# PRIVACY POLICY

# This Privacy Policy applies to the Products and the Website.

# Last Updated: December 10th, 2020

OTS EVENTS, L.P., an affiliate of Jamestown L.P., offers virtual reality (“VR”) software products and operates a platform where users can download, interact with, and submit content and obtain services related to or in connection with our Virtual New Years Eve experience (collectively, the “Products”). We describe our Products including our websites, mobile apps, platform, content, hardware, services, and any product or service that links to this Privacy Policy—in our Terms of Service (opens new window). This Privacy Policy explains how we treat information from or about you, including how we collect, use, and share information on our Products.

What kind of information do we collect?
How do we use information?
How is information shared?
Third Parties that Provide Content, Marketing, or Functionality
Cookies and Other Tracking Technology
How do we respond to legal requests and prevent harm?
Privacy Notice for California Residents
Security
How will we notify you of changes to this policy?
Contacting Us

# 1. What kind of information do we collect?

Depending on which Products you use, we must process different kinds of personal information from or about you. Personal information is information that can be used to identify you, either alone or in combination with other information. The personal information collected through the Products include:

Information Automatically Collected. We collect information automatically when you are connected to the Products. Depending on how you access and use Products, we collect information such as:

a) Information about your interactions with Products, like information about the people, content, apps, features, or other experiences you interact with, including information collected through or from content provided by our third-party partners;
b) Information collected in or through cookies, local storage, pixels, and similar technologies (additional information about these technologies is available below in the section titled Cookies and Other Tracking Technologies);
c) Information about how you access our Products, including information about the type of device you're using (such as a computer, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing;
d) Information about the features you interact with on the Products. For example, we receive information about your Products usage, such as interactions with recommended pages, which browser features you use, crash reporting data, and other statistics related to your Products usage;
e) Certain identifiers that are unique to you. These identifiers include device and other identifiers, such as those from games and apps you use;
f) Information about the content or other apps installed on your device or provided through the Products, including from third parties;
g) Location-related information, which can be derived from information such as your device’s IP address. If you’re using a mobile device, some of our Products collect information about the device’s precise location, which is derived from sources such as the device’s GPS signal and information about nearby Wi-Fi networks and cell towers;
h) Information about your environment, physical movements, and dimensions when you use the VR experience;
i) Information we receive through device settings you choose, such as your photos or audio content; and
j) Technical system information such as crash logs which may contain your user ID, device ID, IP address, local computer file path, feature quality, amount of time it takes to load a feature, and whether you use a certain feature.

Information You (and others) Provide. We collect the information you (and others) give us when using Products. For example:

a) When you register to use Products, we ask for information such as your name, email address, date of birth and phone number.
b) If you add information to your profile after registration.
c) If you buy something on or through our Products, we collect information about the transaction, including your payment information, purchase activity, and shipping and contact details.
d) We collect information about the people, content, and experiences you connect to and how you interact with them across our Products.
e) When you post, share or communicate with us or other Products users on our Products, we receive and store those communications and information associated with them, such as the date a post was created.
f) When you communicate with us, you provide us with information like your email address and location.
g) Depending on which Products services you use, you have the option of submitting information about your physical features and dimensions, and creating an avatar
h) We collect content you create using Products, such as your avatar or a picture you post, such as the date and time you created the content.
i) We also collect content and information that other people provide when they use Products. This can include information about you, like when they send us an abuse report that refers to or contains video of you.

Information From Third Parties. We also receive information about you from third parties, including third-party apps, developers, other online content providers, and marketing partners that provide us information.

# 2. How do we use information?

We use personal information as set out below and to provide our Products to you and our partners for the following purposes:

To provide and personalize our Products. We use the information we collect to provide you with our Products. For example, we use this information to:

a) Provide you with content, apps, and other experiences;
b) Create accounts and user profiles;
c) Communicate with you about our Products;
d) Enable user-to-user communications and other related services;
e) Provide technical support;
f) Notify you about updates to our Products; and
g) Customize your experiences on our Products based on your activities, including the content, activities, apps, and other experiences you interact with, the other online services you use, and other information we collect. This allows us to make your experience unique and relevant to you, for example by showing you content that is most relevant to you.

To improve and develop your experience and our Products. We also use the information we collect to understand and improve our Products and to develop the VR ecosystem. For example, we use the information to:

a) Solicit and analyze input and feedback about our Products;
b) Identify and address technical issues on our Products;
c) Conduct and learn from research about the ways in which people use our Products;
d) Improve services offered by others, such as third parties that offer content, activities, apps and other experiences on our Products; and
e) Improve and develop our features.

To communicate with you. We use the information we collect to respond to your inquiries, provide customer services, send you updates about events and your account, and otherwise as needed to manage and administer your use of the Products.
To market to you. We use the information we collect to send you promotional messages and content about Products and related experiences on and off our Products. We also use this information to measure how users respond to our marketing efforts. If you would like to opt out of receiving marketing emails, please click the unsubscribe link at the bottom of any of our email messages to you.

a) Portions of our Products include sponsored, third-party content, experiences, offers, or links. If you engage with third-party content, your information may be used by those third parties for their own marketing and advertising, subject to the terms and conditions of the third party content provider.

