Next Gen XR SDK for iOS
3D + Interactive AR & VR

Emcore3D Privacy Policy




Last updated: 9 May, 2019

Things3D Ltd (“THINGS3D”) offers the Emcore3D Software Development Kit (“EMCORE3D”) to App Developers (“DEVELOPERS”) that will be referred to in this policy as the “Service” or “Services.” The policy refers to Things3D as “we” or “us” and to the reader as “you.” When we say “device,” we mean any device, including desktop, laptop, PC or Mac computers, smartphones, tablets, or any other device that is used to access or interact with the Service. When we App Developers we mean a third party that develops and/or distributes a game or other app made with EMCORE3D. By using the Service, you agree to this Privacy Policy (“Policy”). This Policy governs our information practices for the Service, which includes any websites, where a link to this policy is provided. It describes how we collect, use, share, and protect information from Developers, players, or people browsing or using our sites (collectively “Users”) when Users access or interact with or use our Service. This includes when Users:

1. Visit www.emcore3d.com;
2. License and integrate EMCORE3D
3. Download EMCORE3D from GitHub
4. Play games or use applications developed by DEVELOPERS using EMCORE3D;

We receive information about Users, their devices, locations and interactions with the Service primarily in two ways:

1. Actively: When Users actively provide us with information. For example, when a User creates an account with EMCORE3D, he or she will type in a name, email address and may be required to provide a date of birth or other information.
2. Passively: When our systems automatically collect information about browsers, devices, and certain activity within the Service. For example, in order to combat piracy, EMCORE3D may automatically collect a variety of information from User devices including device name, device characteristics, and unique identifiers (e.g., Apple IDFA) and reconcile against our digital rights management system to ensure that EMCORE3D is correctly licensed.

Why Have We Created This Privacy Policy?

We understand that privacy is extremely important. As such we are committed to ensuring that all personal information is processed in accordance with applicable privacy and data protection laws. This policy is part of and subject to our Terms of Service for the EMCORE3D Services which we ask you to read carefully. By using the Services you are agreeing to be bound by this policy in respect of the information collected about you via the Services and you consent to the use and disclosure of that information as described in the Policy.

What Information Do We Collect?

As and when you visit, browse or use Services we may collect certain Information from you. Some of this Information may be Personal Identifiable Data and some of the Information may be Anonymous Information. We will only use your Information in accordance with the terms of this Policy.

Developer Registration

In order to register the use of EMCORE3D, you are required to provide certain information about yourself. This could be one or more of the following items of Personal Identifiable Data:

• Your name,
• Your email address,
• Your age
• Your post code,
• Your country of residence,
• Username and password.


If you choose to email or write to us about the Services, or you fill in an on-line contact or support request form available on the EMCORE3D Website, we may collect Information about you from the content of your letter, email or other message e.g. your name, your email address, and what you like or dislike about EMCORE3D.

If you participate in a competition or promotion, or respond to a survey or feedback request then in addition to your entry or response we may collect your name, email and/or other contact details. Our use of your Personal Identifiable Data will always have a lawful basis, either because it is necessary for our performance of a contract with you ( e.g. to carry out a user action you have requested), because you have consented to our use of your Personal Identifiable Data (e.g. by subscribing to emails), or because it is in our legitimate interests.

Specifically, we may use your Information for the following purposes:

• to enable us to provide you with all features and functionality of the Services and to enable you to use EMCORE3D;
• to provide you with personalised content and promotional communications that you are happy to receive from the Services;
• to provide customer service in relation to your use of the Services, e.g. service updates, responding to support requests;
• generally to administer, support, analyse, improve and develop the Services, including automatically updating EMCORE3D, preventing, or otherwise addressing fraud, security or technical issues; and
• as otherwise described in this Policy.

Digital Rights Management (DRM)

In order to combat piracy, the EMCORE3D DRM may automatically collect a variety of information from User devices including device name, device characteristics, and unique identifiers (e.g., Apple IDFA) and reconcile against our digital licensing database to ensure that EMCORE3D instance in the app is correctly licensed and registered.

