First Contact Privacy Policy

Last Updated 9/9/2020

Welcome to First Contact Entertainment Inc. (“First Contact”, “us”, “our” or “we”). We publish virtual reality games and content (“Games”). Our vision and goal is to always innovate on new technologies such as virtual reality, and to create compelling Games and experiences that are fun for all to play. To do that, we need some information about you and your progress in playing our Games. However, protecting your privacy is really important to us. We only use information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have with any websites we own or operate (“Site”), and more generally your use of any of our Games or services (collectively with the Site and Games, the “Services”).

Please be advised that the practices described in this Privacy Policy apply only to information gathered by us through our Services. It does not apply to any information you provide to third-party platforms used to purchase, install, play, connect to, and/or engage with our Games. Please review their privacy policies carefully to understand what information they may collect, process, and use from you.

By using our Services, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services. We reserve the right to modify or amend the terms of our Privacy Policy from time to time. Your continued use of our Services following the posting of changes to the Privacy Policy will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments.

You should also read our Terms of Service which set out the agreement between you and First Contact when you are using one of our Games.

What Information About Me Is Collected and Stored

We may collect certain data directly from and automatically via your use of the Games including non-identifiable game play information from you and/or your device as you use the Games, such as a player telemetry data, play progress or progression, inventory, items collected and/or unlocked, levels achieved, games played, match details, performance stats, team details, achievements, preferred settings, how long the game was played and when, any in-game purchases that might be made via a virtual currency, and other usage statistics. This data is generally anonymized and therefore will not be associated directly with you or your account.

In addition, please note, our Games use third-party platforms like a gaming network and/or hosting service (such as and with limitation the Sony PSVR, Oculus, and Vive platforms) for you to purchase, install, play, connect to, and/or engage with our Games. When you use these third-party platforms for our Games, the third-party platforms may or may not provide us with information about you. For example, although it is not common, we may in certain circumstances receive your name, address, phone number, email address, date of birth, and/or account information. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

Additionally, any communications made using or during the Games should not be considered private. You acknowledge and agree that you have no expectation of privacy concerning the transmission of any user generated content or communications, including without limitation chat, text, or voice communications. Because voice, chat, text, and other communications and user generated content may be viewed and/or heard by other users, users should avoid revealing any personally identifiable information in those communications.

We also do not collect personal information from you when you visit our Site. However, if you choose to contact us via email, we may retain your email and email address along with any other associated information. Doing so is completely voluntary on your part, and you have the choice about whether and what information to disclose via your email.

We may collect certain personal information from you during the course of our normal business operations if you do business with us and/or are employed by us. For example, we may collect certain personal information about you (such as, without limitation, name, email address, date of birth, address, and phone number) either directly from you or from your representative, or from third parties authorized by you.

How We Use and Share Your Information

Use of Information by Us. We may use your information: (1) to improve our Games or Site and to customize your experience with the Games or Site; (2) for internal business purposes; (3) for purposes disclosed at the time you provide your information; (4) to contact you; (5) for internal record keeping; and/or (6) as otherwise set forth in this Privacy Policy or our Terms of Service. 

Third Parties. We may engage vendors, agents, service providers, and affiliated entities to provide services to us. In providing their services, they may access, receive, maintain or otherwise process data on our behalf. Our contracts with these service providers do not permit use of your data for their own marketing and other purposes.

 

Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you as may be permitted or required by law or to prevent or investigate suspected fraud or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct that we believe is inappropriate and inconsistent with generally accepted norms of behavior. 

Access To Your Information 

If for any reason you are concerned that any information you provided to us is not correct and you wish to change or delete it, you have the ability to review and update your personal information to the extent we have it. If you would like to do so, please contact us as set forth below. You may also contact us to request access to, transfer of, or erasure of your personal information to the extent we have any. Specify the nature of your request and the information that is subject to your request.

We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent or request transfer or erasure. Please note that changes or access you request may not be effective immediately. Please also note that despite any request for removal of or change to personal information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. 

Please note, with regards to automatically collected non-identifiable game play information, much of that information will not be associated directly with you or your account, and therefore we may not be able to provide you with access to that information.

