This Privacy Policy outlines how Michael Golembewski ("we", "us", "our") collects, uses, and discloses Personal Information about our VR headset application users ("you"). We refer to these VR headset applications and related services collectively as "MWGStudio" in this Policy.
When you use MWGStudio, you consent to our collecting, using, and disclosing your Personal Information as described in this Policy. The term "Personal Information" refers to any data or information related to an identifiable individual.
Section 1. Personal Information
As described below, we collect Personal Information from or about you or your devices.
Oculus Platform Information. MWGStudio uses the Meta Oculus platform to authenticate users, send invites to friend lists, and provide avatar assets. This provides us with your Meta account display name, Oculus ID, Meta Quest platform friend lists, and access to your avatar images and 3D models.
User Communications. If you contact us directly, we may collect additional information about you. For example, when responding to technical support queries, we gather names and email addresses, and will archive all resultant correspondence.
Usage Information. We collect and infer Personal Information about you as you use and interact with MWGStudio. We record app user setting preferences so that they are persistent across virtual spaces, and keep track of what virtual space you are in, so that others can join you easily.
In-App Communications. When using MWGStudio as a shared multiuser virtual space, you may disclose Personal Information to us and to other users of the software, via conversations, chats, or other user-to-user interactions. We may collect and use this information to the extent permitted by law.
Movement Information. When accessing MWGStudio via a VR headset, we collect information about the physical movements of your body, controllers, and hands. This information is used to enable multiuser VR spaces and to support on-device user interactions, and is not used for identification purposes.
Location Information. We use your IP address to obtain the country and time zone from which you are connecting to the Internet. This information is used for server zone selection, and to ensure the correct display of dates and times in the experience.
Section 2. Persistent Local Files
The MWGStudio app saves small text files to your local device. These persistent files detail your user preferences and recent in-app activity, and allow for more effective and intuitive navigation of the software. They are also used for analytics purposes, to determine how well the software is working.
Section 3. How We Use the Information We Gather
We collect, use, and disclose Personal Information for the following purposes:
To enable access to MWGStudio.
To provide technical support and administrative communication.
To assess the effectiveness of MWGStudio.
To personalize MWGStudio based on your preferences and patterns of use.
For compliance purposes, as required by applicable laws and regulations.
Section 4. When We Disclose Information
We may disclose Personal Information to third parties in the following circumstances:
Service Providers. We allow third party service providers (such as Meta and Photon) to access and process your Personal Information when doing so is necessary for them to provide essential services.
Analytics Services. We allow analytics services to access Personal Information to gather information needed to improve the MWGStudio application.
As Required by Law. We disclose Personal Information about you if required to do so by law.
At Your Direction. We may disclose information to third parties if you expressly direct or authorize us to do so.
Section 5. Your Data Privacy Rights
If you would like to invoke your rights and request that we take action regarding your Personal Information, or if you have any questions, concerns, or complaints about how we are using your Personal Information, you may contact us at https://mikegolembewski.com/contact.
Prior to fulfilling user-related data requests, and to the extent permitted under applicable law, we may ask you to provide information for identity verification.
European Data Privacy Rights
Residents of the European Economic Area, the United Kingdom, or Switzerland have the following rights regarding Personal Information:
Know and access your Personal Information we hold.
Get your information in a standard format and ask for transfer to another party.
Have your Personal Information deleted or corrected.
Limit or object to our use of your Personal Information.
Appeal our decisions on your privacy rights and file complaints with authorities.
Withdraw consent for processing your Personal Information at any time without affecting past lawful processing.
California Data Privacy Rights
If you reside in California, you have additional rights relating to your Personal Information, including:
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information (if applicable); and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you.
Right to Correct Inaccurate Information. Subject to certain exceptions, you may submit a verifiable request that we correct inaccurate Personal Information about you.
Right to Limit Use and Disclosure of Sensitive Information. You have the right to restrict our use of your “Sensitive Personal Information”, as that term is defined in the CCPA. We do not use or disclose Sensitive Personal Information for purposes other than those specified in Section 7027(m) of the CCPA.
Right to Opt Out of “Sale”. You have the right to opt out of our “selling” your Personal Information, as that term is defined under the CCPA. We do not sell your Personal Information.
Right to Opt Out of “Sharing”. You have the right to opt out of our "sharing” your Personal Information for cross-context behavioral advertising. We do not share Personal Information for this purpose.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. We may seek to verify your identity, and when doing so we may ask for additional information.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light '' law (Civil Code § 1798.83).
Submit Requests. To exercise your rights under the CCPA, Please send us any questions or comments to us via the following form : https://mikegolembewski.com/contact.
