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Last Updated: April 19, 2021

ArborXR Privacy Policy

The Purpose of this Document

ArborXR is committed to transparency and protecting the privacy and security of your personal information. This privacy policy ("Privacy Policy") will explain our privacy practices, including how we collect, use, share and store your personal information and your rights and choices with regard to controlling your personal information in connection with the use of ArborXR Services, including our Website. Any capitalized term that is not defined herein shall have the meaning ascribed to it in the ArborXR Terms of Services ("Terms") or the document incorporating the Privacy Policy by reference.

Who is Who

ArborXR. ABXR Labs, Inc. d/b/a ArborXR is referred to in this Privacy Policy as "ArborXR" or "we" or "us". Our business address is 3750 West Main Street, Suite AA, Norman, Oklahoma 73072 USA. We offer a software platform and services for the distribution of virtual reality content and the management of virtual reality games and experiences.

You. In this Privacy Policy, we sometimes refer to "you, which includes all users of the Services such as a Customer, an Authorized User, or an End Users, or someone engaged in a business relationship with ArborXR such as an employee or contractor (collectively, "Data Subjects").

Third-Party Services. Our Services may contain links to or enable services provided by Third-Party Services. Our Services may be provided through, integrated with, access and/or utilize content, features, functionalities, and services operated by these Third-Party Services. We may share and receive information about you from these third parties in order to provide you with access to the Third-Party Services, our Services , or for support of our Services. We do not control these Third-Party Services and their policies regarding the handling of information may be different from ours. You are responsible for reviewing the privacy statements and policies of the Third-Party Service providers you choose to link to or from the Service, so that you can understand how those third parties collect, use, share and store your information.

Data Controller and Data Processor

Data Controller. ArborXR is the Controller and responsible for the personal information processed by the Services.

Data Processor. We may collect, use, and disclose certain personal information about you when we act as a service provider. If you are a Customer, you are responsible for making sure that your privacy rights and the privacy rights of your Authorized Users and End Users are respected, including ensuring appropriate disclosures about third party information collection and use. To the extent that we are acting as a data processor, we will process personal information in accordance with the terms of our agreement with you.

Other Important Information

It is important that you read this Privacy Policy together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

By accessing or using the Services you agree to this Privacy Policy.

If you disagree with the practices described in this policy, you should (a) take the necessary steps to remove cookies from your computer after leaving our Website, and (b) discontinue your use of our Services.

You must be of legal age in your jurisdiction for entering into a binding contract, and in any event, at least 16 years of age. If you are between the ages of sixteen (16) and eighteen (18) years of age, please review this Privacy Policy with your parent or guardian. Your parent or guardian should agree to the collection and use of your personal information in accordance with this Privacy Policy on your behalf.

Information We Collect

Personal Information. We call information that identifies, or that could reasonably be used to identify, you as an individual "Personal Information" or "Personal Data". Personal Information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The information that we collect automatically, including statistical data, may not include Personal Information, but we may maintain it or associate it with Personal Information that we have collected or received from third parties.

The Personal Information that we may collect includes:

Non-Personal Information. We also collect information that is not Personal Information, and we call it Non-personal Information.

Non-personal Information includes:

How We Collect Information

Directly from You. The information we collect may come directly from you when you provide it to us:

As You Use Our Services. As you use or interact with our Services, we may collect certain information that may contain Personal Information or Non-Personal Information that we may tie to Personal Information collected from other sources.

Cookies and Web Beacons. Our Services use browser cookies to distinguish you from other users. A browser cookie is a small file placed on the hard drive of your computer to identify your browser or device and to collect and store information when you use our Services. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain features or functionalities of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you direct your browser to our website or interact with our Services. To learn more about the cookies served through our Services, please see our Cookie Policy.

We may also use a web beacon to collect information. A web beacon is a small electronic file that may be contained on pages of our website and our emails that allow us, for example, to count users who have visited those pages or opened an email and to gather other related website statistics.

