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Privacy Policy

Date: August 14, 2022

Iconic Engine, Inc., (“Company,” “we,” “us,” or “our”) a Delaware corporation, welcomes you to VASOO, our metaverse destination. We have some wonderful experiences in store for you, but first you should know how we handle your privacy when you access and use VASOO and its interface, software, content, functionality, and services (collectively, the “Services”).  This privacy policy describes how we collect, use, and safeguard your personal information as well as your rights to correct or delete that information. It applies to the personal information that we collect:
• On our website https://www.myvasoo.com/
• When you download the VASOO app
• When you access and use VASOO and its Services; and
• Through our service providers. 

This privacy policy does not apply to personal information that we might collect outside of VASOO, for example, when you contact Iconic Engine by email. 

1. What information do we collect?
Personal information is “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” California Consumer Privacy Act § 1798.140(o)(1).

Here are the categories of Personal Information that we collect (some categories overlap):
• Identifiers: Your email address, screen name, IP address, and unique device identifier on your device (e.g. , IDFV for iOS devices and Android ID for Android devices, Oculus Quest 1 & Quest 2) 
• Commercial information:  We collect information on the items and Interactive Services you purchase through the VASOO Store.
• Voice data: We receive your voice data through your microphone. We do not store this information.
• Interactions within VASOO’s environments: We retain and evaluate information about how you move around different sections of VASOO for analytics purposes to understand how people use VASOO so that we can make it more intuitive.
• Geolocation information: The real-time location of your device.
• Information about Your Device:  Your device's unique device identifier, IP address, manufacturer, model platform, operating system and version of OS, and geolocation.
• Country of install: The country from which you download VASOO.
• Anonymized information:  We may collect anonymous information that is associated with your account.  We reserve the right to use this information for any permissible business purpose under applicable law.  

2. How do we collect your Personal Information?
We collect Personal information from you directly when you:
• Register online by providing your email address and VASOO Screen Name.
• Purchase an item or Interactive Service through the VASOO Store.
• Use your VASOO Screen Name to locate other users.

We also automatically collect Personal Information indirectly through you and Third-Party Services when you:
• Download VASOO.
• Access and use VASOO and its Services.

Third-Party Services
We use these Third-Party Services to provide functionality to VASOO:
• Amazon Web Services, used for application program interface (API), and server backends/databases. 
• Amplitude, used for analytics to improve user experience.
• Photon, enable VASOO users to interact with each other. 
• Unity Vivox, provides Voice Over Internet Protocol (VOIP) services so that users can speak to each other within VASOO. 
• YouTube API Services, enables users to search for and display YouTube content within VASOO. Your use of YouTube is governed by https://www.youtube.com/t/terms and Google’s Privacy Policy at http://www.google.com/policies/privacy.

We do not sell any contact or analytics to any third party. Analytics we receive from and share with Third-Party Services has been anonymized. 

3. How will we use your Personal Information?
We use your personal information to:
• Improve your experience on VASOO through analytics.
• Recognize you when you use VASOO.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Give you notices about your account.
• To send you notifications about VASOO such as upgrades, new features, promotions, or events. You may opt out receiving these notifications. 

We also may disclose your Personal Information:
• If you have consented to such a disclosure.
• In furtherance of legal, health, and safety, and other matters in the public interest.  
• If legally compelled to do so such as in response to a subpoena, search warrant, court order, or other legal process. 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our user, or others; and
• To our Third-Party Services for:
   • Analytics,
   • Hosting and backend infrastructure, and
   • Handling payments in the VASOO Store.

4. How do we store your Personal Information?
We store your Personal Information on servers in the State of Oregon and in Frankfurt, Germany. 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. If you have registered a VASOO account and chosen password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

We retain the Personal Information that we collect from you where we have an ongoing legitimate business need to do so. For example, we retain Personal Information in order to continue to provide you access to and use of VASOO and its Services and to communicate with you.  You may request that we deactivate your account or delete your personal information by contacting us at support@myvasoo.com.  Although we will no longer process Personal Information if we receive such a request, we will securely store your Personal information for as long as we deem it reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5. How does VASOO Use tracking technologies?
We use a token id to maintain your log-in status. 

When you use VASOO or its content, certain Third-Party Services may use automatic information collection technologies to collect information about you or your device (see list of our current Third-Party Services above). Third-Party Services may use tracking technologies to collect information about you when you use VASOO. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services websites. We do not control these Third-Party Service tracking technologies or how they may be used. 

6. What are your data protection rights?
We would like to make sure you are fully aware of all of your data protection rights.  These rights may differ by age, region, state and country.

Children’s Privacy Rights
• VASOO is not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If we learn we have collected Personal Information from a child under 13, we will delete that information and the user account.  If you believe we might have any Personal Information from or about a child under 13, please contact us at legal@iconicengine.com.  We may require parents and guardians to provide additional information to verify their identity before we provide any information or make corrections.  This information will be kept confidential.

California Consumer Privacy Act Disclosure
Residents of California have the right to:
• Know what personal information we collect about you and from where we collect it
• Access a copy of the personal information we hold about you.
• Understand how we process your personal information and how it may be shared.
• Opt out of having your personal information shared with certain third parties.
• Request we delete your VASOO account and personal information.
To make such a request, please send an email to legal@iconicengine.com

European Union - General Data Protection Regulation (GDPR)
You have the following data privacy rights:
• The right to access - You have the right to request copies of your personal data from Our Company.  We may charge you a small fee for this service.
• The right to rectification - You have the right to request that Our Company corrects any information you believe is inaccurate. You also have the right to request that Our Company completes information that you believe is incomplete. 
• The right to erasure - You have the right to request that Our Company erases your personal data, under certain conditions.
• The right to restrict processing - You have the right to request that Our Company restricts the processing of your personal data, under certain conditions.
• The right to object to processing - You have the right to object to Our Company’s processing of your personal data, under certain conditions.
• The right to data portability - You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you.  If you would like to exercise any of these rights, please contact us by email at legal@iconicengine.com.  

7. Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users' Personal Information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

8. Contact Information
Iconic Engine, Inc. makes decisions about how your information will be used.  Our contact information is: Iconic Engine, Inc., Attn: VASOO Privacy, 154 Bell Canyon Road, Bell Canyon, CA 91307

To ask questions or comment about this privacy policy and our privacy practices, contact our Data Protection Officer at: legal@iconicengine.com

For all support inquiries, please contact support@myvasoo.com