Effective date: 16/11/2023
This is the Privacy Policy of Copium. (hereafter referred to as "Copium" "we," "us" or "our"), which explains how we collect, use, share and otherwise process and protect your personal information in connection with the Copium VR application (hereafter: “Copium VR application” or simply “Copium” or “the Services”). It describes how we process your personal information when we invite you to join Copium and when you use the Copium VR application. The Copium VR application is made available in the Meta Quest Store, which means that you need a Meta account to download the VR application. To play Copium, you need a Meta Quest VR headset and certain system requirements as prescribed by Meta.
We process personal data in a manner that is in accordance with the General Data Protection Regulation (in Dutch: Algemene Verordening Gegevensbescherming or “AVG”). We may update this policy from time to time by publishing a new version on our Website.
Please note that this Privacy Policy only relates to the Copium VR application, but not to our website(s) or other applications or services that we offer. For each of these (other) websites, applications or services we use different privacy policies that will be made available to you when you visit those websites or use those applications or services.
1. Who we are
The View B.V. is responsible for the processing of your personal data in connection with the Copium VR application as described in this Privacy Policy.
Our name and address details:
The View B.V.
Piet Heinkade 55
1019 GM, Amsterdam
The Netherlands
Registered in the Trade Register of the Netherlands Chamber of Commerce: 81938683
To exercise your rights or for any questions regarding the use, collection or processing of your personal information, please contact us via: privacy@jointheview.com
Please note, that we are an independent application developer and service provider not affiliated with Meta. We are not responsible for the processing of your personal data by Meta in connection with your Meta account. We do, however, need to create a connection with your Meta account to enable you to make use of the Services. Also, we are not responsible or liable in any way for your use of the Meta products and services, such as the Meta Quest application store and your Meta Quest VR headset, nor do we offer any warranty or guarantee that the VR application remains available in the Meta Quest Store, or on any other platform, or that it will always function properly or in accordance with your expectations.
2. What kind of information do we collect and for which purposes?
We process the following personal information in connection with the Services:
3. For which purpose do we use this information?
Your personal data will be processed by us only for the following purposes:
To invite you to join The Application
We process your name and e-mail address to invite you to join Copium in case you have given your permission directly to us or via one of our business partners who have asked your consent to be approached by Copium.
To communicate with you about the Services
We may use your contact details to communicate with you about the Services, for example to inform you about any new or changed features of Copium or other information about the Services that may be useful or relevant to you, to respond to your questions or to offer you support.
Marketing
We may use your information, such as your name and e-mail address to contact you with newsletters, personalised advertisements or other information about our services and products that may be of interest to you.
We do this only if you have explicitly given your consent to us to do so or if you have requested us to send you this information. You may unsubscribe from our e-mails to which you have subscribed at any time by clicking on the unsubscribe link in the e-mail. You may always contact us to unsubscribe from receiving messages containing advertisements and offers.
To improve our services
We may analyse your data in aggregated or pseudonymized form to improve our Services and for determining our product development goals and marketing strategies.
4. Lawful grounds
We only process your personal data based on lawful grounds such as your consent (for example to be able to send you our newsletters or marketing communications), when this is necessary to provide you with the Services you have requested or when this is necessary for our legitimate interests, unless your interests, fundamental rights or freedoms outweigh these interests. In determining whether processing can take place on the basis of our legitimate interests, a prior balancing of interests will be made between the interests of The View (or group companies of The View) and the interests of the data-subjects involved. Processing which is necessary for the purpose of analysing, maintaining and optimising the Services and for the purpose of fraud detection or prevention can for example (when a prior and careful balancing of interests in favour of the business interests) take place on this legal basis. We also conduct market research and compile management information for product and service development, to improve our services and for determining our (general) strategy.
5. How is your data shared?
We will not share your data with third parties unless with your prior permission or if one of the following situations apply:
In special cases, we may make personal data available to third parties without your consent. Special cases include legitimate requests to do so from competent authorities, subpoenas or court orders, to demonstrate compliance with laws or regulations applicable to us (such as evidence of your consent for certain processing operations of your data), actions to detect or prevent damage or fraud, actions to ensure the security of our network and services or to defend against legal claims.
Change of control
If we sell or otherwise transfer part or the whole of our company or our assets to another organisation (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information may be among the items sold or transferred. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.
6. Safety and security
We implement appropriate technical and organisational measures to protect your personal data, in accordance with the GDPR, against destruction, loss, alteration, unauthorised disclosure or unauthorised access and to make sure that the regulations and requirements relating to data protection are observed and upheld both by ourselves and by our external service providers. We use state-of-the-art technologies to keep the information collected through the VR application secure, including database encryption, internal access restrictions, incident monitoring and by regularly updating our systems. If you think that your data is not properly secured or if you have indications that your data is being misused, please send us an email to: privacy@jointheview.com.
7. International transfer
Your personal data may be transferred to and maintained on computers located outside the European Economic Area (“EEA”) that may not have data protection rules that require the same level of protection. However, in the case we engage non-European service providers, we carefully consider whether an adequate level of protection can be provided. These service providers are only permitted to use the information insofar as reasonably necessary for the performance of the agreement you have concluded with us. Where necessary, we conclude data transfer agreements with these service providers based on standard contractual clauses established by the European Commission. Under specific circumstances these service providers may be obliged to provide access to your data based on their applicable laws and regulations. For more information about safeguards for international transfers, please contact us using the contact details provided in this Privacy Policy.
8. Retention period
In accordance with the law, we do not retain your personal data longer than is reasonably necessary for attaining the purposes for which they were collected outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. We will retain your personal data as follows:
Type of personal data
Retention period
Correspondence
Up to 5 years after the last transaction due to the statutory limitation period for claims for damages. This information may serve as evidence.
Marketing communications
(email address)
Until you unsubscribe. If you decide that you no longer wish to receive the marketing communications, we will keep the withdrawal of your request. You may unsubscribe from our advertisements at any time.
Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
If you would like details of the retention periods for a particular aspect of your personal information which is not detailed above, please contact us at privacy@jointheview.com.
9. Your rights
You have the statutory right to know what personal data of yours we have stored and to whom we have disclosed it. You are entitled to request information at no cost about your data at any time and without charge, and to demand its correction, deletion or blocking. You may also revoke your consent to the processing methods at any time with immediate effect for the future.
You can easily access most of your data (including the data provided by you). You can ask us to rectify/correct such data by sending an email to us.
If you wish, we can send your personal data to you so that you can transfer it to another party, where technically feasible. You can make a request to that effect by sending an email to us.
In addition, you can ask us to restrict the processing of your personal data (for example if you deem the information to be incorrect, the processing is unnecessary or the processing is unlawful) or to terminate the use of your personal information and to erase your data.
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.
Remember, you can always object to the processing of your personal data.
If you would like further information about how your personal information is processed, or you wish to exercise one of your aforementioned rights, please send us an email. You may be contacted by our customer support team in order to verify your identity before we fulfil your request. This is to protect your privacy and the privacy of others. Finally, you can always submit a complaint about our data processing practices to the Dutch Data Protection Authority via www.autoriteitpersoonsgegevens.nl
10. Children's privacy
We do not intend to address to children (under 13 in the US, under 16 for EU residents, or other age as required by local law) ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Children have provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 16 (or the applicable age in their territory) without verification of parental consent, we take steps to remove that information from our servers.
11. Changes to this privacy policy
We may modify or update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12. How to contact us
If you have any questions about this Privacy Policy or the Services, or if you wish to send us a request based on your statutory rights as described under §9, please send an email privacy@jointheview.com.