If You Fail to Provide Personal Information. Where we need to collect Personal Information under the terms of a contract we have with you or by law, and you fail to provide that information when requested, we may not be able to perform the contract we are trying to enter into with you. In that event, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

How We Use Information

We will only process your Personal Information when the law allows us to do so and in accordance with this Privacy Policy. We will use your Personal Information on the following legal bases:

Some of the legal basis or grounds for processing information will overlap and there may be several grounds to justify the processing of your Personal Information. The situations in which we will use your Personal Information and the lawful basis for processing that information are listed in the table below:

Use or Purpose Type of Personal Information/Data Processed Lawful Basis for Processing
To provide and maintain our Services Identity, Contact, Technical, Payment, Transaction, Third-Party Services, Employment, Marketing and Communication
  • Performance of a contract your consent
  • Necessary for our legitimate interest
Monitor and analyze use and functionality of our Services Technical, Transaction, Marketing and Communications
  • Performance of a contract
  • Necessary for our legitimate interest
Gain a better understanding of your usage patterns for our Services Identity, Technical, Transaction, Cookie, Marketing and Communications
  • Performance of a contract
  • Your consent
  • Necessary for our legitimate interest
Improve your user experience with our Services Identity, Contact, Technical, Payment, Transaction, Marketing and Communication
  • Consent
  • Necessary for our legitimate interest
Provide customer, technical and administrative support Identity, Contact, Technical, Payment, Transaction, Employment, Marketing and Communication
  • Performance of a contract
  • Necessary for our legitimate interest
Process e-commerce transactions Identity, Contact, Payment, Transaction, Technical, Employment
  • Performance of a contract
  • Necessary for our legitimate interest
Communicate information about us and our Services Identity, Contact, Technical, Marketing and Communication
  • Performance of a contract
  • Your consent
  • Necessary for our legitimate interest
To notify you about changes to our Services and to make recommendations to you about products or services that may be of interest to you based on your interaction with the Services and/or our other products and services Identity, Contact, Technical, Transaction, Marketing and Communication
  • Performance of a contract
  • Necessary for our legitimate interest
Streamline your onboarding process and the use of our Services Identity, Contact, Technical, Payment, Third-Party Services, Marketing and Communication
  • Performance of a contract
  • Your consent
For the administration of files, records, and reporting, including accounting Identity, Contact, Technical, Payment, Transaction, Employment
  • Performance of a contract
  • Necessary for our legitimate interest
  • Necessary to comply with a legal obligation
To engage, hire and onboard consultant, contractors and employees Identity, Contact, Technical, Payment, Employment
  • Performance of a contract
  • Necessary for our legitimate interest
  • Necessary to comply with a legal obligation
To ensure compliance with this Privacy Policy and our other terms of use regarding our Services Identity, Contact, Technical, Payment, Third-Party Services, Transaction, Marketing and Communications
  • Performance of a contract
  • Your consent
  • Necessary for our legitimate interest
To prevent fraud or comply with applicable laws, regulations, and enforcement agency requests Identity, Contact, Payment, Transaction, Technical
  • Necessary for our legitimate interest
  • Necessary to comply with a legal obligation
To fulfill any purpose described with your consent Identity, Contact, Payment, Transaction, Technical, Marketing and Communication
  • Your consent

Marketing and Promotional Offers From Us. We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or registered a User Account with us or if you provided us with details when you signed up for our mailing list, and in each case, you have not opted out of receiving that marketing.

Opting Out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Please note that we may still send you important administrative messages, notices or alerts that are required to provide you with our Services. ArborXR does not control the marketing communications or lists maintained by third parties not at the request of ArborXR. To opt-out of marketing communications sent by third parties not at the request of ArborXR you must use the third-party opt-out link contained within such marketing communication.

Disclosure of Information

In connection with our operations, we may share Personal Information that we collect from you or you provide to us, as further described in this Privacy Policy, with the following trusted parties:


We have implemented reasonable organizational, technical, and administrative measures designed to protect your Personal Information within our organization. We limit access to your Personal Information to those employees, contractors, consultants, or third parties who have a business need to know such information. They are contractually bound to only process your Personal Information on our instructions and they are subject to a duty of confidentiality. Unfortunately, even with these measures, no data transmission or storage system can be guaranteed to be totally secure. By using our Services, you acknowledge and agree that we make no such guarantee, and that you use our Services at your own risk. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

While we are dedicated to securing your Personal Information and our systems and the Services, you are responsible for securing and maintaining the privacy of your User Credentials and Account information and for verifying that the Personal Information we maintain about you is accurate and current. It is your responsibility to give us current, complete, truthful and accurate information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information, or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.


We will retain Personal Information for the period necessary to fulfill the purpose we collect it for unless a longer retention period is required or permitted by law. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means, and the applicable legal requirements. By law for tax and business purposes, we may have to keep basic data about you for 7 years (or the applicable retention period permitted by law) even after they cease being such individuals.

Rights of Access, Correction, Erasure and Restriction

In regard to your Personal Information, under certain circumstances, by law you have the right to:

If you want to review, verify, correct or request erasure of your Personal Information, object to the processing of your Personal Information, or request that we transfer a copy of your Personal Information to another party, please contact us by email at [email protected].

We may need to verify your identity before acting upon your request and we may have to retain certain information for legitimate business or legal purposes. In addition, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Generally, we will respond to your request within 30 days from the date you contact us or sooner if otherwise required by applicable law.

Right to Withdraw Consent

In limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for processing at any time. To withdraw your consent, please contact us at [email protected]**. **** Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.**

Children Under the Age of 16.

Our Services are not intended for children under 16 years of age and we do not knowingly collect Personal Information from children under 16. No one under age 16 may provide any Personal Information to the Services. You shall not disclose to us any personally identifiable information from anyone under the age of 16 unless you have express parental permission to do so. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

Jurisdiction and Cross-Border Transfers.

Our Services are global so please be aware that your Personal Information and communications may be processed and stored in any country where we have operations or where we engage service providers, and we may transfer information to countries outside of your state, province, or country of residence, including the United States, which may be located outside of the European Economic Area ("EEA") and/or have data protection rules that are different from those of your country. We will take measures to ensure that your information remains protected to the standards described in this Privacy Policy.

European Union Data Protection. If you are located in the European Union ("EU") or the EEA, transfer of personal customer data outside of the EU or EEA is regulated by certain EU data protection laws. When required in order to effectuate the transfer of personal data, ArborXR has entered into a Data Processing Addendum ("DPA") with its Customers that includes EU Model Clauses which are standardized contractual clauses used to ensure that personal data leaving the EEA will be transferred in compliance with these laws.

Notice to California Residents/Your California Privacy Rights. If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as "unsubscribe") or opt-in for use of your information by third parties for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year. If you are a California resident and you wish to request information about how to exercise your third party disclosure choices, please submit your request at [email protected] or by postal mail to 3750 West Main Street, Suite AA, Norman, Oklahoma 73072, Attn: Your California Privacy Rights. All requests must be labeled "Your California Privacy Rights’’ on the email subject line or envelope or postcard. For all requests, please clearly state that the request is related to "Your California Privacy Rights’’, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Data Supervisory Authority

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concern before you approach the ICO so please contact us in the first instance.

Changes to This Privacy Policy

We may change this Privacy Policy. The "Last Updated" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. The new version will become effective on the date it’s posted. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates. If the changes are significant, we may notify you by posting an alert on our website, or if you are a user, contacting you through our Services or by email listed on your Account. You are responsible for ensuring we have an up-to-date deliverable email address for you and/or for periodically visiting the Services and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: [email protected] or at:

ABXR Labs, Inc.
3750 West Main Street, Suite AA
Norman, Oklahoma 73072
Attention: Legal