Privacy Policy

You should read this policy in full, but here are the key points:

• When you download vTime XR or use our services or website you may share certain personal information with us - such as your date of birth, your email address and so on.

• In addition, we also collect a variety of information about how you use our website and vTime XR app - such as details of the device you are on, your IP address, how long you’re on the service and so on.We need to collect, store and process this personal data in order to provide a safe, reliable and legal service and to understand how our website and vTime XR app are used, so we can make them better.

• We do not routinely view or listen to your conversations in vTime XR, and do not routinely view any images you upload. But we can, and do, moderate images if we suspect they breach our Acceptable Use Policy or community guidelines.

• We do all we can to protect and safeguard your data, keeping it for the minimum time necessary. You can ask to see your data and ask for it to be rectified or deleted, although deletion would result in you no longer being able to use our service.

vTime Master Privacy Statement

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how vTime Limited collects and processes your personal data through your use of our website, and the vTime XR app and other services, including any data you may provide when you use our vTime XR app, sign up to our newsletter or take part in a competition.

Our apps and services are not intended for children (anyone under 16 years of age) and we do not knowingly collect data relating to children. You may from time to time be requested to verify your age as set out in our Age Verification Policy which can be found in our terms and conditions.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them. Please read our terms and conditions in full to understand the terms you must agree to in order to use our services.

Please note that if you have downloaded our app known as “vTag” that app has a separate privacy policy and terms and conditions that relate to its use and we would request and encourage you to read those terms if you wish to use “vTag”. If you don’t accept those terms you should not use vTag.

CONTROLLER

vTime Limited is the controller and responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

• Company name: vTime Limited
• Name and title of privacy manager: Stephen Houston, General Counsel and Director
• Email address: [email protected]
• Postal address: 27 Parliament Street, Liverpool, UK. L8 5RN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on July 4th, 2020 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our apps, services and website may include links to third-party apps, websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party apps or websites and are not responsible for their privacy statements. When you leave our apps or website, we encourage you to read the privacy policy of every app and website you use and their terms and conditions.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. Identity Data includes first name, last name, username or similar identifier, title, and date of birth.
2. Contact Data includes email address.
3. Technical Data includes internet protocol (IP) address, your login data, device type and version, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our apps, services and website.
4. Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
5. Usage Data includes when and where you log on to our apps, what device you use, who you speak or message with, your friends list and how long you spend on the apps.
6. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app or website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you (such as our terms and conditions) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you the vTime services through our vTime XR app). In this case, we may have to cancel the services you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your Identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   1. create an account on our apps, services or website;
   2. request marketing to be sent to you;
   3. enter a competition, promotion or survey; or
   4. give us some feedback.
2. Automated technologies or interactions. As you interact with our website, services or apps we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
4. Technical Data from the following parties:
   1. analytics providers such as Google or Facebook;
   2. search information providers such as Google;
   3. platform holders, such as Oculus.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you though our terms and conditions.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal or regulatory obligation.

The types of lawful basis that we will rely on to process your personal data are set out in the table below.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the vTime group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you, by following this link, or by contacting us at any time.

Where you opt- out of receiving these marketing messages, this will not apply to personal data provided to us as a result of using our apps or services.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our apps, services and website may become inaccessible or not function properly. For more information, read our full Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules and our terms and conditions or where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

1. Internal Third Parties as set out in the Glossary.
2. External Third Parties as set out in the Glossary.
3. Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy and our terms and conditions

We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, unless you have agreed or consented to them doing so, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you have registered to use vTime XR using other social media platforms or other external Third Parties (such as Facebook, Instagram, Google, Apple), for example through single sign on, you or they will provide us with your username and public profile. In return we share certain Technical Data with those external Third Parties such as your IDFA (on iOS) or Advertiser ID (on Android) and the referring URL for the purposes set out in paragraph 4 above.