To promote safety, integrity and security. We use the information we collect to verify accounts and activity, combat harmful conduct, detect and prevent bad experiences, maintain the integrity of our Products, and promote safety and security on and off our Products. For example, we use information collected to investigate suspicious activity or violations of our terms or policies, detect when someone needs help, and protect our or others’ rights or property.

# 3. How is information shared?

Our Products help you engage with the VR ecosystem and others that interact with it. To provide and support our Products, information we have about you is shared in certain circumstances. Here is who can see information about you when you and others use our Products.

People and accounts you share and communicate with on our Products. When you share, interact, and communicate using our Products, you choose the audience for what you share. For example, when you share a photo or other content in a public virtual space, other people who visit the space may be able to see it.
Public Information. Certain information you post to your Products profile, such as your ID (also known as your Username), and avatar, will be public and visible to people on and off our Products. Your ID is a unique identifier you choose to identify yourself on our Products. Information you post to public areas of our Products, such as a forum, blog, or other community tool, will also be visible to people on and off our Products. If you post information to these interactive features, it will be publicly available. Certain information associated with your public posts, such as the time of your post, also will be published and publicly available.
Content others share about you. You should consider who you choose to share with, because people who are able to see your activity, content, or information on our Products may choose to share it with others on and off our Products. For example, when you interact with others in the VR experience, another user could choose to livestream that experience – including what you are doing in the game on another platform. People may also use Products to share content about you they have obtained from other sources.
Apps, Developers, and Other Online Content Providers on our Products. You can interact with third-party content, activities, apps, and other experiences through our Products. We share information about you with these partners, so they can provide you with the experiences you've requested, such as:

a) Information in your profile and about how you use our Products.
b) Information about your interaction with the third-party service, such as how long you have interacted with content.
c) Any other information you choose to share with the third party.

Third-party content providers may also collect information from you directly through the experiences they provide. Please note that any information you share with these (or other) third parties will be subject to those third parties’ own privacy policies, not this one.

Information collected by third-party content providers may be shared or transferred to us as well. For example, if you click on a sponsored advertisement in our Products and make a purchase through the third party, the third party may provide us information regarding the overall number of purchases made, the locations of the purchasers, and in some cases, personal information about the purchasers.
5. Service providers. We share the information we collect with vendors, service providers, and other partners, who work at our direction to support the Products (such as hosting our Products, fulfilling orders, facilitating payments, analyzing the way people use our Products, processing credit card payments, providing customer service, or sending electronic communications for us). For example, we utilize a service provider to develop and maintain the Products.
6. Other parties in connection with certain business transactions. In the event that our ownership (or any portion of our assets) changes as a result of a merger, acquisition, or in the event of a bankruptcy, information from or about you or your device will be transferred to another company.
7. Permission. We share your information for any other purpose you choose. If you choose to share, stream, upload, or post your experience or information from our Products on a third party platform, the information and content will be managed according to the privacy policy and terms of use of the third party platform. Please take caution when sharing your information and content. Once shared, you may not be able to remove or edit the information.
8. Law enforcement or legal requests. We share information with law enforcement or in response to legal requests in the circumstances outlined in Section 6 below.

We also share de-identified or aggregate data with others. 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.

# 4. Third Parties that Provide Content, Marketing, or Functionality

Some of the platform, content, marketing, and functionality on our Products is provided by third parties that are not affiliated with us. For example, we work with companies that help us understand how people use our Products as well as companies who’ve sponsored portions of our Products experience.

Other companies may collect information on or through our Products to market to you on or off of our Products. These and other third parties may collect information about your use of our Products, including through the use of cookies, device IDs, local storage, pixels and other technologies, and this information may be collected over time and combined with information collected on different websites and online services. The information collection and use practices of these third parties is governed by the separate, independent privacy policies of those third parties.

# 5. Cookies and Other Tracking Technology

Products may collect information by using technologies and methodologies, such as tags, web beacons or other similar technologies that enable tracking as you browse the Products. Cookies are small files used by many websites that reside on your computer’s hard drive and store information about your use of a particular site.

Generally, we use first-party and third-party cookies for the following purposes: to make our Products function properly; to provide a secure experience during your use of Products; to collect passive information about your use of Products; to measure how you interact with our marketing campaigns; to help us improve Products; and to remember your preferences for your convenience.

We may use the following types of cookies on our Products:

Strictly Necessary Cookies – These cookies are essential because they enable you to use our Products. For example, strictly necessary cookies allow you to access secure areas on our Products. Without these cookies, some Products cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Products to work and they cannot be disabled.
Functional Cookies – We use functional cookies to remember your choices so we can tailor Products to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of Products.
Performance or Analytic Cookies – These cookies collect passive information about how you use Products, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize Products. We do not use these cookies to target you with online marketing. You can disable these cookies.

