PRIVACY POLICY

1. General

We are Milvus Volante Corp.. (or “Milvus Volante”). Protecting your privacy is really important to us. We only use information that can or could be used to identify you, relates to you or could be reasonably linked to you, directly or indirectly (“Personal Data”) where we have a legal basis to do so. This Privacy Policy will help you understand what Personal Data we collect, how we use it and what choices you have when you play any of our games or use any of our apps, use our websites, buy merchandise from us, or take part in live events and promotions (the “Services”).

Our Privacy Policy is designed to give you a comprehensive understanding of the steps that we take to protect the Personal Data that you share with us, and we would always recommend that you read it in full.

You should also read our Terms of Use which set out the contract between you and Milvus Volante when you use our Services.

2. Who decides how your information is used?

Milvus Volante Corp.. (2nd Floor, Ellen L. Skelton Building, Fishers Lane, Road Town, Tortola, British Virgin Islands, VG 1110) generally is the data controller responsible for making decisions about how we use your personal information. If you have any questions or comments on this policy, you can contact our Data Protection Officer by email at operations@so-vigilantes.com

If you have any questions or comments on this policy, you can:

Email us our Contact our Data Protection Officer at operations@so-vigilantes.com

3. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you or is linked or reasonably linkable to you (“Personal Data”). This Privacy Policy does not apply to the Personal Data that we process on behalf of our customers pursuant to a written agreement we have entered into with such customers (“Customer Data”). Our customers’ respective privacy notices or policies govern their collection and use of Customer. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy.

This Privacy Policy covers our use of your Personal Data.

We need to collect and use certain Personal Data to provide the Services to you and fulfill the promises we make to you in the Terms of Service:

• Some of our Services require you to register with us or sign up for an account before you can use them. Where this is the case, you provide us with information including the confirmation that you are not a child and the in-app username that you choose to use on our Services. We collect and use this information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services.
• You may be required to have an account with a supported external single sign-on service in order to use some of our Services. Where this is the case, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Milvus Volante Services.
  • If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.
• Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
• We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for participating Services, while you are not directly interacting with these Services), including how you move around and events that occur during in app activity or gameplay. Our Services include location based games whose core feature is to provide an experience tied to your real world location, so we need to know where you are to operate these apps and games for you, and to plan the location of in-game or in-app resources. We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Services through, and mobile/cell tower triangulation.
• We also collect and use your in-game or in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to operate the Services for you and to personalize your gameplay and user experience. We will also generate an internal account ID when you use certain Services to associate you with an account.
• We can use the information above to show in-game sponsored locations that are in your vicinity as part of the gameplay experience.
• We further use the information above in order to provide technical and customer support to you.
• You also give us Personal Data when you make a purchase through us, subscribe to our publications, register for a live event, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, age, and email address. We use that information to fulfill those Services to you and to provide related customer support to you and to perform system maintenance and debugging
• Our games and apps include innovative features which allow you and other players to view and interact with the same virtual objects at the same time in a shared physical space. They also allow you to leave persistent virtual objects at real world locations, so other players can see them even when you are not there, and so you can see them when you return. In order to provide you with these AR experiences, Milvus Volante needs to collect geospatial data and images from your device camera and sensors during your AR experiences.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

• Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, age, as well as actions you take during gameplay, your in-app user settings, preferences, and your in-app purchases to learn about our users, and understand who is using our Services and how.
• Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
• Using your internal account ID and in-game username in order to attribute to your account any user content (such as local points of interest) that you elect to submit to Milvus Volante through the Services.
• Using your email address in order to share updates and news with you by email. You can unsubscribe from these at any time.
• Analyzing your in-game actions and achievements to show you rewards, promotions, or other offers about our Services that are tailored to your personal user experience. You can choose to opt out of this and certain other processing of your Personal Data by following the steps described in Section 7 (“Your rights and choices”).
• We collect content you contribute such as images, text, and/or video to provide social features within our games and apps so you can interact and play with other players, including storing and displaying your communications, content, and other information shared with those players, finding your friends and being found by them, and sharing your gameplay or in-app experience and achievements with your friends or other players. If you elect share images or scans of real world public places on our services with associated location information, we may use that information to improve our products and services, including for the training of machine learning and AI models, but only after anonymizing the scans through various means, including blurring. We use a mix of automated and manual review to detect and moderate content you contribute to our Services to protect Milvus Volante, or to protect the rights and safety of others.

• To improve the features that we offer you through the Services, or to provide you with new or additional features for our Services.
• To organize and run live events based on or featuring our games. Note that when you participate in live events your in-game actions and achievements, in-game username and your avatar, team, and other components of your in-game profile will be visible to other event participants and to the public (for example on leaderboards displayed at the event and online).

