We are committed to protecting and respecting the privacy of your personal data. This privacy notice explains how your data is collected, used, transferred and disclosed by us. It applies to data collected when you use our website and when you interact with us through social media, email, or phone.
We are registered with the Information Commissioners Office with registration number: ZA308372
WHO WE ARE
Immotion VR Limited (Company Number 10697809 of East Wing, Ground Floor, The Victoria, 150-182 The Quays, MediaCityUK, M50 3SP (referred to as “Immotion”, “we”, “us” and “our” in this privacy notice) is the controller and responsible for your personal data collected through the immotionvr.com website (the “website”).
You may contact us with questions in relation to this privacy notice, and our details are set out in the “How to Contact Us” section at the end of this notice.
OUR COMMITMENT TO YOU
We take the protection of your personal data seriously and will process your personal data fairly, lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used.
We will only collect and use your personal data (including through cookies as explained later in this notice) in order to:
• deliver the services;
• keep you up to date with our latest offers;
• help us to make our marketing more relevant to you and your interests;
• improve our services; and
• meet our legal responsibilities.
HOW WE KEEP YOUR DATA SAFE AND SECURE
We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. By this we mean that we limit the access available to your data within our business and provide appropriate training in data protection to our personnel.
The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.
We require any third party who is contracted to process your personal data on our behalf to limit their processing to that we have instructed and ensure that they treat your personal data as confidential, have security measures in place to protect your data and agree to treat such data in accordance with the law.
In the unfortunate event of a personal data breach, we will assess the situation promptly and notify you and any applicable regulator when we are legally required to do so.
Social Media: Posting Data on our Sites and Pages
Posts and comments on Social Media Platforms (and, if relevant, the Website https://immotionvr.com/) are publicly available and you should bear this in mind when you post or upload content to Our Sites (including checking your privacy settings to ensure that they reflect the level of privacy that you wish to maintain for the relevant social media account
Please note that the services we provide through the website are not intended for access and use by children under 18. If you are under that age of 18 you should ask your parent’s or legal guardian’s permission before using the Website.
The applications that we provide and the software operating within these Apps are, however, designed with data protection considerations taken into account. The services that we provide are covered by the Childrens’ Code, effective September 2021 (the “Code”) and we work to ensure that the user experience meets the standards expected of us in the Code.
THE PERSONAL DATA WE COLLECT
Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed.
While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or allow children to make bookings with us. If you are under the age of 13, you are not permitted to use or submit your data to the website.
THE FOLLOWING GROUPS OF PERSONAL DATA ARE COLLECTED
• Contact Data includes booking information such as: name, email address, billing address, location, country, telephone number.
• Financial Data includes information such as: payment card details and details of your Bank.
• Transaction Data includes information such as: details of your booking; payments to and from you and details of other booking / services you have obtained from us which are held in your account history, correspondence or communications with you in respect of your bookings, and details of any rewards and bonuses awarded where these have been offered under any marketing schemes that we operate.
• Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Profile Data includes information such as: purchases made by you, preferences, feedback, and survey responses.
• Usage Data includes information is obtained in accordance with the cookie settings you have consented to and covers: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, weblogs and other communication data; loyalty programme activities; and details of any other Immotion products and services used by you.
• Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share in anonymised form 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 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 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 notice.
HOW WE COLLECT YOUR DATA
We may collect personal data about you in the following ways:
• Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:
◦ Create an account or making bookings on our Website;
◦ Subscribe to our newsletter, discussion boards, social media sites or create wish lists;
◦ Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service);
◦ Use the “refer a friend” function on our website; or
◦ When you log in to our website via social media.
• Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies.
• Third parties – we may receive personal data about you from various third parties, including:
◦ Identity and Contact data from another individual when they purchase an e-gift card for you or use the “refer a friend” function on our website;
◦ Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’;
◦ Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
◦ Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
◦ Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
HOW WE USE YOUR DATA
We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it and, where required by law, to provide the data to a third party.
We will only collect personal data from you when:
• we have your consent to do so, or
• we need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or
• the processing is in our legitimate interests and not overridden by your rights, or
• we have a legal obligation to collect or disclose personal data from you.
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 or the processing undertaken is otherwise permitted by law. If we wish 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.
If you have any questions about how Immotion uses any of your personal data, please contact firstname.lastname@example.org.
How long we keep your data for
We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.