# Your Choices

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Products by taking the steps outlined below:

First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of Products may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org (opens new window).
Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices (opens new window). Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers (opens new window).

We do not control third-parties’ collection or use of your information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

- Google Chrome  
- Internet Explorer  
- Mozilla Firefox  
- Safari (Desktop)
- Safari (Mobile)  
- Android Browser  
- Opera  
- Opera Mobile

# Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

# TrueDepth API / Camera Usage

The Selfies feature uses your device’s TrueDepth API camera system to track movement of your eyes, mouth and face. This allows for a unique user experience that allows you to capture playful images and/or videos of yourself.
In order for this feature to function, the app requires access to your camera. You will be prompted by the app to accept or decline permission to use your camera when the Selfies feature is activated.
The camera and resulting face data are only used for image and video creation purposes. Theseimages and/or videos are contained in the app’s Media Gallery and can be deleted at any time. The app allows you to share your images and/or videos with your friends through the native functionality of your device.

The face data is not stored on your device, stored remotely or given to third parties. The face data is only used when the app is active.

# 6. How do we respond to legal requests and prevent harm?

We access, preserve and share information with regulators, law enforcement or others in response to a legal request (like a search warrant, court order or subpoena), if we have a good faith belief that the law requires us to do so. This includes responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Information we receive about you, including your location, web behavior, and financial transaction data related to purchases made on or through our Products, can be accessed, processed and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from Products accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other term violations.

# 7. Privacy Notice for California Residents

This Section 7 applies only to California residents and contains the information that the Californian Consumer Privacy Act of 2018 (“CCPA”) requires us disclose. For purposes of this Section 7 only, “Personal Information” has the meaning given in the CCPA, but excludes information exempted from the scope of the CCPA. This Section describes Products’ collection, use and sharing practices in relation to Personal Information of California residents during the twelve (12) months preceding the effective date of this notice, and informs California residents of their rights with respect to that Personal Information.

I. Categories of Personal Information we collect may include:

Identifiers;
Data with special protections, if you choose to provide it;
Commercial information, if you choose to provide it;
Internet or other electronic network activity information;
Location-related information, including precise device location if you choose to allow us to collect it;
Audio or visual information, including photos and videos, if you choose to provide it; and
Information derived from other Personal Information about you, which could include your preferences, interests, and other information used to personalize your experience.

Personal Information is used for the purposes described in Section 2, and may be shared for the business and commercial purposes described in Section 3.

II. Sources of Personal Information

We receive Personal Information from the information that you and others provide, from your device(s), and from our partners. The categories of sources from which we’ve collected or received Personal Information include:

You: We collect information you provide when you use our Products, including when you sign up for an account, add information to your profile, buy something through our Products, create or share content, and message or communicate with others. We also collect information about how you use our Products, such as information about the people, activities, content, apps, features, or other experiences you interact with.
Other people: We also collect content and information that other people provide when they use the Products. This can include information about you, like when they send us an abuse report that refers to or contains video of you.
Your device(s): We collect information from and about the devices you use to access our Products, including information about the type of device you're using (such as a desktop, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing.
Partners: We may receive information about you from partners, including third-party apps, developers, other online content providers, and marketing partners that provide us information.

III. How can you exercise your rights provided under the CCPA?

Under the CCPA, you have the following rights:

Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
Right to Opt Out: You have the right to opt out of the sale of your information (as defined under the CCPA);
Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

To exercise your “right to know”, “right to opt out”, or your “right to request deletion,” email us at Privacy@jamestownlp.com, submit a request via our Web Form (opens new window), or call toll free: +1-888-914-9661 (PIN: 773 067).

Please note that to protect your information and the integrity of our Products, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as your name and proof of residence.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. In most cases, we will facilitate your request through automated tools available through your password protected account.

# 8. Security

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law and industry standards. These measures include computer safeguards and secured files and buildings. We restrict access to personal information to those employees, affiliates, agents, and third parties who have a need to know the information to perform a business purpose. We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control. You should be aware that, unfortunately, no system can be 100% secure. There will always be a risk that your personal information gets compromised. We also depend on you to keep your account information secure by keeping your password confidential and taking precautions to keep others from accessing your account. Please notify us immediately if you become aware of any unauthorized access to or use of your account.

# 9. How will we notify you of changes to this policy?

If we make changes to this Privacy Policy, we will provide notice of such changes as appropriate, such as by sending you an email notification to the address you’ve provided, and/or providing notice through the Products. If we make an administrative change, we will update the “Last Updated” date at the top of this Privacy Policy.

# 10. Contacting Us

If you have questions about this Privacy Policy, please contact us at:

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308
Email: Privacy@jamestownlp.com
US Toll Free: +1-888-914-9661 (PIN: 773 067)
Online: Web Form (opens new window)