Our servers will automatically collect information from your device, including the following:

• an app id and/or name
• the IP Address linked to the device
• the date and time;
• the make and model of your device (including operating system version);
• the version of EMCORE3D being used

Website

Our website (www.emcore3d.com) will automatically record and store information created by your access and use of the website through the use of cookies. This may include information about your device, your IP Address, browser type, the pages that you visit, time spent on pages and other statistics.

Marketing Communications

We may use your Information to send you notifications and information about the Services and other THINGS3D products and services we think may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. If at any time you no longer wish to be contacted for this purpose, please let us know and we will remove you from our mailing list. Please note that You may not opt out of service related emails as these are necessary for the security and performance of the services.

How And Where Will Your Information Be Processed?

We use Amazon Web Services (“AWS”) to store and process data on our behalf in connection with the Services. We primarily use AWS servers located in Ireland to store and process your Information; however Amazon AWS also use various servers located around the world to cache data locally and speed up access to Content.

Users Located In The European Union

If we transfer any of your Personal Identifiable Data outside the European Economic Area (EEA) we shall take all steps reasonably necessary to ensure that your Personal Identifiable Data is adequately protected by only using processors who comply with EU data protection laws. If you use the Services while you are outside the EEA, your Personal Identifiable Data may be transferred to countries outside the EEA (including the United States) to enable us to provide you with those services. As the apps powered by EMCORE3D may be available for use internationally it is possible that any Personal Identifiable Data contained may be automatically transferred by our servers to a device, server or other computer equipment being used in a country outside the EEA where they have a different level of data protection. By using the Services you specifically give your consent to the international transfers referred to in this section.

When Might Things3d Share Your Information With Others?

Other than as expressly set out in this Policy or as otherwise required or permitted by law or regulatory requirement, we will not share, sell or transfer any of the Information you provide to us without your consent. We may disclose Your INFORMATION to or share it with the following:

• other users where you allow Information to be made public;
• social media services you choose to share Information with;
• any third party to whom disclosure is necessary to enable us to provide you with the Services including our server provider(s);
• other companies that we have hired to provide services on our behalf e.g. providers of analytics services and customer relationship management tools;
• any third party to whom disclosure is necessary to protect the rights, property or safety of the Services, its users and the public. This includes exchanging Information with other companies and organisations for fraud protection and spam prevention;
• any person to whom disclosure is necessary to enable us to enforce our rights under this Policy or under our Terms of Use;
• any prospective purchaser of THINGS3D, its parent company, or the Services or any part thereof (see below);
• any subsidiary or holding company of THINGS3D or any subsidiary of any such holding company for use by them in accordance with this Privacy Policy; and
• other outside parties (e.g. judicial or regulatory authorities) to comply with the law and legal obligations.


Controlling The Use Of Your Information
By submitting your Information, you consent to the use of that Information as set out in this Policy. You may withdraw your consent for THINGS3D to process your Personal Data for direct marketing purposes at any time by notifying us in writing (an email will suffice, or using the contact us form). You are always free to opt-out from the future collection of your Personal Data by THINGS3D in accordance with this Policy by uninstalling any applicable App(s) which use EMCORE3D from each of your devices and discontinuing use of the SERVICES.

Changes Of Business Ownership And Control

THINGS3D may from time to time expand or change our business and this may involve the sale and/or the transfer of control of all or part of THINGS3D or the THINGS3D Services. Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part as one of the transferred assets. The new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Information for the purposes for which it was originally supplied to THINGS3D. We also reserve the right to disclose de-identified user data to the prospective buyer of such business or assets.

Links To Non Emcore3d Services

The Services may contain links to microsites, websites and/or other on-line services that are operated by third parties (i.e. businesses other than THINGS3D) (collectively, “Third Party Services”). THINGS3D has no control over these Third Party Services and is in no way responsible for their content, or information collection practices. This Policy does not apply to your use of any Third Party Services. Please consult the terms, conditions and privacy policies of any Third Party Service you choose to access to find out how they will collect, use and share your personal information and to establish whether and for what purpose they use cookies and similar technologies. Please remember that some Third Party Content contained on (or accessible via) the Services may operate as links to that third party’s website(s) and as such any information they collect by virtue of your clicking on that link will be collected and used in accordance with the privacy policy of that third party.

