Personal Information of Users ("User", "you") obtained through the https://darkroomvr.com/ website
("Website") and its services. The terms “we,” “us,” and “our” refer to the Company.
“Personal Information” or “Personal Data” is an information that identifies or can be used to
identify, contact, or locate the person to whom such information pertains.
The definition "processing" refers herein to the handling of your Personal Data by us, including
collecting, protecting and storing your Personal Data.
registered members of the Website by creating their own account (referred to in this Website as
“Members”). For the purpose of this Policy, the definition “User” refers to Visitors as well as to
Members as the context shall require. Visitors and Members must be aged eighteen (18) years and over
or must have attained the age of majority in their respective jurisdiction in order to be able to
use the Website. All Users who do not meet these criteria are strictly forbidden from accessing or
viewing the contents of the Website. We do not knowingly seek or collect any Personal Information
from natural persons who have not attained the age of eighteen (18).
We are fully committed to respecting privacy and to protecting any information that our users
provide. Your privacy and security are both our highest priorities and we make every effort to
ensure that all the information provided by you is protected.
We follow and comply with best practices and regulation in the sphere of privacy including but not
how the Company collects and processes your Personal Data and tells you about your rights under the
PERSONAL INFORMATION WHICH WE MAY COLLECT
Depending on your status and your level of interaction with our Website and Services we
may collect and process different categories of Personal Information about you. We will
limit the collection and processing of Personal Information to information necessary to
achieve one or more of our legitimate purposes and interests as identified in this
Personal Information, that we collect and process from Visitors:
- Technical information, which we may collect through automated means. Through
your use of the Website and Services, we monitor and collect tracking
information related to usage such as IP (Internet Protocol) address, language
preference, country, information about hiding of banners, the “remember me”
function during the authorization, information that helps us not to provide you
repeated data, information about viewing of posters on our Website, analytics
information, access date, time and location, browser plug-in types and versions,
mobile phone network information, device identification, information that helps
us to receive payment from you, operating system, browser type and version. This
information may be directly obtained by the Company or through third party
- Consents, including any permissions, consents or preferences that you give to
- Usage Data, including your communication preferences and information about how
you use our Website including the services you viewed or searched for, page
response times, download errors, length and number of visits and page
interaction information (such as scrolling, clicks and mouse-overs) as well as
- In case you decide to share with us some other Personal Information and we may
collect it as well.
- Personal Information, that we collect and process from Members:
- All Personal Information that we collect from Visitors in accordance with cl.
2.2. of the Policy;
- Identity and contact Personal Information, including your email address,
username and password;
- Information, that you can add to your Account such as your favorite content,
- Marketing Data, including preferences in receiving marketing from us and
- Technical information such as the information about the current session of the
- Communications, including communication provided by you in comment section and
information on how and what methods we use in order to communicate with you
through electronic and verbal correspondence.
- It shall be separately stated that we do not store your financial information as far as
your payment is processed by third party service providers responsible for processing or
facilitating any payment. By entering your information during your payment of
subscription fee you grant third party service providers a consent to process your
information in order to complete the payment. The Company is not responsible for the
activities of any third party or the content of any third party website, including a
or operating system) collected when You make payment. You are responsible for reviewing
any terms and conditions of membership on third party sites.
- We may also collect, use and share aggregated data such as statistical or demographic
data for the purpose of customizing our marketing efforts or the use of our Website.
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.
WHO WE ARE
- The Personal Information on the Website is collected, controlled and processed by the
wish to obtain more details in relation to the Personal Data we process about you,
please contact us by sending an email to firstname.lastname@example.org.
WAYS OF COLLECTING YOUR PERSONAL DATA, FAILURE TO PROVIDE PERSONAL DATA
As a general rule we obtain your Personal Data through any information you provide
directly to us via our Website. However, we also use other indirect methods to collect
Your Personal Information while you use our Website and/or Services. Below is a list of
ways we collect your Personal Data:
- when you visit and/or use our Website;
- when you complete the registration steps in order to create an account;
- you also provide Personal Information indirectly when you navigate the Website,
as Personal Information about you is automatically observed and collected;
- when you contact us via the Website, email, comments or otherwise.
- Where we need to collect and process your Personal Data in order to provide you with our
services and you fail to provide that data when requested, we may not be able to provide
you with access to our Website and/or the services we offer. In this case, we may have
to suspend your access to the Website or, if you are a Member, prohibit any access to
non-public areas of the Website or restrict the operation of your account and the
services we provide to you.
