www.virryhealth.com, www.virryvr.com, and use our VR products (“Services”). This Privacy Policy (Privacy Policy) details the steps we take to protect your personal information when you use our services. It describes the personal information that we collect, the purposes for which we use such information, and your choices regarding our use of it.
We have adopted the principles of the General Data Protection Regulations (EU Regulation 2016/679) across our platforms in all countries as we believe this is a robust set of principles which proves our commitment to ensure we keep your personal data safe and secure at all times.
Fountain Digital Labs Limited ("our", "we", "us" or "Fountain Digital") is the controller and is responsible for your personal data. Fountain Digital Labs Limited, registered office at 2 London Wall Place, London, EC2Y 5AU (“Fountain Digital”). This entity shall act as the controller and shall process your personal information in accordance with this Privacy Policy. Please refer to the contact details section of the Privacy Policy for details on this entity.
The steps we take to protect your personal information and how you can review and correct your personal information are also covered here. By accessing our Service, you are consenting to the information collection and use practices described in this Privacy Policy. We may occasionally update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. When we do, we will revise the "last updated" date at the bottom of the Privacy Policy. Please ensure that you frequently check this Privacy Policy for any updates.
Fountain Digital Labs Limited is committed to protecting your privacy and personal information. We respect and value the privacy of everyone who visits our Websites
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings: “Confidential Information” means all written or oral information, disclosed by either Party to the other that has been identified as confidential or that by its nature ought reasonably to be considered confidential.
“Customer”, “you”, “Users” mean a natural or legal person who has accepted these Terms with Fountain Digital. “Personal Data” is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
“Data Protection Laws” means all laws and regulations, including laws and regulations of the European Union (the “EU”), the European Economic Area (the “EEA”) and their member states, Switzerland and the United Kingdom, and the United States of America, applicable to the Processing of Customer Personal Data under these Terms.
“Cookie” means a small text file placed on your computer or device by our Website when you visit certain parts of our weite and/or when you use certain features of our Website. Details of the Cookies used by our Website are set out in Part 14, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
“Service” means our websites virryhealth.com, virryvr.com and our VR products (Virry VR): Virry VR: mindfulness in nature VR; Virry Safari : Wild Encounters; Virry VR : Feel the Wild; and Virry App.
“Website” means an interface of the Platform compiled of all web documents (including images, CSS, and HTML files) made available via virryhealth.com or its sub-domains or domains under other top domains and owned by Fountain Digital.
2. Your consent (important, please read carefully)
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SERVICE 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 DATA 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 SERVICE IN ANY MANNER, DO NOT INSTALL THE SERVICE AND/OR PROMPTLY UNINSTALL THE SERVICE FROM YOUR VR DEVICE.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of our Service. Our Service may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites, or your VR device and we advise you to check the privacy policies of any such websites or your device before providing any data to them.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.
b) The right to access the personal data we hold about you. Part 12 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 16 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to withdraw consent for the use of your personal data.
g) The right to object to us using your personal data for a particular purpose or purposes.
h) The right to data portability. This means that, if you have provided personal data to us directly or we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.
If you wish to exercise any of these rights, please contact us using the details provided in Part 16.
Further information about your rights can also be obtained from the Information Commissioner’s Office (United Kingdom), your local Citizens Advice Bureau (United Kingdom) or The Office of the Privacy Commissioner for Personal Data (Hong Kong).
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. The personal data we collect from you, how we collect it and how we use it?
Depending upon your use of our Websites, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy).
• Name
• Address
• Email address
• Telephone number
• Industry
• Business name
• Job title
• Gender
• Date of birth
• IP address
• Other information relevant to customer surveys and/or offers
To ensure data minimisation, we will only ask for data that is relevant and necessary in relation to the purposes for which they are processed.
In our Virry VR products for Oculus and Playstation VR, we ask users to state their mood at the beginning and end of their Virry VR experience. This data is collected to help personalise the service, allowing users to track their mood progression as a result of using the product. This data is only stored on the app on your device and is not collected/ transferred away from your device, unless you as the user manually exports this data, for example by sharing a screenshot of this feature. Reporting of Mood is optional and we do advise in our Terms of Use document that with headsets that may be shared with other users users should select a mood rating you would be comfortable with being viewed by others. Please see the Terms of Use document for more information.
In our iOS and Android Virry apps we suggest to join the ‘Parents Club’ community by giving your name and email. It’s a voluntary procedure and users may ignore a popup invitation to the club by closing it. The reason to subscribe is to receive emails with tips and original ideas for family time, and to watch exclusive videos to learn more about wildlife. We never send out emails more than once a week. Every email includes an option to unsubscribe. There is also an option to subscribe to the Club via Facebook.
In our Oculus and PlayStation VR apps we suggest joining the ‘Virry Club’ by giving your email in the popup form. It is also optional and the reason to give your email is to receive letters about product news and wildlife conservation.
Email addresses are collected by the cloud platform Heroku, which securely transfers them to our Mailchimp database. Heroku utilizes application isolation, operating system restrictions, and encrypted connections to ensure risk is mitigated at all levels. The entire Mailchimp application is encrypted with TLS.
All email data is kept on our AWS secure servers and Mailchimp service.
