Last Updated: November 8, 2021

LLVR Systems LLC d/b/a Jedburgh. (“Jedburgh,” “we,” “us,” and “our”) provides an online platform allowing our customers to learn a foreign language from anywhere in the world using virtual reality. Our Privacy Policy (“Privacy Policy”) is designed to help you understand our practices regarding the collection, use, and disclosure of certain information, including your personal information, and to assist you in exercising your privacy rights.

 

SCOPE

This Privacy Policy applies to information processed by us in the course of our business, including on our websites (the “Sites”) and applications (the “Apps”).

 

INFORMATION WE COLLECT

When you use our applications, we may collect the following kinds of information:

 

INFORMATION YOU PROVIDE TO US

Account Information. When you sign up for an account with our applications, you will provide us with personal information (also known as “personally identifiable information” or “personal data” under applicable laws). This may include your name, email address and possibly address of your employer and your role at the employer. We may further collect necessary personal information about authorized users whom you authorize to use the applications on behalf of your employer.

Your Communications with Us. We collect personal information from you such as your email address, name, employer or other company or organization with which you are associated, VR device type, and purchasing plans when you request information about our applications, request customer or technical support, or otherwise communicate with us. A contact form is available on our Website which can be used to contact us electronically. On our Website we use a Hubspot CRM, an integrated software solution by which we cover different aspects of our digital marketing, sales and customer relation management. Furthermore, we use the tool for analytical purposes of our web offer in order to optimize it and to offer you the best possible and user-friendly service. For this purpose, we forward your data to Hubspot, which processes the data exclusively at our request. All data required to complete the contact form is subject to the principles of data reduction and data economy, meaning you only have to provide the data that is absolutely necessary for processing inquiries and making contact.

Virtual Training Environments. When you use our applications, you can occupy virtual training environments (“VTE”) and visit VTEs created by others. The applications allow you to upload images, documents, slides, attachments and other digital content (collectively, “Content”) into the VTEs so that you may easily share and collaborate with other individuals. We collect and store data describing the VTEs and the Content uploaded to the VTEs.

Teleconferencing. The applications allow you to teleconference with other users within the VTEs using the sensors on your AR/VR device. When you do this, audio of your voice will be captured by us and provided to other users along with an avatar constructed by you to enable VR teleconferencing. We also collect and store usage information describing teleconferencing activities within the VTEs, such as the number of files uploaded, times and durations of the teleconferences, and the anonymized identities of the users who participated in the teleconferences.

 

 

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

 

Conferences and Trade Shows. We may attend conferences and trade shows where we collect personal information from individuals who interact with or express an interest in Jedburgh applications. If you provide us with any personal information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

 

INFORMATION COLLECTED AUTOMATICALLY

 

Automatic Data Collection. We may collect certain personal information automatically when you visit the website. This personal information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based on your IP address), Internet service provider, pages that you visit before, during and after using the applications, information about the links you click, information about how you interact with the applications, including the frequency and duration of your activities, and other information about how you use the applications. Personal information we collect may be associated with accounts, other devices, Rooms, and teleconferences.

 

Cookies, Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the applications, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect personal information through the applications. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the applications.

 

Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the applications may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the applications that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on particular content. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

 

Analytics. We use Google Analytics to collect anonymized or aggregate information regarding user behavior and user demographics on the applications. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s processing of data generated by your use of the applications by visiting http://tools.google.com/dlpage/gaoptout.

 

Language Proficiency Metrics. The application assesses your performance on various aspects of your foreign language proficiency and are attributed to your persona name. Various modalities of your language proficiency, to include listening proficiency, reading proficiency, and vocabulary proficiency, are continuously measured based upon your in-app performance. Your in-app performance is publicly viewable to other users in your licensed cohort and their in-app performance is viewable to yourself.