Keeping Your Personal Data Secure
To protect your Personal Identifiable Data from unauthorised persons and against unlawful processing, accidental loss, destruction and/or damage we have put into place commercially reasonable physical, electronic and managerial security counter measures ; • The Information you send THINGS3D is protected by SSL/TLS end-to-end encryption when transmitted from your servers to our servers. • Information stored on our servers is protected by encryption, key authentication and by firewalls. Only authorised employees are allowed access to Your Information. Further such employees are obliged to preserve the confidentiality of all information that comes to their attention unless disclosure is compulsory by law or necessary for the fulfilment of their duties.


Despite the above security measures THINGS3D cannot 100% ensure the security of your Information or guarantee that your Personal Data will not be accessed, disclosed, altered or destroyed by an unauthorised person who is determined to circumvent our security measures.

How Long Your Personal Data Is Retained

THINGS3D will retain your Personal Identifiable Data for the duration of your use of the Services and for a reasonable period thereafter. These are for the purposes of backup, archive and/or audit purposes or for as long as the law otherwise requires or permits.

Can I Access My Personal Data?

Yes- you have the right to ask for a copy of any of your Personal Data where such data is actually held by us and we can identify who you are. We will normally provide copies in response to your request free of charge. That said, we reserve the right to charge a reasonable fee for requests which are manifestly unfounded or excessive, particularly if it is repetitive and for further copies of the same information. Please note that we will ask you to provide proof of your identity before we disclose any Information to you.

Children’s Privacy And The Children’s Online Privacy Protection Act (COPPA)

This Policy section only applies if any Services are accessed from within the USA or any other country which requires parental consent to be obtained before any collection of personal information from a child under the age of 13. THINGS3D does not knowingly collect or solicit personal information from children under the age of 13. The Services and their Content are not intentionally directed at children under the age of 13 and we do not target children under 13 as our primary audience. In the event we learn that we have inadvertently collected personal information from a child under the age of 13, and that child lives in a country which does not permit such collection without prior parental consent, we will delete that information as quickly as possible. If a parent or legal guardian becomes aware that their child under the age of 13 has provided us with personal information without prior parental consent, please contact us we will delete such information from our files.

Use Of The Emcore3D Powered Apps By Young Children

Parents and guardians - please be aware that apps and games built with the Services may be a general audience service (i.e. Developers using EMCORE3D to power their 3D augmented reality functionality may use EMCORE3D to render any renderable 3D model) and provide a wide variety of content and experiences some of which may be of a nature unsuitable for young children. THINGS3D has no control over this. Further, the Third Party Developer app can potentially be accessed and viewed by anyone. If you have any concerns, you may wish to monitor your child’s use of the Third Party Developer App and THINGS3D recommends that you do not allow your child to use these Third Party Developer Apps with such unsuitable materials.

Changes To Our Privacy Policy

The Services, our collection and use of Personal Identifiable Data and the laws and regulations which apply will change over time. THINGS3D reserves the right to make changes to this Policy. If we do, the changes to the Policy will be posted to this Website – we will change the “Last Updated” date shown at the top of the page. You are deemed to have accepted the wording of the amended Policy on your first use of any Services following the changes. We encourage you to visit this page from time to time for the latest on our information collection practices.

Contacting Us

If you have any questions about the Services or this Policy, please contact us by email, by online form or by post using the details below. Please ensure that your query is clear, particularly if it is a request for information about the Personal Identifiable Data we hold about you.

Postal Address:

Data Protection Officer
Things3D Ltd
Suite 30-31 Beechfield House
Winterton Way
Macclesfield
SK11 0LP
Cheshire
United Kingdom

Applicable Law

Irrespective of which country you live in or submit Information from the law which applies to this Policy shall be the law of England and Wales.