Our Website places certain cookies that are necessary for the security of the site. Users cannot opt-out of these first-party cookies being placed on their device when using our site, as they are used for protection from DDOS attacks. Please see our Cookie Policy for further details.
By using our services and by submitting personal information to us then this Privacy Policy will apply.
6. How is your personal information used?
We will use the personal information you provide to us to:
- Provide and manage your Account
- Fulfil your purchase order or contractual requirements
- Provide you with personalised access to and use of the service;
- Provide you with our services; your personal details are required in order for us to enter into a contract with you
- Internal record keeping
- Share your personal information with other partners (detailed below);
- Recommend goods, services or promotions which may be of interest to you (but only where you have consented to be contacted for such purposes);
- Supply you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us)
- Analyse your use of our Service and gather feedback to enable us to continually improve our Service and your user experience
- Communicate with you. This may include responding to emails or calls from you
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided, subject to you having agreed to this
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax, mail or SMS. We may use the information to customise the Website according to your interests
With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and post with information, news, and offers on our products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out Third Parties (including Distributors) whose content appears on our Website may use third-party Cookies, as detailed below in Part 14.
Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
7. With whom is your personal information shared?
We will not sell, distribute or lease any personal information we have to third parties unless we have your explicit permission or are required by law to do so.
We may disclose your personal information in the following ways:
- To group companies in our common control;
- To third parties acting on our behalf to process, organize or host data for us. These data processors will not have separate rights to use your data and will always act strictly in accordance with our instructions.
We may disclose personalized data (such as aggregated statistics) about the users of our service in order to describe our sales, customers, traffic patterns, and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
We may occasionally be required by law, court order, or governmental authority to disclose certain types of personal information. Examples of the type of situation where this would occur would be:
- In the administration of justice;
- Where we have to defend ourselves legally.
Finally, in the event of a reorganization, sale, or takeover we may need to disclose or transfer personal information.
8. The requirements of Data Protection Laws
We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end we fully endorse and adhere to the 'Data Protection Principles' set out in the Act. In particular, without your consent or first amending this Privacy Policy to reflect any change in our usage of personal information:
- We will not use your personal information for any purpose that is incompatible with this Privacy Policy;
- We will only collect sufficient personal information for the uses set out above;
- Any personal information collected by us will not be shared or processed for any other reason than what is outlined in this Privacy Policy.
- We will endeavor to keep your personal information up-to-date;
- We will not retain your personal information longer than necessary, unless required to do so by law. Your personal data will therefore be kept for the following periods or, where there is no fixed period, the following factors will be used to determine how long it is kept:
- For the duration of our contractual relationship or until requested by you to cease our business relationship.
- Personal data processed for newsletters will be kept until the user unsubscribes.
Following these events, the data will be securely deleted in accordance with AWS secure servers and MailChimp service’s data deletion methods. We do not keep any physical copies of personal data.
- We will operate appropriate technical and organizational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy;
9. How and Where Do You Store or Transfer My Personal Data?
We will not transfer your personal information to a country outside the European Economic Area unless safeguards are in place to protect your personal information to the standards that apply within the EEA.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
- We have implemented technical and operational controls to ensure the security of your personal data.
10. How Can I Control My Personal Data?
10.1 In addition to your rights under the GDPR, set out in Part 4, when you submit personal data via our Website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Can I withhold information?
You may access certain areas of our Website without providing any personal data at all. However, to use all features and functions available on our Website you may be required to submit or allow for the collection of certain data. You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.
12. Reviewing your personal information
In some cases, you can review and correct personal information provided through our service by going to the page on which you provided the information.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email address in the Contact Details section at the bottom of this document.
In all cases, you can make a subject access request to review your personal information collected via our service or ask us to stop using it by sending us an email. We may take steps to verify your identity before providing you access to your personal information. There is not normally any charge for a subject access request. However, if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.
You can help us to maintain the accuracy of your information by notifying us of any change.
If you find that a child (a person under the age of 18) has accessed the Service and provided personal information without parental consent, please contact us using the details set out in section 16 and we will endeavour to investigate the matter as swiftly as possible and remove any records of the data accordingly.
13. Links to other websites
Our service may contain links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.
14. Cookies
Our Website places certain cookies that are necessary for the security of the site. Cookie Law deems these Cookies to be “strictly necessary”. The following first-party Cookies may be placed on your computer or device:
Our Website does not use analytics. Please see our Cookie Policy for further details.
15. Enforcement of this Privacy Policy
If you have questions regarding this policy or our handling of your personal information, please contact us via the following address: contact@fountain-digital.com.
Last updated on 23 May 2023.
16. Contact Details:
If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights to request details of any personal information which we hold about you under the General Data Protection Regulation (EU) 2016/679, or if you think that the Privacy Policy has not been followed, please contact us by emailing contact@fountain-digital.com
You may contact our Data Protection Officer, Svetlana Dragayeva, at svetlana@fountain-digital.com.
We will respond without delay and within one month of receipt of the request. We may exercise our right to extend the time limit by a further two months if the request is complex or if we receive a number of requests from you.
Fountain Digital Labs Limited, registered in England and Wales as a limited company at Companies House (No. 08230374) with a registered company office at 2 London Wall Place, London, EC2Y 5AU, United Kingdom.
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