POLICY TOWARDS MINORS
- We do not intend to solicit or collect Personal Information from anyone under the age of
18 or under the legal age of your country, if it is higher. If you are under 18 or are
not of a legal age of your country, do not enter any Personal Information on our Website
and leave our Website. If we become aware that a minor has provided us with Personal
Data, we will take steps to remove such data and terminate that person's account
immediately (if such account was created). We encourage you to contact us via
email@example.com if you become aware that minor provided us with Personal
PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
We will collect, process store and use Personal Information for providing you with our
lawful services and make available all functionality of the Website in accordance with
this Policy. In brief, we have the following legal basis under the GDPR and other
applicable EU laws for processing your Personal Data:
- We process Personal Data for the purposes of providing the services,
functionality and security because the processing is necessary to provide the
services you have requested via the Website, or to provide our Website and
services in a manner consistent with our terms and conditions of use and any
other contract that you have with us;
- We process Personal Data where it is necessary for our legitimate interests (or
those of a third party) and your interests and fundamental rights do not
override those interests;
- We process Personal Data where such processing is necessary for us to comply
with a legal or regulatory obligation;
- We process Personal Data in specific circumstances where you have provided your
consent to such processing.
- Please find below this legal basis and circumstances in further detail.
Performance of our services to you
Provision of services
We may collect and process your Personal Data where it is necessary in order
to present our Website and its contents to you, including any interactive
features on our Website and to provide you with information or services that
you request from us.
Please note that if you do not agree to provide us with the requested
information, it may not be possible for us to continue to operate your
account and/or provide you with the services we provide to our Members.
Customer management (Members Only)
We may use identifiers, contact information and any other types of Personal
Information to manage your account, to provide customer support and notices
to you about your account, including expiration and renewal notices, and
notices about changes to our Website or any products or services we offer or
provide through it;
Customization of content (Members Only)
We may collect and process your Personal Data where it is necessary in order
to perform research and analysis about your use or, or interest in, our
Website content and/or services, so as to develop and display content and
advertising tailored to your interests on our Website.
We may collect and process your Personal Data where it is necessary in order
to determine whether users of the Website are unique, or whether the same
user is using the Website on multiple occasions, and to monitor aggregate
metrics such as total number of visitors, pages viewed and demographic
Functionality and security
We may collect and process your Personal Data where it is necessary in order
to diagnose or fix technology problems, and to detect, prevent and respond
to actual or potential fraud, illegal activities, or intellectual property
Other legitimate interests
In addition to the above, we may process your Personal Data, to the extent
required for our business needs in order to:
- develop new services on our Website as well as analyze and target new
- protect our legal rights and interests (including legal claims and
preparing our defense in litigation);
- monitor, maintain and improve internal business processes, information and
data, technology and communication solutions and services;
- ensure network information security, including monitoring Visitors' and
Members’ access to our information technology for the purpose of preventing
cyber-attacks, unauthorized use of Website and prevention or detection of
- send you relevant marketing information (including details of other
services provided by us which we believe may be of interest to you), but
only where you are a Member of the Website;
- monitor the performance and effectiveness of our services and the Website;
- assess the quality of our customer services.
For compliance with legal obligations
When you visit and/or use and/or register in our Website (and throughout your
relationship with us), we are required to comply with certain legal and regulatory
obligations which may involve the processing of your Personal Data. This may include
- perform checks and comply with laws relating to fraud;
- manage contentious regulatory matters, investigations and litigation.
You have provided your consent
We will only ask for your consent when we wish to provide marketing information to
you in relation to our services which we believe may be of interest and of benefit
You have the right to revoke your consent at any time. However, any processing of
Personal Data prior to the receipt of your revocation will not be affected.
DISCLOSURE AND SHARE OF YOUR PERSONAL DATA
- In certain situations, We may be required to disclose Personal Information in response
to lawful requests by competent authorities, including to meet national security, public
interests or law enforcement requirements.
- We may disclose your Personal Information where required by law (e.g., to comply with a
subpoena, warrant, court order, or legal process served on the Company), and when we
believe that disclosure is necessary to (a) satisfy any applicable law, regulation,
legal process, or governmental request, (b) enforce applicable terms and conditions of
use, including investigation of potential violations thereof, (c) detect, prevent, or
otherwise address illegal or suspected illegal activities, security or technical issues,
(d) protect against harm to the rights, property or safety of our company, our users,
our employees, or others; or (e) to maintain and protect the security and integrity of
our Website or infrastructure. In such cases, we may raise or waive any legal objection
or right available to us, in our sole discretion.