• Using your in-app actions and achievements, transactions, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to carry out anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service, to prevent abuse, and to provide a fair gaming experience to all players.
• To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.
• We’re passionate about AR and make use of the Niantic Spatial Platform SDK Niantic Spatial make their technology available to other developers, like Milvus Volante, who feel the same so that we too can create and publish exciting AR experiences for you to enjoy. By using the Milvus Volante Services (considered a third-party game or app), Niantic Spatial Platform SDK has legitimate interest in collecting and using the Personal Data described above in order to operate the AR features in the games and apps. This includes your location, as well as geospatial data and images collected from your device camera and sensors, while you use these AR features.

We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

While you may disable the usage of cookies through your browser settings, Milvus Volante currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

4. Who we share information with

We will not share any Personal Data that we have collected from or about you except as described below:

Personal Data Shared with Our Service Providers.
We engage external Service Providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external Service Providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The Service Providers we use help us to:

• run, operate, improve and maintain our Services through third-party platform and software tools;
• perform content moderation and crash analytics;
• run email and mobile messaging campaigns;
• perform game, app, and marketing analytics;
• prevent and detect fraud, abuse, or other harm;
• provide measurement and advertising services to us, including by targeting ads on third-party sites outside the United States (you can opt out of these third party ad targeting services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
• administer live events, competitions, sweepstakes and promotions, including registering players, managing check-in and attendance, verifying eligibility and prize fulfillment;
• provide payment attribution;
• provide technical and customer support; and
• process payments for live events ticketing or other purchases.

Some external service providers may also collect Personal Data directly from you (for example, a payment processor may request your billing and financial information) as a Third-Party Service in accordance with their own privacy policy. Such external Third-Party Service does not share your financial information, like credit card number, with Milvus Volante, but it may share limited information with us related to your purchase, like your zip or postal code.

Personal Data Shared with Other Players or Users.
When you use the Services, and in particular when you play our games, use social features within those games (including cross-game features), or take part in live events, we will share certain Personal Data with other players or users. This Personal Data includes your in-game or in-app profile (such as your username, your avatar, your online status, and your team), your in-game or in-app actions and achievements, real-world locations associated with your gameplay, or which gameplay resources you interacted with when playing the game, and your in-game messages and related content you share with other players or users. Additionally, certain games or apps link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services; Milvus Volante does not control and is not responsible for the practices of these third-party sharing features.

Information Shared Publicly
When you use the Services, and in particular when you play our games, use competitive features, contribute content or participate in our forums, the following Personal Data about you may be shared on web pages accessible to the public and therefore become publicly available: your username, in-game or in-app profile, achievements, groups, meetups, and public messages.

Personal Data Shared with Third Parties.
We share de-identified data with third parties for performance, industry, and market analysis. We do not share Personal Data with any third parties for their direct marketing purposes.

Personal Data Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share Personal Data about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate:

1. to respond to claims, legal process (including subpoenas and warrants);
2. to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; or
3. to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Personal Data Disclosed in Connection with Business Transactions.
Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third-party acquirer in connection with the transaction.

5. How your Personal Data is transferred

Milvus Volante operates its Services across the globe. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the EEA, the UK, or Switzerland to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA, the UK, or Switzerland.

6. How long we will keep your Personal Data

Milvus Volante maintains policies and procedures surrounding the retention of your personal data. The criteria used to determine our retention periods varies based on type of personal data, including, but not limited to, legal requirements to retain personal data in certain jurisdictions and retention limitation periods under applicable laws. We also keep your Personal Data for as long as we need to provide the Services to you and fulfill the purposes set out in this Privacy Policy. This is also the case for anyone that we share your Personal Data with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

7. How we keep your Personal Data safe

We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Your rights and choices

Under applicable laws, you have certain rights in relation to your Personal Data. Milvus Volante offers these rights to all users, regardless of where they live. This means you can:

• Request access to the Personal Data we hold about you by submitting a request by emailing us at operations@so-vigilantes.com.
• Delete or correct your Personal Data. You can email us at operations@so-vigilantes.com
• Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes such as tailored rewards, promotions, and other offers, by emailing operations@so-vigilantes.com. But be aware that sometimes we need to use your Personal Data in order to provide the Services to you.
• Have your Personal Data transferred to another organization (where it is technically feasible).
• Complain to a regulator. We’d appreciate the chance to deal with your concerns directly so we’d prefer you to contact us first. However, if you’re based in the EEA, the UK, or Switzerland and believe that we have not complied with data protection laws, you can complain to your local supervisory authority.
• If you’re based in the EEA, you can also contact our EU Representative, EDPO. EDPO can be contacted:
  • by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
  • by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction.

We will not discriminate against you if you exercise any of these rights.

9. Children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not knowingly collect Personal Data from them. We define “children” as follows:

• Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
• Residents of the Republic of Korea, anyone under 14 years old.
• Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.

If we learn that we have collected Personal Data of a Child, we will take steps to delete such information from our files as soon as possible.

10. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

11. Third parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third-Party Service”). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-Party Services that you access.