Use of Cookies and Other Tracking Technologies

We do not use any cookies for any purpose, including “session” cookies, “persistent” cookies, flash cookies, web storage, web beacons or other technology that tracks you in relation to the Games or Site. 

To the extent any third parties, such as your browser or access provider, may be using cookies, you can also control the use of cookies at the individual browser level as most browsers and mobile devices allow you to change your settings to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept or allow it. Most browsers allow you to disable or delete existing cookies or to automatically reject future cookies. For more information about what cookies or similar technologies those third parties use, please review the third party services’ cookie policies.

Legal Grounds

We rely on the following legal grounds to use your data:

  • Where it is needed to provide you with our Services.

  • Where it is in our legitimate interests to do so, such as: managing our products and services, and providing our Services to you.

  • To comply with our legal obligations.

  • With your consent or explicit consent, where applicable.

  • For a public interest.

 

Your Rights Under Data Protection Laws. 

Here is a list of the rights that individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. 

  • The right to be informed about the processing of your personal information.

  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed.

  • The right to object to processing of your personal information.

  • The right to restrict processing of your personal information.

  • The right to have your personal information erased (the “right to be forgotten”).

  • The right to request access to your personal information and to obtain information about how we process it.

  • The right to move, copy or transfer your personal information (“data portability”).

  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

 

If you have any questions or concerns regarding these rights please contact us via the contact information below.

How Long Is Your Personal Information Retained By Us. 

We keep your information for as long as we need it to provide the Services to you and fulfil the purposes set out in this Privacy Policy and our Terms of Service. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will remove it from our systems to the extent it is not anonymized so that it is not associated with you. 

What Steps Are Taken To Keep Information Secure

We exercise great care in providing secure transmission of your information from your device to our servers. Information collected by our Services is stored in secure operating environments that are not available to the public. Please understand, however, that while we try our best to safeguard your information once we receive it, no communication of data can be guaranteed to be 100% secure. 

How Can We Transfer Your Personal Information

Your information collected through the Services may be stored and processed in the United States or any other country in which we or service providers maintain facilities. We may transfer information that we collect about you across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the United States or other regions with laws governing data collection and use that may differ from US law, please note that we may transfer information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Wherever your personal information, if any, is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

 

Assignment

We may change our ownership or corporate structure while providing the Services. We may also sell certain assets associated with the Services. As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

What Are Your Choices and How Do You Opt-Out?

We believe you should have choices about the collection, use and sharing of your information. Although you cannot opt-out of all data collection when you use our Games, you may be able to limit the collection, use and sharing of your information. As described above, we do not collect any of your personal information. If you have any questions about this Privacy Policy, you should contact us by email at contact@firstcontactent.com.

Your California Privacy Rights 

The CCPA grants California residents certain privacy rights regarding the personal data we collect. We are committed to respecting these rights and complying with the CCPA. Under the CCPA you have the right to request that we disclose to you what personal data we collect, use, disclose, and sell. The CCPA also gives California residents a right to opt-out from the sale of their personal data. You also have the right to request deletion of personal data that is in our possession, subject to certain exceptions. Please note that your request to delete data may impact your use of the Games in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA. Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

As described above, we do not directly collect any of your personal information. Similarly, we do not sell personal data and have not done so in the past 12 months. However, if you would like more information on what, if any, personal data we have, please send an e-mail to contact@firstcontactent.com

Children's Privacy

We do not knowingly collect or maintain personal information from persons under 13 years of age. If you are under 13 years of age, then please do not use or access the Games at any time or in any manner. If we learn that information of persons under 13 years of age has been collected on the Services without verified parental consent, then we will take the appropriate steps to delete this information. Teenagers under the age of 17 and over the age of 13 should encourage their parents to review this policy and to contact us if they would like to evoke our opt-out policy or to raise any concerns.

Contacting Us

If you have any questions about this Privacy Policy, or have inquiries about your personal data, please contact at: contact@firstcontactent.com and/or First Contact Entertainment Inc., 30699 Russell Ranch Rd., Suite 170, Westlake Village, CA 91362.

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