MARKETING PREFERENCES, ADVERTS AND COOKIES
We may send you marketing communications and promotional offers:
• if you have opened an account with us or made bookings with us, or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below); and
• by email if you have signed up for email newsletters.
We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data and Marketing and Communications Data to form a view on what we think you may like, or what may be of interest to you, and to send you details of offers which may be relevant for you.
We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS and other communication channels.
From time to time we may also include with your order, inserts advertising goods, services or offers from other third-party companies that you may be interested in. In respect of third party marketing communications, we will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time you can unsubscribe or ‘opt-out’ by sending an email to email@example.com or by following the link included in the footer of any marketing email. We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.
Cookies are text files containing small amounts of information which allow our site to recognise your device and are downloaded to your device when you visit a website if you agree to the site doing so. Cookies are then sent back to the website on each subsequent visit, or to another website that recognises that cookie.
Cookies allow a website to recognise a user’s device and are widely used in order to either make websites, work more efficiently, let you navigate between pages, and generally improve your user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
Cookies do not contain confidential information such as your home address, telephone number or credit card details. We do not exchange cookies with any third party websites.
If you don’t change your browser settings and continue to use our site, we will assume that you consent to us continuing to download cookies onto your device.
Whether or not you allow us to download cookies is up to you, but if you choose to disable cookies by changing your Browser Settings, our Website and its features may not necessarily work in the same way or produce the same personalised experience. If you delete all of your cookies, you will have to update your preferences with us again. If you use a different device, computer profile or browser you will have to tell us your preferences again.
Our use of analytics and targeted advertising tools
We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyse Google’s interest-based advertising data and/or third-party audience data (such as age, marital status, life event, gender and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook, Content Square, Adroll, Responsys, Criteo and Bing to perform similar tasks, using your Contact, Technical, Usage and Profile Data.
In order to opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings or opt-out of the relevant third-party ad settings. If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us.
Links to websites and other third parties
Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.
HOW WE SHARE YOUR DATA
We may disclose and share your personal data with the parties set out below:
• where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties’ (including co-branded or jointly promoted) products and services, in giving your consent you agree that we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications;
• to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business for the purposes set out above in the section ‘How we use your data’, such as:
◦ third party service providers that we engage to provide IT systems and software, and to host our website;
◦ services and to provide marketing and advertising services;
◦ MailChimp and any other third party service providers that we engage to send emails and postal mail on our behalf including in relation to incomplete orders, or marketing communications, to provide data cleansing services and to provide marketing and advertising services;
◦ analytics and search engine providers that assist us in the improvement and optimisation of our website;
◦ affiliate networks through whom you have accessed our website;
• to any third party 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 notice;
• to protect our customers from fraud and theft, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with third party organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• to our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Keeping Your Data Up to Date
Please help us to ensure that any Personal Information you provide us with is up to date and accurate. If your Personal Information changes, you can let us know by updating the details through your account on our Website or contacting our Customer Service Team.
You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:
• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• request restriction of processing of your personal data;
• request the transfer of your personal data;
• object to processing of your personal data; and
• request human intervention for automated decision making.
Brief details of each of these rights are set out below. If you wish to exercise any of these rights, please email firstname.lastname@example.org. We will endeavour to respond as soon as possible and within one month in any event unless we have an appropriate reason to extend this date and advise before expiry of the initial deadline.
For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
REQUEST ACCESS TO YOUR PERSONAL DATA
You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.
REQUEST CORRECTION OF YOUR PERSONAL DATA
You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by emailing email@example.com.
REQUEST ERASURE OF YOUR PERSONAL DATA
This enables you to request that Immotion delete your personal data. 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.
REQUEST RESTRICTION OF PROCESSING OF YOUR PERSONAL DATA
You have a right to ask Immotion to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future.
REQUEST THE TRANSFER OF YOUR PERSONAL DATA
You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.
OBJECT TO PROCESSING OF YOUR PERSONAL DATA
You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it. You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
RIGHT TO LODGE A COMPLAINT
If you have any concerns or complaints regarding the way in which we process your data, please email firstname.lastname@example.org. You also have the right to make a complaint to the ICO (the data protection regulator in the UK). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance.
Should you wish to contact ICO with any concerns, the contact details are as follows can be found at www.ico.org.uk.
CHANGES TO THIS PRIVACY NOTICE
From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.
HOW TO CONTACT US
Please send any questions, comments or requests for more information to our nominated representative – email@example.com.
This privacy notice was last updated on 29 March 2021(version 003).