Privacy Policy for Silversky3D VR LTD

1. Introduction

Welcome to Silversky3D VR LTD (“we,” “us,” or “our”). We are a company based in Cyprus dedicated to creating immersive Virtual Reality (VR) and Augmented Reality (AR) experiences.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website silversky3d.com  to use our VR/AR applications (“Experiences”), or otherwise interact with our services.

We are committed to protecting your personal data and your right to privacy. If you have any questions or concerns about this policy or our practices with regard to your personal information, please contact us at the details provided in Section 12.

By using our Services, you agree to the collection and use of information in accordance with this policy.

2. Who is the Data Controller?

For the purpose of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller is:

Silversky3D VR LTD, Eleftheriou Venizelou 21, Agios Dometios, 1105 Nicosia, Company Registration Number: ΗΕ331119 Email: [email protected] Phone: 22252500

3. What Information We Collect

We may collect personal information that you provide to us directly, information we collect automatically through our Services, and information from third-party sources.

3.1. Information You Provide to Us

• Contact Information: When you fill out a contact form, subscribe to our newsletter, or communicate with us, you may provide your name, email address, phone number, and the content of your message.
• Account Information: If our Experiences require an account, we may collect a username, password, email address, and other profile information you choose to provide.
• Business Information: If you are a client or partner, we may collect your company name, job title, and other details related to our business relationship.

3.2. Information We Collect Automatically

When you use our Services, we may automatically collect certain information, including:

• Website Usage Data: Your IP address, browser type, operating system, referring URLs, pages visited, and timestamps of your visit to our website. We may use cookies and similar tracking technologies to collect this data.
• VR/AR Experience Data:
  • Device Information: The type of VR headset you are using (e.g., Meta Quest, HTC Vive), device ID, operating system, and other technical specifications.
  • Usage and Gameplay Data: Information about your interactions within our Experiences, such as session duration, features used, in-app achievements, and error reports. This data is often aggregated and anonymised.
  • Positional and Movement Data: To enable the VR/AR experience, we process data about your physical movements, such as the position and orientation of your head and hands. This data is typically processed in real-time on your device and is generally not stored or transmitted to our servers unless it is essential for a specific gameplay feature (e.g., a multiplayer avatar’s position) or for aggregated analytics.

3.3. Information from Third-Party Platforms

When you access our Experiences through a third-party platform like the Meta Quest Store, SteamVR, or others, we may receive information from that platform, such as your user ID, username, or entitlement to use our Experience. We do not control the information that these platforms collect from you.

4. How We Use Your Information

We use the information we collect for various purposes, based on a specific legal basis under GDPR:

• To Provide and Maintain Our Services: To operate our website, deliver our VR/AR Experiences, authenticate users, and fulfill our contractual obligations.
  • Legal Basis: Performance of a Contract
• To Improve and Personalise Our Services: To understand how our users interact with our Experiences, identify bugs, analyse performance, and develop new features.
  • Legal Basis: Legitimate Interests
• To Communicate With You: To respond to your inquiries, send you technical notices, updates, security alerts, and administrative messages.
  • Legal Basis: Legitimate Interests, Performance of a Contract
• For Marketing and Promotions: To send you newsletters, special offers, and other information about our Services, but only where we have your explicit consent.
  • Legal Basis: Consent
• For Safety, Security, and Legal Compliance: To protect the rights and safety of our users and third parties, to enforce our terms, and to comply with legal obligations in Cyprus and the EU.
  • Legal Basis: Legal Obligation, Legitimate Interests

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with the following categories of third parties:

• Service Providers: We may share data with third-party vendors who perform services on our behalf, such as cloud hosting (e.g., AWS, Google Cloud), analytics providers, and email delivery services.
• Platform Providers: We may share necessary data with the platforms through which you access our Experiences (e.g., Meta, Valve) to validate your purchase or facilitate platform features.
• Legal Authorities: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
• Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred.

6. International Data Transfers

As we may use global service providers, your information may be transferred to, and maintained on, computers located outside of the European Economic Area (EEA). Where this occurs, we will ensure that adequate protection is in place by relying on mechanisms such as the European Commission’s Standard Contractual Clauses (SCCs) or by ensuring the recipient is in a country deemed to provide an adequate level of data protection.

7. Data Security

We implement appropriate technical and organisational security measures designed to protect the security of any personal information we process. These measures include data encryption, access controls, and secure server infrastructure. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

8. Data Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with Cypriot tax and accounting laws), resolve disputes, and enforce our legal agreements and policies.

9. Your Rights Under GDPR

As a resident of the EEA, you have the following data protection rights:

• The Right to Access: You can request copies of your personal data.
• The Right to Rectification: You can request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The Right to Erasure (Right to be Forgotten): You can request that we erase your personal data, under certain conditions.
• The Right to Restrict Processing: You can request that we restrict the processing of your personal data, under certain conditions.
• The Right to Object to Processing: You can object to our processing of your personal data, under certain conditions.
• The Right to Data Portability: You can request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The Right to Withdraw Consent: You have the right to withdraw your consent at any time where Silversky3D VR LTD relied on your consent to process your personal information.

To exercise any of these rights, please contact us at [email protected].

You also have the right to lodge a complaint with a supervisory authority. The competent authority in Cyprus is the Office of the Commissioner for Personal Data Protection. You can find their contact details on their website.

10. Children’s Privacy

Our Services are not intended for use by children under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we become aware that we have collected personal data from a child under this age without verification of parental consent, we will take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top. We encourage you to review this Privacy Policy periodically for any changes.

12. Contact Us

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

Silversky3D VR LTD 

Address: Eleftheriou Venizelou 21, Agios Dometios, 1105 Nicosia

Company Registration Number: ΗΕ331119 

Email: [email protected] 

Phone: 22252500