- We may disclose any of the categories of Personal Information to members of our
corporate group (that is, entities that control, are controlled by, or are under common
control with us) to the extent this is necessary for the purposes set out in this
- We may disclose all of the categories of Personal Information we collect to a buyer or
other successor in the event of a merger, acquisition or sale or transfer of some or all
of our assets, whether as a going concern or as part of bankruptcy, liquidation or
- We may share Personal Information with certain companies that perform services on our
behalf on a need-to-know basis. We require any company with which we may share Personal
Information to protect that data in a manner consistent with this policy and to limit
the use of such Personal Information to the performance of services for the Company.
- You agree that We may share and transfer Your information which no longer identifies You
to the third party (pseudonymisation) who is a contracting party with Us, usually Our
service providers or advertising partners. This information does not contain any
Personal Data and may be used to develop content and services that we hope you and other
users will find of interest.
- Please note that we have never sold and will never sell your Personal Data to third
- The Company aims to protect your Personal Information as much as we aim to protect our
own confidential information and network. We do not sell, trade, or rent your personal
identification information to others. You should never disclose your account password to
- We take appropriate security measures (including physical, electronic and procedural
measures) to safeguard your Personal Data from unauthorized access and disclosure. For
instance, only authorized employees are permitted to access Personal Data, and they may
do so only for permitted business functions. In addition, we use encryption in the
transmission of your Personal Data between your system and ours, and we use firewalls to
help prevent unauthorized persons from gaining access to your Personal Data. However we
cannot guarantee that these measures will stop any users try to get around the privacy
or security settings on the Website through unforeseen and/or illegal activity. That is
why we make no warranty, express, implied or otherwise, that we will prevent such
- You are responsible for maintaining the secrecy of your unique password and account
information at all times. We are not responsible for circumventions of any privacy
settings or security measures contained on the Website.
- We will retain your information only for as long as is necessary for the purposes set
out in this policy. We will retain your information just to the extent necessary to
comply with our legal obligations, resolve disputes, and enforce our agreements. We may
retain your Personal Data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect of our relationship with
- To determine the appropriate retention period for Personal Data, we consider the amount,
nature and sensitivity of the Personal Data, the potential risk of harm from
unauthorized use or disclosure of your Personal Data, the purposes for which we process
your Personal Data and whether we can achieve those purposes through other means, and
the applicable legal requirements.
- Where we no longer need to process your Personal Data for purposes set out in this
your data for longer if we cannot delete it for legal, regulatory or technical reasons.
If we do, we will make sure that your privacy is protected and that your data is only
used for those purposes.
- If you have questions about our data retention practices, please contact us
electronically by sending as an email at firstname.lastname@example.org.
TRANSFERS OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
- Whenever in the course of sharing information we transfer Personal Information to
countries outside of the European Economic Area and other regions with comprehensive
data protection laws, we will ensure that the information is transferred in accordance
protection and a similar degree of protection is afforded to shared Personal
- We may additionally, in rare occasions, transfer your Personal Data to a party outside
the EEA where we have your prior explicit consent to do so or where such transfer is
necessary for the provision of our services to you.
- We may process your Personal Data so as to inform you about existing and/or future
services that may be of interest to you by sending you periodic announcements with
details on existing and/or new services and/or programs.
- You have the right to object at any time to the processing of your Personal Data for
- We can only use your Personal Data to promote our services to you if we have your
explicit consent to do so, or in certain cases such as for example when you are a Member
of our Website, if we consider that it is in our legitimate interest to do so. You may
also occasionally receive marketing communications from our affiliates, but only
provided you have given your explicit consent in receiving such communications.
- Even if you inform us that you no longer wish to receive marketing material, you will
still receive from us system notices and other information specifically related to your
account from time to time.
YOUR RIGHTS RELATED TO YOUR PERSONAL DATA
- In accordance with effective regulations You have a significant number of rights related
to your Personal Information, such as e.g.:
- The right to access and amend the Personal Information we hold about you. You
have a right to request a copy of the Personal Information we hold about you.
- You have the right to correct or update your Personal Information at any time.
- The right to delete your Personal Information. In accordance with the "Right to
be forgotten", we leave the opportunity to erase Personal Information about you.
If you do not want to use Website or want your data to be erased, you can
request us to erase your Personal Information permanently. In this case, the
Company will cancel your account (if you are a Member) and delete your Personal
Data subject to erasure.
Grace period: There is a 14-day grace period before we
proceed with erasure. During this Grace Period you will be allowed to
restore your account. The grace period functionality allows you not to lose
any important information and options by mistake. After the expiration of
the grace period however, your account will be deleted and/or Personal Data
will be erased.
