VRHealth – Privacy Policy

XRHealth Privacy Policy

Last Revised: December 11, 2018

XRHealth Ltd., (“Company”, “we” or “XRHealth”) respects the privacy of the users of its Services (“User” or “you”) and is committed to protect the User’s information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our terms of use available at: https://dev.xr.health/vrhealth-terms-of-use/ (“TOU“), into which this Privacy Policy is incorporated thereto by reference.

1.        Your consent (important, please read carefully!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE PROPERTIES AND/OR BY CLICKING THE “I AGREE” BUTTON WHEN SETTING YOUR ACCOUNT, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

PLEASE NOTE: IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ENTER TO, CONNECT TO, ACCESS OR USE THE PROPERTIES IN ANY MANNER, DO NOT INSTALL THE APP AND/OR PROMPTLY UNINSTALL THE APP FROM YOUR MOBILE DEVICE

2.        Which information we may collect on our Users?

We may collect two types of data and information from our Users:

  • The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us when such User installs and/or uses our Properties. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Properties, type of operating system, device type, User’s ‘click-stream’ on the Properties, keyboard language, screen resolution, time spent on various screens of the Properties, etc. We also use third-party service providers such as Mixpanel and Google Analytics to obtain detailed analytics on the User’s behavior on the Properties.
  • The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
    • We gather the Users’ IP address (or Mac Address, as applicable) mainly to detect anomalies for enhancing the User’s experience and security purposes (i.e., in order to safeguard our Properties).
    • In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User:
      • Personal Information is collected from the details the Users provide when opening an Account via the registration form available on the Site, which include, inter alia, the User’s name, email address, password, phone number, gender, date of birth and address. Additional information may be requested in the future.
      • Personal Information is included in the Reports and collected when you use the Service (i.e., when you wear the Oculus Go headset, we are aware of your movements).
      • You may sign-up to the Properties by providing a cell phone number and receiving a verification code you will be required to enter in order to start filling the play card. Alternatively, you may sign-up to the Properties via one of your existing Third-Party Services accounts (e.g. Google+, LinkedIn, Facebook, Instagram etc.). When you sing-up to the Properties through such existing third-party account, then such third-party accounts provide us with access to certain information, which is detailed and displayed to you in the notice which appears during the integration process, which may include your name, email address, profile photo and user-id on such account. Please read carefully such notice in order to understand what information is made available to us via your third-party accounts. We may collect your login information and other relevant information necessary to enable us to access your third-party accounts in order to collect the above mentioned information. We may store the above-mentioned information (or any part of it), in order to achieve the purposes, set forth herein. Please remember that the manner in which third-party accounts use, store or disclose your information is governed solely by their policies and we will have no liability or responsibility for the privacy practices or other actions of such third parties. If you do not agree to these practices, please do not use third-party accounts in order to use our Properties. You hereby agree that such information will be stored even after the linkage to your third-party accounts expires, for any reason.
      • Personal Information is collected from the details the Users of the Properties provide in the Contact Form which includes, inter alia, full name, e-mail address and phone number. You may optionally provide via the Contact Form any text you wish to insert into the “message box”. Our representative may collect additional Personal Information from you.
      • Users will have the option to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see Section 6 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with (and where applicable, the last four digits of your credit card number), and such information is strictly secured.
      • You may use the “Work with us” page available on our Site in order to apply for a position at VRHealth and send us your CV, and in such case, we will collect all Personal Information which is included in the applicable form on the ” Work with us” page, and any Personal Information included in your CV. Note that such Personal Information may be accessed by our HR department and/or by VRHealth managers, worldwide, solely for the purposes of evaluation and to enable us to contact you with respect to the recruitment process. If you submit an application on behalf of a third party, you hereby acknowledge that such third-party was made aware of this Privacy Policy and has granted his/her consent to the processing of his/her Personal Information by VRHealth. Personal Information collected via the “Work with us” page may be retained for future consideration by VRHealth (e.g. future positions at VRHealth).
      • Personal Information may be collected from the details the User may provide us while contacting us via the support e-mail available on the Properties or by sending us an email.

For avoidance of doubt, any Non-Personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of the TOU and the Privacy Policy.

3.        How Do We Collect Information on our Users?

There are two main methods that we use:

  • We collect information through your entry, connection, access and/or use of the Properties. In other words, when you are using the Properties, we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above and your IP address), either independently or through the help of our authorized third-party service providers as detailed below.
  • We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account or when you contact us via the Site.

