Last updated October 29, 2018

Introduction

XR Association (“we“, “our“, “us“) are committed to protecting and respecting your privacy. We are a California mutual benefit corporation established in the United States with a registered office at 1 Hacker Way, Menlo Park, California 94025, and for the purpose of the General Data Protection Regulation (the “GDPR“), we are the data controller.

This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our website at https://xra.org (the “Website“). Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website.

What types of information do we collect and how do we use it?

Information you give us. You may provide information by contacting us via our Website or email, telephone, instant chat, social media, or otherwise.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our organization, we will use your information to:

  • communicate with you;
  • contact you via telephone or email;
  • identify our users;
  • personalize our services for you;
  • enforce our Website terms and conditions;
  • if you have opted in to marketing, communicate with you about products, services, promotions, events, and other news and information we think will be of interest to you; or
  • provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

Technical usage information. When you visit the Website, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:

  • your IP address;
  • device information including, but not limited to, identifier, name, and type of operating system;
  • mobile network information; and
  • standard web information, such as your browser type and the pages you access on our Website.

As it is in our legitimate interests to process your data to provide effective services and useful content to you we collect this information in order to:

  • personalize our Website to ensure content from the Website is presented in the most effective manner for you and your device;
  • monitor and analyze trends, usage, and activity in connection with our Website and services to improve the Website;
  • administer the Website, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical, and survey analysis;
  • keep the Website safe and secure; or
  • measure and understand the effectiveness of the content we serve to you and others.

We receive information from other sources, such as from the members of the XR Association. For information regarding our members’ privacy policies, please visit their websites.

Do we use cookies?

We use cookies to collect information about your browsing activities over time and across different websites following your use of our services. They allow us to recognize and count the number of users and to see how users move around the Website when they are using it. This helps us to improve the services we provide to you and the way the Website works. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.

We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site — for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

How do we share your personal data?

We do not sell, rent, or lease your personal information to others except as described in this Privacy Policy. We share your information with selected recipients. These categories of recipients include:

  • cloud storage provides located in the United States to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you; and
  • analytics and search engine providers located in the United States that assist us in the improvement and optimization of the Website.

We will share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process, or request;
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent, or otherwise address security, fraud, or technical issues; or
  • protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
  • if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

Where do we store your personal data?

The information that we collect from you will be transferred to, and stored at/processed in the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

The security of your personal data

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft, and unauthorized use, access, or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

How long do we store your personal data?

We will retain your information as follows:

  • if you contact us via email we will keep your data for twelve (12) months after; and
  • your technical usage information for twelve (12) months.

After you have terminated your use of our Website, we will store your information in an aggregated and anonymized format.

Your rights

You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.

In certain circumstances, you have the right to ask us to delete the personal data we hold about you:

  • where you believe that it is no longer necessary for us to hold your personal data;
  • where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or
  • where you believe the personal data we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:

  • where you believe the personal data we hold about you is inaccurate and while we verify accuracy;
  • where we want to erase your personal data as the processing is unlawful but you want us to continue to store it;
  • where we no longer need your personal data for the purposes of our processing but you require us to retain the data for the establishment, exercise, or defense of legal claims; or
  • where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

To exercise any of these rights above, please contact us at info@xra.org.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals, where there are overriding public interest reasons or where we are required by law to retain your personal data.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at info@xra.org and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Changes

Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact

Questions, comments, and requests regarding this policy are welcomed and should be addressed to info@xra.org.