VISUAL VOCAL

Privacy Policy

Last Updated: October 7, 2016

30 60 90 Corporation (“Visual Vocal”, “us”, “our” and “we”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users this website and any other websites of Visual Vocal (collectively, the “Site”), our mobile application called “Visual Vocal” (the “App”) and the services offered through the Site and App (collectively with the Site and App, the “Services”). We will only process your personal data in accordance with applicable data protection and privacy laws. For the purpose of EU data protection legislation, the data controller is 30 60 90 DBA Visual Vocal of 223 Yale Ave N, Seattle, WA 98109.

1. Questions; Contacting Us; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

30 60 90 DBA Visual Vocal

Attn: John SanGiovanni

223 Yale Ave N, Seattle, WA 98109

1-425-269-7537

2. A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Visual Vocal and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at [email protected].

3. A Note to Users Outside of the United States. If you are a non U.S. user of the Services, by using the Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be transferred to, stored at and processed in the country in which it was collected and in other countries, including but not limited to the United States, where data protection and privacy laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data and using the Site or App, you consent to such transfer, storage and/or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

4. Types of Data We Collect. “Personal Data” means any data, either alone or in combination with other information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

(a) Voice Recordings and Gaze Information. In connection with your use of the Services, we will collect voice recordings that you make using the Services as well as “gaze” information (i.e., information regarding the direction your head is pointed when using the App), and will use and disclose this information in accordance with this Privacy Policy. You expressly consent to such collection, use and disclosure of such information.

(b) Information You Provide to Us

We may collect Personal Data from you, such as your first and last name, e-mail, picture, gender, company name and password when you create register for an account on the Services (“Account”).
If you use our Services on your mobile device, including through our Application(s), we may collect certain mobile device identification information such as the type of mobile device you use, the email you use in connection with your Android device (if applicable), mobile operating system version, etc..
We retain information on your behalf, such as data, content and other information or materials that you store using your Account.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
When you post content on or through the Services, the information contained in your posting will be stored in our servers and Project Owners (defined below) may be able to see it depending on your Account settings, which may be set by the administrator for the enterprise customer (“Customer”) who invited you to use the Services (“Project Owner”).
When you participate in one of our surveys, we may collect additional profile information.
We may collect information regarding the AR/VR viewer you are using with the App (e.g., Cardboard, Homido, Samsung Gear VR, etc.).
We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail or web form provided by the third party service, ZenDesk, regarding support for the Services.
If you post content on or through Visual Vocal’s social networking pages, those postings are, by default, public. Any anyone who visits such pages will be able to see such content. Visual Vocal reserves the right (but has not obligation) to respond to or remove such postings.
If you participate in a sweepstakes, contest or giveaway on our Site or App, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
We may also collect Personal Data, such as at other points in our Site or App that state that Personal Data is being collected.

(c) Information Collected via Technology

Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most online services, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Site or App, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you use the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Pixel Tags. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
Note: Does the Site/App allow third parties to serve ads on the Site and place cookies and pixels to track users?
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Services.
Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our App. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the App, and information about the type of device you use. In addition, in the event our App crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

(d) Information Collected from You About Others. If Customers invite you or a third party to create an Account, we will collect certain information from you or the third party such as your first and last name, e-mail, picture, gender, company name and password from the Customer in order to invite you or the third party to create an Account. You or the third party may contact us at [email protected] to request the removal of this information from our database.

(e) Information Collected from Customers. We may receive Personal and/or Anonymous Data about you from Customers. We may add this information to the information we have already collected from you in order to improve the Services we provide.

(f) Information from Social Networking Sites. Our Services may include interfaces that allow you to connect with social networking sites, such as Facebook, LinkedIn, and YouTube (each an “SNS”). If you connect to an SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

5. Cookies

(a) What are Cookies? Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site or App. This type of information is collected to make the Site or App more useful to you and to tailor the experience with us to meet your special interests and needs. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site or App; and (2) third party cookies, which are served by service providers on our Site or App, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

(b) Cookies we use. Our Services use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies	In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you use the Services. This includes third party analytics services, including but not limited to Google Analytics and Unity Analytics (“Analytics Services”), that we engage to help analyze how users use the Services, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Services. The information generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of service and privacy policy. By using our Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at [email protected] You can find out more information about Unity Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB You can find out more information about Unity Analytics cookies here: https://unity3d.com/legal/cookie-policy#cookies You can find out more about how Unity protects your data here: https://unity3d.com/legal/privacy-policy There are several browser plugins available to Users that want to be better informed about and have more control over the use of cookies and related technologies on their devices. Some popular ones are Ghostery (https://www.ghostery.com/en/) and Abine (http://www.abine.com/index.html).
Targeted and advertising cookies	We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