For all users certain Technical Data such as the IDFA (on iOS) or Advertiser ID (on Android) associated with a user is sent to Facebook, in order to attribute the source of a user of our app, unless they have opted-out on their device. We may share this information with other external Third Parties such as social media platforms or advertisers, too. In this way we can verify if a user has accessed our app from Facebook or other platform and we can then analyse how effective our adds on that platform have been and we can use that data to bring you more relevant adds and to improve your experience. The use of this data and its processing by Facebook or another external Third Party will be under their terms and conditions and privacy policy.

For all users certain Technical Data such as the IDFA (on iOS) or Advertiser ID (on Android) associated with a user is sent to CFG (“City Football Group Limited”), in order to attribute the source of a user of our app, unless they have opted-out on their device. In this way we and CFG can verify if a user has accessed our app from CFG related apps or if the user is, for example, a registered member of a fan club associated with CFG. The use of this data and its processing by CFG will be under CFG’s terms and conditions and privacy policy.

Where you share content on other social media platforms, the relevant content, username and accompanying text and audio file may be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content may be shared.

You can access Facebook’s, CFG’s other relevant external Third Party’s terms and conditions and privacy policies in the Glossary Section below.

We also incorporate various third party plugins and libraries of software into our apps in order to build the vTime XR functionality. A full list can be found here. Based upon the the licence agreements and supporting documentation provided by them to us, we believe they do not share any personal data with third parties. However, if you are concerned, you should familiarise yourself with their individual privacy policies.

6. INTERNATIONAL TRANSFERS

Many of our external third party service providers or partners are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
2. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we >process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract processing your data where it is necessary for the performance of a contract to which you are a party (such as our terms and conditions) or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the vTime Group acting as joint controllers or processors and who are based in the UK or the US.

EXTERNAL THIRD PARTIES

Service providers acting as processors based in the US who provide IT and system administration services used by us are set out below. We also list other social media platforms with whom we may share data for the reasons set out above at paragraph 5, Disclosure of Your Personal Data. You should review and familiarise yourself with their individual privacy policies.

1. Amazon Web Services - is used for storage of data and server infrastructure. Amazon Web Services have no direct access to vTime users’ personal information.
2. Apple - we may share certain Technical Data with Apple to enable single sign on. Apple’s ability to store and process information collected by Apple about you is restricted by Apple’s Terms of Use and Apple’s Privacy Policy.
   
3. CFG - we may share certain Technical Data with City Football Group Limited so that they and we can verify if a user has accessed our app from CFG related apps or if the user is a registered member of a fan club associated with CFG.
4. Facebook - we share certain Technical Data with Facebook in order to enable single sign on and to verify the effectiveness of our adds on their platform and to enable us to provide you with more relevant adds, so as to provide you with a better experience. Facebook’s ability to store and process information collected by Facebook about you is restricted by Facebook’s Terms of Use and Facebook’s Privacy Policy.
5. Google Analytics - we may share certain Technical Data with Google to enable single sign on. We use Google’s services to help us anlayse the usage of our app in order to create a better user experience and improve our System. Google’s ability to store and process information collected by Google Analytics about your visits to our apps, website and system is restricted by the Google Terms of Use and the Google Privacy Policy.
6. Instagram -we may share certain Technical Data with Instagram in order to verify the effectiveness of our adds on their platform and to enable us to provide you with more relevant adds, so as to provide you with a better experience.
7. Mailchimp - we sometimes use Mailchimp’s services to help us with marketing activities. Mailchimp’s ability to store and process information collected by Mailchimp about you is restricted by the Mailchimp Terms of Use and the Mailchimp Privacy Policy.
8. WhatsApp - if you share information on this platform WhatsApp’s ability to store and process information about you is restricted by WhatsApp’s Terms of Use and WhatApp’s Privacy Policy.
   
9. Unity - Unity’s ability to store and process information collected by Unity about you is restricted by the Unity Terms of Use and the Unity Privacy Policy.
10. Oculus Avatar and Platform SDK - Oculus’ ability to store and process information collected by Unity about you is restricted by the Oculus Terms of Use and the Oculus Privacy Policy.
11. Facebook Unity Plugin - Facebook’s ability to store and process information collected by Facebook about you is restricted by the Facebook Terms of Use and the Oculus Privacy Policy.
12. HM Revenue & Customs, regulators and other law enforcement authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances