Liminal Privacy Policy

1. Introduction

Last updated: 13 December 2018

This Privacy Policy is brought to you (“you”, “your”) by Liminal VR Pty Ltd (“Liminal“, “we“, “us“).

The scope of activities conducted by Liminal are wide-ranging, but include:

(a) the development of software, including virtual reality, mixed reality, augmented reality, audiovisual and other content, data and behavioural analytics, and web, mobile and desktop applications;
(b) research activities, including scientific experiments, clinical research, behavioural research, emotional and cognitive research, psychometric, biometric and neurometric research, and the facilitation of surveys or questionnaires;
(c) the provision of educational materials and services in relation to all of the above.

For the purposes of this Privacy Policy, these are referred to as “Activities”.
Our primary Services include:

(a) products and services commissioned by Liminal’s clients (see www.liminal360.com); and
(b) the Liminal Platform and Liminal Partnership Program (see www.liminalvr.com and www.liminal.app).

This Privacy Policy explains how we treat information in relation to our users, including how we collect, use, store and share information in connection with our Services or Activities.

By using our Services or participating in our Activities, you consent to us collecting, using, storing and sharing information in connection with our Services or Activities.

While personal information and data is never 100% safe, we will use our best efforts to protect your privacy and act in accordance with this Privacy Policy. If we knowingly collect, use, store or share information in a manner that is not contemplated by this Privacy Policy, we will inform you about these activities and seek your permission before we proceed.

2. Changes to this Policy

Liminal will change this policy from time to time. If changes are significant, we’ll send you an email notification to the address that you’ve provided or provide a notice through the Services.

3. What kind of information do we collect?

Depending on which Services you use or Activities you participate in, we must process different kinds of information from or about you. This information includes:

3.1 Information you (and others) give us.

We collect the information that you (and others) give us when using our Services or participating in these Activities. This includes, for example:

(a) When you register for our Services (including setting up a user account) or participate in research activities, you may be asked to provide certain information. Depending on the Services or Activity in question, this might include your name, date of birth, gender, education level, location, address, email address, phone number, demographic information or other information about you.
(b) After you register for our Services, you may add information to your profile or account after registration. You may be required to do so in order to access certain features on our Services.
(c) If you buy something on or through our Services, you may be required to provide us with information for the purposes of entering into a transaction with us. This can include payment method details, purchase activity, delivery address and contact details.
(d) When you use our Services, we may collect information from you about how you engage with or respond to content and experiences on our Services.
(e) We may collect information you post, share or communicate with us or information provided by other users on our Services.
(f) Depending on which Services you use, you may submit information about your reactions, responses or feedback in relation to particular content or experiences. For the purposes of the Liminal Platform, this includes psychometrics, enjoyability ratings and information collected as whenever you use experiences, or in response to experiments conducted on the Liminal Platform.
(g) We may collect information about content that you create or provide using our Services, which may include your avatar, a picture you post or an experience you create.
(h) If you are a Liminal Partner, we may collect information about you to give you attribution for experiences you create for inclusion in the Liminal Platform.
(i) We may collect any information you voluntarily provide to us.

3.2 Information automatically collected about you when you use our services.

We may collect information automatically when you use our Services or participate in our Activities. Depending on how you access and use our Services or the nature of the Activities you participate in, this information may include:

(a) Information about your interactions with our Services, such as information about the content, features or other experiences you interact with;
(b) Data and behavioural analytics about your use of the Service or participation in the Activities;
(c) Information collected in or through cookies, device IDs, pixel tags, local storage (such as browser web storage or application data caches), databases, server logs and other technologies;
(d) Information about how you access our Services, including information about the type of hardware or device that you’re using, its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, location-related information and how your device is performing;
(e) Certain identifiers that may be unique to you, including identifiers relating to your device or accounts with any distribution platform which is hosting our Services;
(f) Information about the experiences and features you use through our Services;
(g) Information about your environment, physical movements and dimensions when you use a device; and
(h) Information we receive through or as a result of device settings or settings on our Services that you choose.

Whenever you post, share or communicate with us or other users on our Services, we receive and store those communications and information associated with them, such as the date a post was created.

3.3 We may collect certain information about you from Third parties in certain limited situations.

Depending on which Services you use or Activities you participate in, we may receive information about you from third parties, including:

(a) Related companies. This includes other companies that are within the family of related companies that are legally part of the same group of companies that Liminal is or will become part of in the future.
(b) Clients or joint venture partners. We may receive information about you from clients or our joint venture partners in order to deliver projects to them, or in conjunction with them. For example, if we deliver a product to a client which requires that a user account is set up for you.
(c) Information from other sources. We may receive information about you from third parties, including partners that provide us with information that is publicly or commercially available, and may combine that information with the other information that we collect about you.
For the purposes of the Liminal Platform, if you have a user account set up for you as part of an enterprise licence, we may collect information necessary to set up that user account from the third party setting up the user account. Enterprise licence holders might include, for example, your employer, school, university, college, hospital, clinic, health professional, service provider, or any other organisation setting up the user account for you as part of the enterprise licence.
We may combine information collected from third parties with other information that we collect about you.

4. How do we use information?

4.1 To provide and personalise our Services.

We use the information that we collect to provide you with our Services. For example, we use this information to:

(a) provide you with content, applications and other experiences;
(b) create accounts and user profiles;
(c) process financial transactions with you;
(d) communicate with you about our Services, for example, to notify you about updates to our Services;
(e) provide technical support in relation to our Services, for example, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services; and
(f) customise your experience and deliver personalised information or data to you to make your experience unique and relevant to you. In the case of the Liminal Platform, this includes data relating to psychometric and enjoyability ratings that you enter while using the Liminal Platform.

4.2 To improve and develop your experience and our Services.

We also use the information that we collect to understand and improve our Services. For example, we use the information to:

(a) solicit and analyse input and feedback about our Services;
(b) identify and address technical issues on our Services;
(c) conduct and learn from research about the ways in which people use our Services;
(d) understand the emotional, cognitive, psychological, behavioural or other effects of content on our Services;
(e) for the purposes of the Liminal Platform, to rank experiences in order of effectiveness and enjoyability.

4.3 To conduct research activities
We may use information that we collect from you for research activities, in which case, we will make that clear to you at the time of collecting the information.

4.4 To market, promote and drive engagement with the Services and Activities.

We may use the information that we collect from you in order to:

(a) send you promotional messages and content and to otherwise market to you on matters that we think may be of specific interest to you on and off our Services; and
(b) to evaluate how users respond to our marketing efforts.

Psychometric information on the Liminal Platform personally identifiable to you will not be used for marketing purposes.

4.5 To promote safety and security.

We may use information that we collect to help promote safety and security on and off our Services. For example, we may investigate suspicious activity or breaches of our terms or policies and protecting our or others’ rights or property.

4.6 To protect our legitimate business and commercial interests

We may use information that we collect to protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

5. How is information shared?

To provide and support our Services and Activities, information that we have about you is shared in certain circumstances.

5.1 Public information

Information that you post to public areas of our Services, such as a forum, blog or other community tool, or a developer profile on the Liminal Platform (if you are a Liminal Partner), will be visible to people on and off our Services. Certain information associated with your public posts, such as the time of your post, may also be published and publicly available.

This content may be published by third parties using our Services.

5.2 Related companies

Depending on which Services you use or Activities you participate in, we may share information with other companies that are within the family of related companies that are legally part of the same group of companies that Liminal is or will become part of in the future.

5.3 Clients

If a client has commissioned us to develop or deliver a product or service for them, and we collect information about you as part of that product or service, we may share information about you with our client.

5.4 Service providers

We may share the information that we collect with third party vendors, service providers, researchers and other partners, who work at our direction or provide tools or software that we use to support the Services or Activities. Some examples include third party providers that:

(a) host our Services;
(b) fulfil orders or facilitating payments (eg. credit card payments);
(c) collect or analyse data relating to our Service, including the way people use our Service;
(d) provide customer service or sending electronic communications for or on behalf of us;
(e) provide software development or other support for the Services or Activities; or
(f) provide professional advice to us.

5.5 Distribution platforms

We may share certain information with distribution platforms (such as the Oculus Store, Daydream Store, Microsoft Store, Viveport or other platforms) in order to provide the Services or conduct the Activities.

5.6 Other parties in connection with certain business transactions.

Certain information about you may be transferred to another company in the event that the ownership or custodianship of Liminal, our related companies, or any portion of our assets, change as a result of a merger, acquisition or in the event of a bankruptcy.

5.7 Permission.

We may share information about you in accordance with any permission you have given us.

5.8 Law enforcement or legal requests.

We may share information with law enforcement or in response to legal requests (eg. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so.

5.9 De-Identified and Aggregated Information

We may share de-identified or aggregate data with third parties. De-identified data means information where we have removed your name and other data that could reasonably be used to identify you. Aggregate data is data that has been combined with other data so that it doesn’t identify any specific person.

5.10 Sharing De-Identified and Aggregated Psychometric Data on Liminal Platform

In respect of the Liminal Platform, we provide third parties with aggregated and de-identified data (including psychometric data) and statistics in relation to experiences on the Liminal Platform. These third parties include other users, Liminal Partners, enterprise licence holders, clients, researchers, and others.

We do not provide psychometric data about any individual to third parties.

5.11 Sharing of Information for marketing purposes

Some of the marketing on our Services may be provided by third parties that are not affiliated with us.

These third parties may collect information on or through our Services to market to you on or off our Services. These and other third parties may collect information about your use of our Services, including through the use of cookies, device IDs, pixel tags, local storage (such as browser web storage or application data caches), databases, server logs and other technologies, and this information may be collected over time and combined with information collected on different websites and online services.

In respect of the Liminal Platform, psychometric data personally identifiable to you will not be made available to third parties for marketing purposes.

6. How we store and secure information we collect

6.1 Information storage and security

We use data hosting service providers to host the information we collect. Your information may be transferred or transmitted to, or stored and processed on servers in jurisdictions outside of where you live.

While we use technical measures and implement safeguards designed to secure your data and protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

6.2 How long we keep information

How long we keep information we collect about you is a case by case determination which depends on the type of information and the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

(a) Account information. We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
(b) Managed accounts. If the Services are made available to you through an organization (e.g. your employer) under an enterprise licence, we retain your information as long as required by the administrator of your account.
(c) Marketing information. If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information.
(d) Purchase Information. We may retain certain purchase information for accounting and tax purposes even after you have deleted your account.

6.3 Deletion of account

When you delete your account, we will delete information relating to that account that is no longer necessary for us to retain, including things you have posted, certain data and entitlements. You will not be able to recover that information later.

7. How to access and control your information

You have certain choices available to you when it comes to your information.
You have the right to request a copy of your information in a structured, electronic format. We will do our best to provide a copy of your information upon request within a reasonable time.
You also have the right to object to our use of your information or data (including for marketing purposes), to request the deletion or restriction of your information or data.
We do not currently have the infrastructure, tools or resources available to us to respond to any specific objections you may communicate to us about our use of your information or any requests to delete or restrict information. If you have any concerns about any information we hold about you, we recommend that you delete your account.

8. Contacting us

If you have questions about this Privacy Policy, please contact us at privacy@liminalvr.com.