collected Information: When you use the Platform, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Platform. Please review your web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Platform, you may not be able to utilize the features of the Platform to their fullest potential. We may use third party cookies on our Platform as well. For instance, we use Google Analytics to collect and process certain analytics data. To learn more about how Google Analytics uses your information and what choices you have, please visit www.google.com/policies/privacy/partners/. VRChat does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use our Platform.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Platform, the pages or other content you view or otherwise interact with on the Platform, and the dates and times that you visit, access, or use the Platform. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users and may be connected with other information about you.

(c) Information Disclosed While Using the Platform: When using the Platform, including participation in different “rooms” made available to users of the virtual-reality component of our Platform, you may disclose to us and to other users of the Platform information about you. This may occur when you engage in conversations, chats, or other user-to-user interactions. We may collect and use this information to the extent permitted by law.

(d) Payment Information: If you choose to access or use parts of the Platform that require payments or fees, we may require you to provide financial information to us for the purpose of processing those payments. We may provide your payment information to third party payment processors who process transactions on our behalf. We may also collect and retain information relating to the transactions you conduct.

(e) Location Information: We may use your IP address to obtain general information about the physical location from which you are connecting to the Internet.

(f) Third Party Web Beacons and Third Party Buttons: We may display third-party content on the Platform. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third party content on the Platform. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by VRChat. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies. Please note that privacy choices you have made on VRChat will not carry over to third party sites or Platforms (and vice-versa).

(g) Information from Other Sources: We may obtain information from third parties and sources other than the Platform, such as analytics partners and advertisers.

2. How We Use the Information We Collect

We use information we collect on the Platform (in both individual and aggregate format) in a variety of ways in providing the Platform and operating our business, including the following:

(a) We use the information that we collect on the Platform to operate, maintain, enhance and provide the Platform, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Platform.

(b) We use the information that we collect on the Platform to understand and analyze the usage trends and preferences of our users, to improve the Platform, and to develop new products, services, features, and functionality.

(c) We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including required notices, marketing communications, or updates on promotions and events relating to products and services offered by us and by third parties.

(d) We may use information to: (i) personalize our Platform, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Platform; (ii) provide customized content, and information; (iii) monitor and analyze the effectiveness of the Platform; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; (v) track your entries, submissions, and status in any promotions or other activities on the Platform; (vi) detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Platform; (vii) or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

(e) We may also use information for other purposes for which we provide specific notice at the time the information is collected.

3. When We Disclose Information

Except as described in this Policy, we will not disclose information about you that we collect on the Platform to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

(a) We work with third party service providers who provide website, application development, hosting, payment, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us.

(b) We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

(c) We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Platform and any facilities or equipment used to make the Platform available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

(d) Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

(e) We may make certain aggregate or otherwise non-personal or de-identified information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Platform.

4. Your Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Platform. You may update your profile information through the Platform. If you wish to access, update, delete or amend any other personal information we hold about you, you may contact us at [email protected]. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at [email protected] or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Platform.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Platform.

Residents of California may have additional rights – please see the California Resident Privacy Notice at the end of this policy for more information.

5. Third-Party Services

The Platform may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Platform. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Platform. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

6. Children’s Privacy

Our Site is a general audience site not directed to children under the age of 13, and we do not knowingly collect personal information from children . If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below and we will delete any such account or profile and associated information.

7. Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

8. International Visitors

The Platform is hosted in the United States. If you choose to use the Platform from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Platform. By providing any information, including personal information, on or to the Platform, you consent to such transfer, storage, and processing.

9. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Platform, and indicate the effective date. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Platform for the first time after such material changes are made. Your continued use of the Platform after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

10. How to Contact Us

Please contact us with any questions or comments about this Policy, information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email at [email protected].

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

In the preceding twelve months, we have not sold any California resident’s Personal Information.

Use of Personal Information 

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

1. Providing Services: Providing our services.

2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.

3. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.

4. Personalization: Personalizing your experience on our services such as presenting tailored content.

5. Facilitating Payments: Facilitating transactions and payments.

6. Deidentification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.

7. Safety Issues: Responding to trust and safety issues that may arise.

8. Compliance: For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

9. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

10. Debugging: Debugging to identify and repair errors that impair existing intended functionality.

11. Transient Use: Short-term, transient use.

12. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

13. Research: Undertaking internal research for technological development and demonstration.

14. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

15. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

16. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Collection of Personal Information 

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

1. You/Your Devices: You or your devices directly.

2. Analytics Providers.

3. Social Networks.

Disclosure of Personal Information 

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties:

1. Analytics Providers.

2. Government: Government entities.

3. Social Networks.

4. Vendors: Vendors and service providers.

5. Third Parties as Legally Required: Third parties as required by law and similar disclosures.

6. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.

7. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

Your California Privacy Rights 

If you are a California resident, you may exercise the following rights. 

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. We may seek to verify your identity by asking you to log in to your password protected account. If we are unable to verify your identity in this way, we may ask for additional information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please send an email to [email protected] or write to us at 548 Market St, PMB 93053, San Francisco, CA 94104-5401.

Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.

Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at [email protected] or write to us at 548 Market St, PMB 93053, San Francisco, CA 94104-5401.