4.        What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:  

  • Use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services.
  • Enhance the User’s experience while using the Services.

Personal Information is collected in order to:

  • Operate the Services (including sending receipts to Users, etc.).
  • To verify the User’s identity when he/she signs in to the Properties.
  • Personalize and enhance the Users experience while using the Properties.
  • Respond to your inquiry.
  • Provide the Users with commercial materials, updates about VRHealth’s developments, new offerings, news regarding the Services and other services/products that may be of an interest to you, etc.
  • Enable payment through third party Online Payment Processors. Please note that we do not collect and store credit card or other financial information.
  • Be able to contact Users for marketing purposes and provide them with technical assistance.
  • Enable the User to use social features.
  • Keep the Properties safe and secured and for prevention of fraud and crime.

5.        Sharing Information with Third Parties

VRHealth will not share any Personal Information it collects with any third party, other than in the extreme circumstances as follows: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of the Company, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure. Note, that we collect, hold and/or manage your Personal Information through VRHealth’s authorized third parties’ vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.  Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.   

For avoidance of doubt, VRHealth may transfer and disclose Non-Personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Properties.

6.        Payment

We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. VRHealth is not affiliated with such Online Payment Processors (for more information see our TOU), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

7.        Third Party Service Providers

While using the Properties we may be using third party service providers, who may collect, store and/or process the information detailed herein. VRHealth uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such software may include without limitation:

Please read such third-party service providers’ terms of use and privacy policies to understand their privacy practices.

8.        Minors

The Properties is intended for Users over the age of thirteen (13). Therefore, VRHealth does not intend and does not knowingly collect directly Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Site and/or Platform.

9.        Direct Marketing

You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services. You may withdraw your consent by sending a written notice to VRHealth’s e-mail address that appears in the Properties or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

10.     Cookies & Local Storage

When you access or use the Properties, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on your device (“Local Storage“) which may enable us, inter alia, to recognize your device from those of other Users of the Properties, to improve the Service’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the Properties, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, and to estimate our audience size and usage pattern and perform other analytics.

Such information is locally stored in the User’s device. VRHealth and/or our authorized third party service providers may access such information. VRHealth and/or our authorized third party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Properties may store non-personal information (such as the different pages viewed by a User within the Properties) as well as User persistent identifier, which will be collected in accordance with the terms specified herein.

Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Site may be limited. Please note that unless you block the acceptance of cookies, the Site will utilize cookies upon your use of the Properties. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Site from placing further cookies on your device unless and until you adjust your settings as described above.  For detailed instructions regarding the blocking of cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

Please note that VRHealth uses Mixpanel as a service provider in order to track Users’ activities on the Properties, including by use Mixpanels’ persistent cookies. You may opt-out of Mixpanel’s tracking by following the instructions on the following link: https://mixpanel.com/optout/. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

11.     Deletion or Modification of Personal Information

Your data is yours. If for any reason you wish to delete, access or modify your Personal Information you can do so within the App. In the event that you wish to cancel your Account you may close your Account using the settings or you can send us an e-mail of your request to: Privacy@vrhealthgroup.com, and we will close your Account and delete any Personal Information therein pursuant to any applicable privacy laws. In the event that you wish to modify or delete the Personal Information you provided us via the Properties you can send us an e-mail of your request to: Privacy@vrhealthgroup.com, and we will modify or delete your Personal Information pursuant to any applicable privacy laws. We will retain and use your Personal Information for a reasonable time after termination as necessary to comply with our legal or business requirements or obligations (including as required by applicable law), to resolve disputes, to enforce our Terms and/or to enable the User to reinstate his/her Account. Aggregate and/or anonymous data derived from your Account information or from your use of the Properties may remain on VRHealth servers indefinitely. Note that unless you instruct us otherwise we may retain your Personal Information for as long as required to provide you the Properties and related services, all as permitted under any applicable privacy laws.

12.     Security

We take reasonable measures to maintain the security and integrity of our Properties and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The User Information is hosted on the Microsoft Azure Cloud servers which provide advanced strict security standards (both physical and logical). In addition, we employ highly secure services design and implementation using state of the art encryption and architectures mechanisms. Furthermore, we implement a secure permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.  Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. VRHEALTH SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA.    

13.     Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Properties and any information collected therein. VRHealth reserves the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Platform on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

14.     Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: Privacy@vrhealthgroup.com, and we will make an effort to reply within a reasonable timeframe.