(c) Disabling Cookies. If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, please visit http://www.allaboutcookies.org; http://www.aboutads.info/, http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/. Please note that even if you do choose to remove cookies by the third parties listed at the above links, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

6. Use of Your Personal Data

(a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We may use your Personal Data in the following ways:

facilitate the creation of and secure your Account on our network;
identify you as a user in our system;
provide improved administration of our Services;
provide the Services you request;
improve the quality of experience when you interact with our Services;
send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
send you administrative e-mail notifications, such as security, or support and maintenance advisories;
send you push notifications or push messages to your device;
respond to your inquiries or other requests; and
with your consent, send newsletters, surveys, offers, and other promotional materials related to our Services and for our other marketing purposes.

(b) User Testimonials and Feedback. We often receive testimonials, feedback and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user’s consent prior to posting his or her name along with the content. If you make any comments on a blog or forum associated with our Services, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. In addition, Visual Vocal may use and disclose such comments in accordance with our Terms of Use and this Privacy Policy. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

(c) Creation of Anonymous Data.We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

(d) Data Integrity. Visual Vocal will use Personal Data only in ways that are compatible with the purpose for which it was collected or subsequently authorized by you. Visual Vocal will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. Visual Vocal depends on you to update and correct your Personal Data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.

7. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

(a) Third Parties Designated by You and/or Project Owners.< When you use the Services, the Personal Data you provide will be shared with the third parties that you or the Project Owners designate to receive such information in accordance with your Account settings (which may be set by the Project Owners). You may change your Account settings at any time by going to your Account and changing the settings or contacting the Project Owners.

(b) Project Owners. Project Owners will be able to see and edit the Personal Data in your Account, change your Account privileges, and observe the activity on the Services of end users who are members of a project for which the Project Owner has Project Owner Permissions.

(c) Customers. We may share all or a portion of your Personal Data with Customers.

(d) Users. We will share your Personal Data with other users in accordance with your Account settings solely for the purpose of providing the Services.

(e) Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you; to conduct quality assurance testing; to facilitate creation of Accounts; to provide technical support; and/or to provide other services to Visual Vocal.

(f) Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

(g) Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(h) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Visual Vocal may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Visual Vocal; (c) to protect or defend the rights or property of Visual Vocal or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

8. Information Disclosed to Third Parties. This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Services. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party (such as a Customer or other users). We do not control the privacy policies of such third parties, and you are subject to the privacy policies of those third parties where applicable.

9. Third Party Websites. Our Services may contain links to third party websites. When you click on a link to any other website or location, you will leave our Services and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

10. Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:

(a) Email Communications. With your consent, we will periodically send you newsletters and e-mails that directly promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.

(b) Push Notifications. If you do not want to receive push notifications, you can disable these services through your mobile device settings.

(c) Accessing, Changing or Deleting Your Personal Data. You may access or request a change to or deletion of your Personal Data by sending an e-mail to us at the e-mail address above. In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data that you have provided to us. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that deletion of your Personal Data may result in some or all of the Services being inaccessible or not functioning correctly.

(d) Applications. You can stop all collection of information by the App by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. To serve ads in our App where Cookie technology is not available, Visual Vocal hashes users’ device ID. Users may choose to reset or opt out of anonymous IDs at any time. If users choose to opt out, ads delivered to the App by ad serving technology will not be served on an anonymous ID.

11. Retention of Your Personal Data. We will retain your personal data only for the period necessary to fulfill the purposes outlined in this Policy. However, please note that we may need to retain certain information and not delete it or to keep this information for a certain time (e.g. for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion) in which case we will comply with your deletion request only after we have fulfilled such requirements, unless a longer retention period is required or permitted by law. When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.

12. Security of Your Personal Data. Visual Vocal is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Visual Vocal uses reasonable efforts to protect your Personal Data, Visual Vocal cannot guarantee its absolute security.

13. Sensitive Personal Data. Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.

Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Services and within the App. We will also update the “Last Updated” date at the top of this Privacy Policy. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Services or within the App. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of the Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.