The right to restrict processing. You have the right to ask us to restrict the
processing of your Personal Information. When processing is restricted, we can
still store your information, but will not use it further. This enables you to
ask us to restrict the processing of your Personal Data if:
- it is not accurate; or
- it has been used unlawfully but you do not want us to delete it; or
- it is not relevant any more, but you want us to keep it for use in
possible legal claims; or
- you have already asked us to stop using your Personal Data but you are
waiting for us to confirm if we have legitimate grounds to use your Personal
- The right to object to the processing of your data. You have a right to object
to our use of your Personal Information for our own purpose at any time. In
other words you can withdraw your consent to processing your Personal
Information by us. In case you want to exercise this right, you may contact us.
This right also includes the right to object to processing your Personal
Information for marketing and advertising purposes. You can do it by clicking on
the special button (an unsubscribe button) or by contact us and opting out from
receiving all e-mails. If you exercise your right to object, we will no longer
process your Personal Data unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and freedom or
for the establishment, exercise and defense of legal claims.
- The right to data portability. You have the right to receive Personal
Information you provide to us, in a "commonly used machine-readable format".
This allows you to obtain and reuse your information for your own purposes
across different services.
- The right to lodge a complaint with a Supervisory Authority. We take privacy
concerns seriously. If you believe that we have not complied with this Privacy
Policy with respect to your Personal Information, you may contact our respective
Data Protection Office. We will investigate your complaint promptly and will
reply you within 30 (thirty) calendar days. If you do not receive acknowledgment
of your complaint or your complaint is not satisfactorily addressed, you have
the right to lodge a complaint with the respective supervisory authority.
- In case you want to exercise your rights, please contact us.
- Please note that some requests to delete certain Personal Data will require the deletion
of your account as a Member as the provision of Member accounts is inextricably linked
to the use of certain Personal Data (e.g. your email address). Also note that it is
possible that we require additional information from you in order to verify your
authorization to make the request and to honor your request.
- There are exceptions to these rights, however. For example, access to Personal
Information may be denied in some circumstances if making the information available
would reveal Personal Information about another person or if we are legally prevented
from disclosing such information. In addition, where some of the data is necessary to
maintain the Company or where that is a legal requirement, we may retain such data for
the period it is needed or required even if you withdraw your consent or cancel your
account. Such information will not be considered as subject to erasure.
practices, please contact us electronically at email@example.com.
CALIFORNIA CONSUMER PRIVACY ACT NOTICE
- As of January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") provides
California residents ("Consumer(s)") certain rights with respect to their Personal
Information, as this term is defined under the CCPA. In addition to the rights we state
under this policy and subject to the exceptions found under the CCPA, Consumers have the
- opt-out of the sale of their Personal Information, should we sell their Personal
- be informed of certain information concerning our collection and use of their
- request that we delete certain Personal Information we collected from them;
- appoint an agent to exercise their rights provided for by the CCPA, provided
that a duly executed notarized power of attorney is presented and provided that
the agent has information deemed sufficient to allow us to verify the identity
of the Consumer in question and to locate his/her information in our systems;
- not be subjected to discrimination for the exercise of these rights. We will not
deny California residents the use of our service, neither will we provide a
different level or quality or services for exercising any of their CCPA rights,
unless as permitted under the CCPA.
- The Company does not sell nor has it sold in the past 12 months Personal Information to
third parties for monetary or other valuable considerations. We may however disclose
certain Personal Information with third parties, service providers and entities within
our corporate group in order to enable them to perform certain services on our behalf
and namely to make the Website work properly. Regardless, we respect the California
residents' right to exclude Personal Information from such sharing arrangements and to
thereby opt-out of any future sale of their Personal Information. If the CCPA is
applicable to you and you would like to record such preference, please send us an email
LAW AND HARM
- Notwithstanding anything to the contrary in this Policy, we may preserve or disclose
your information if we believe that it is reasonably necessary to comply with a law,
regulation, legal process, or governmental request; to protect the safety of any person;
to address fraud, security or technical issues; or to protect our or our users’ rights
or property. However, nothing in this Policy is intended to limit any legal defences or
objections that you may have to a government’s request for disclosure of your
- Our Website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect
or share data about you. We do not control these third-party websites and are not
responsible for their privacy statements. We specifically disclaim responsibility for
representations about their accuracy, content or thoroughness. When you leave our
CHANGES TO POLICY
- This Policy may be amended at our full discretion without prior notice. We encourage you
to review it periodically in order to be aware of the changes we may have made. Reading
it carefully and checking for any modifications is your responsibility. By using the
Website, you accept and agree to the Policy and the Terms and Conditions of Use.
- As we have briefly mentioned in this Policy, our Website uses small files known as
cookies to make it work better in order to improve your experience.