 

 

HOW WE USE YOUR INFORMATION

 

We use your personal information for a variety of business purposes, including to: Provide the applications or Requested Information, such as:

  • Fulfilling our contract with you;
  • Managing your information;
  • Responding to questions, comments, and other requests;
  • Providing access to certain areas, functionalities, and features of the applications;
  • Answering requests for customer or technical support; and
  • Allowing you to register for events.
  • Serve administrative purposes, such as: pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Measuring interest and engagement in the applications;
  • Improving our products and applications;
  • Developing new products and applications;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on the applications and Privacy Policy changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

 

Marketing Our Products and applications. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. At any time you have the right to revoke your consent with respect to our collection, use or disclosure of your personal information

De-identified and Aggregated Information Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create., and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

 

How We Use Automatic Collection Technologies. Our uses of the automatic collection Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our applications that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
  • Performance Related. We may use Technologies to assess the performance of our applications, including as part of our analytic practices to help us understand how our visitors use the applications;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our applications. This may include identifying you when you sign into our applications and keeping track of your specified preferences or past pages viewed; and
  • Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our applications or on websites. Depending on applicable law, we will seek your express consent to such ads. We do not sell your personal information.

 

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the personal information of the browser and devices that appear to be used by the same person.

 

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

 

We may share your personal information with the following categories of third parties:

Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust information include service providers for: (i) the provision of the applications; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services. We do so in accordance with applicable law, which may require data processing agreements or addenda.

Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.

Advertising Partners. Through our applications, we may allow third party advertising partners to set Technologies and other tracking tools to collect personal information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” Depending on your place of domicile and applicable law, we may request your express consent to undertake such activities. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Information Shared with Other Users. When you use the applications, including when you use our teleconferencing services, certain personal information may be shared with other users. This personal information may include your account information (such as your name and your avatar), Content you choose to present, including any audio that your VR device captures while you engage in teleconferencing, and foreign language proficiency. Please be aware that Jedburgh has little or no control over how individuals may use the Content you share. You choose with whom you wish to share your Content in VTE while using the applications.

APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our applications. APIs and SDKs may allow third parties to collect your personal information, subject to applicable law, to provide Content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

 

 

Disclosures to Protect Us or Others. We may access, preserve, and disclose any personal information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal information may be transferred as part of such a transaction as permitted by law and/or contract.

 

INTERNATIONAL DATA TRANSFERS

 

You agree that all personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States and other countries which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If you are a resident of the European Economic Area (EEA) and provide personal data to us, we will either seek your express consent to such transfer if you are an individual data subject in accordance with applicable law, or we will rely on mechanisms such as Standard Contractual Clauses.

 

YOUR CHOICES

 

General. You may have the right to opt into certain uses of your personal information, or based on type of use and/or your geographic location, to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or applications you have requested. We may also send you certain non-promotional communications regarding us and our applications, and you will not be able to opt out of those communications (e.g., communications regarding the applications or updates to this Privacy Policy).

 

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Depending on your domicile and applicable law, we may seek your express consent to the placement of cookies. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.

 

Please note you must separately opt out in each browser and on each device.

 

YOUR PRIVACY RIGHTS

 

Depending upon your location and in accordance with applicable laws, such as if you are resident in the EEA or in California, you may have the right to:

Access personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.

Request Correction of your personal information where it is inaccurate or incomplete.

Request Deletion of your personal information, subject to certain exceptions prescribed by law.

Request Restriction or Object to Processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties.

Not be Discriminated Against by us for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

 

DATA RETENTION

 

We retain the personal information we receive as described in this Privacy Policy for as long as you use our applications or as necessary to fulfill the purpose(s) for which it was collected, provide our applications, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

SECURITY OF YOUR INFORMATION

 

We take steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

To the extent permitted by applicable law, by using the applications or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the applications. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the applications or by sending an e-mail to you.

 

THIRD PARTY WEBSITES/APPLICATIONS

 

The applications may contain links to other websites/applications and other websites/applications may reference or link to our applications. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of, such other websites or applications. Visiting these other websites or applications is at your own risk.

 

CHILDREN’S INFORMATION

 

The applications are not directed to persons under 16 (or to children as required by applicable law), and we do not knowingly collect personal information from children. We will try to establish that you are at least 16 years old, and we require that if you are not, please do not misrepresent your age or use the applications. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

 

SUPERVISORY AUTHORITY

 

If you are located in the European Union or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

 

CHANGES TO OUR PRIVACY NOTICE

 

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the applications after the new Privacy Policy takes effect.