Authorizing an Agent. To authorize an agent to make a request on your behalf, please send a written authorization signed by you and the authorized agent to us via the contact information listed in the “How to Contact Us” section below. If permitted by law, we may take additional steps to verify your identity and relationship to the authorized agent.
Do Not Track. This is not applicable to our app.
Brazilian Data Privacy Rights
If you reside in Brazil, you have the following rights relating to your Personal Information:
The right to know and access the Personal Information we have collected about you;
The right to request that we delete your Personal Information; and
Any user can submit a complaint to the National Data Protection Authority of Brazil at anpd@anpd.gov.br
Section 6. Legal Bases for Processing European Personal Information
If you are located in Europe, we only process your Personal Information when we have a valid “legal basis,” as set forth below:
Consent. You have expressly consented to the use of your Personal Information.
Contract. We need your Personal Information to fulfill a contractual obligation to you.
Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information.
Legitimate Interests. We or a third party have a legitimate interest in using your Personal Information to provide you with multiuser and VR functionality in MWGStudio. We also have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and to improve the safety, security, and performance of MWGStudio.
We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
Section 7. Children’s Privacy
MWGStudio is not intended for children under 16. We don’t collect their data knowingly. If a child under your care has given us their data without consent, inform us and we’ll remove their account and data.
Section 8. Data Security
We implement various safeguards to protect your Personal Information, but no system is foolproof. Despite our efforts, we can’t assure complete security against unauthorized access or breaches.
Section 9. Data Retention
We adopt a policy of data minimisation, and remove data immediately once the purpose of its collection has been met.
We only use body pose information to animate your avatar in real time and to enable realtime interactive effects. We do not store records of this information.
Section 10. International Visitors
The Personal Information of MWGStudio is processed and stored in the United States. We may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling user requests, and operating MWGStudio. By providing Personal Information to MWGStudio, you agree with this transfer, storage, and processing.
Section 11. California Resident Privacy
This section applies to individuals residing in California from whom we collect Personal Information.
We do not “sell” or “share” Personal Information and we do not disclose Personal Information for purposes other than those specified in section 7027(m) of the California Privacy Rights Act regulations.
Identifiers
Personal Information Collected : Username, Oculus ID, Avatar Visual assets, IP address
Source of Personal Information : Meta Quest Headset Entitlement Data, Gaming platforms and infrastructure providers (Meta and Photon), Analytics services (Unity)
Business Purpose : Provide multiuser VR services, facilitate communication between app users, provide avatar assets in app
Third-party Recipients : Gaming platforms and infrastructure providers (Meta and Photon), Analytics services (Unity)
Categories listed in the California Customer Records Statute
Personal Information Collected : No data of this type is collected.
Characteristics of Protected Classifications under California or Federal Law
Personal Information Collected : No data of this type is collected.
Commercial Information
Personal Information Collected : Oculus User Friend List.
Source of Personal Information : Gaming platforms and infrastructure providers (Meta and Photon)
Business or Commercial Purpose : Provide matchmaking and joining functionality to app.
Third-party Recipients : Gaming platforms and infrastructure providers (Meta and Photon)
Biometric Information
Personal Information Collected : No data of this type is collected.
Network Activity Information
Personal Information Collected : VR Room Joining and VR Room Exit data.
Source of Personal Information : Gaming platforms and infrastructure providers (Meta and Photon)
Business or Commercial Purpose : Provide matchmaking and joining functionality to app.
Third-party Recipients : Gaming platforms and infrastructure providers (Meta and Photon)
Geolocation Information
Personal Information Collected : Approximate location via IP address.
Source of Personal Information : Gaming platforms and infrastructure providers (Photon)
Business or Commercial Purpose : Enable region specific server connections in multiuser VR groups, support app use analytics
Third-party Recipients : Gaming platforms and infrastructure providers (Photon), Analytics services (Unity)
Sensory Data
Personal Information Collected : Voice, head movement, eye movement.
Source of Personal Information : From users engaging with the app.
Business or Commercial Purpose : Allows multiuser VR and VOIP.
Third-party Recipients : Gaming platforms and infrastructure providers (Photon and Meta), Analytics services (Unity)
Employment-Related Information
Personal Information Collected : No data of this type is collected.
Non-Public Education Information
Personal Information Collected : No data of this type is collected.
Inferences Drawn from Personal Information
Personal Information Collected : No data of this type is collected.
Sale and Sharing of Personal Information
In the preceding twelve months, we have not sold or shared any California resident’s Personal Information, as those terms are defined in the CCPA.
Section 12 : Contact Us
Michael Golembewski (Westport, MA, 02790, United States) is responsible for the processing of your Personal Information. Please send us any questions or comments using the form at https://mikegolembewski.com/contact.