Privacy Policy

1. Processing manager

The data collected is processed by SAS VIRTUOSE REALITY STUDIO with a capital of 60000€ registered under the number 821 740 909 at the PARIS RCS. Its headquarters are located at 22 rue Cardinet 75017 Paris, France, and its CEO, Mr. Jérôme Simonpietri, represents the company.

VIRTUOSE REALITY STUDIO is very concerned with the protection of your personal data and the respect of your privacy. This privacy policy (along with terms of service) is meant to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. We invite you to carefully read this document to better understand how we process your personal data, and to know your rights.

This Privacy Policy is applicable to all Services created by VIRTUOSE REALITY STUDIO that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy applies).

2. The information we collect

Your use of our Services makes it likely that we collect and process data necessary to the proper functioning of the Application and to the supply of the Services. It can be information you share with us directly, or data we collect automatically.

Data we collect automatically
When you use our services and features, we collect information regarding your activity on the Application:

Activity data: when you access our Services and use the Application and its features, data on the way you use them may be collected and processed. More specifically, this includes your registration date and last connection.

Device and equipment data: we collect information from the devices and equipment you use to access our Services, including server logs, which may contain information like IP addresses, version of the application, mobile model, mobile ID, language used, operating system, application crashes.

3. How we use the data collected

The data collected by VIRTUOSE REALITY STUDIO allows us to provide the Services and make sure the Application is running smoothly, which it is contractually obligated to do, in virtue of the contract biding us with the Members (Terms of Service).

The data collected is also necessary to VIRTUOSE REALITY STUDIO fulfilling its legitimate interests (improving and optimizing its services, along with gaining a better knowledge of its Users and the ways in which they use the Services) and allow the company to run statistical studies, satisfaction surveys, and marketing analyses relating to the use of the Application and Services by the Members.
As the data processing relies on the consent of Members to have their data processed, they can withdraw it at any time; withdrawal of the consent does not affect processing carried out before the withdrawal.

VIRTUOSE REALITY STUDIO may process Members’ personal data in response to a legal request (search warrant, court order, or the like) or to comply with its legal, regulatory, judicial, or administrative obligations.

Lastly, VIRTUOSE REALITY STUDIO can process your personal data to uncover or prevent fraudulent activities or breaches to the Service’s safety, in compliance with the law, or analyze reports of Members displaying a behavior breaching the Terms of Service.

4. How data is shared

Only certain VIRTUOSE REALITY STUDIO employees from the customer or support services, and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.

VIRTUOSE REALITY STUDIO may also enter into agreements with authenticated and reliable service providers and partners, who may process Members’ personal data, in compliance with the Privacy Policy, and while ensuring the safety and privacy of the Members’ personal data. These service providers and partners help us run and improve our Services, especially with regards to data hosting, surveys, analyses and statistics, the use and/or proper functioning of the Application, and providing the necessary assistance to Members.
VIRTUOSE REALITY STUDIO may forward some data to a public body, if it is requested to do so, to comply with any judicial or legal request.

5. Overview of a Member’s rights

In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés), and the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to contest or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, HAPPN commits to respecting the protection of personal data and to process requests as soon as possible. A Member can exercise his/her rights, granted he/she can prove his/her identity, by sending a letter or e-mail to or by exercising his/her rights directly on the Application.

For any other claim, the Member may lodge a claim with the national authority responsible for the protection of data.

• The right to access allows a Member to ask VIRTUOSE REALITY STUDIO for data pertaining to him/her in an accessible format, based on Article 39 of the French Data Protection Act (Loi Informatique et Libertés), and article 15 of the GDPR.
• The right to correct grants a Member the right to demand VIRTUOSE REALITY STUDIO corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on Article 40 of the French Data Protection Act (Loi Informatique et Libertés), and article 16 of the GDPR.
• The right to data portability grants a Member the right to receive the personal data he/she gave to VIRTUOSE REALITY STUDIO, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with article 20 of the GDPR.
• The right to contest grants a Member the right to contest, free of charge and at his/her own discretion, the use of his/her data by VIRTUOSE REALITY STUDIO for prospection, especially commercial, and to the processing based on VIRTUOSE REALITY STUDIO’s legitimate interest, in compliance with Article 38 of the French Data Protection Act (Loi Informatique et Libertés), and article 21 of the GDPR.
• The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of the data transmitted to VIRTUOSE REALITY STUDIO, within the limits of the rights based on article 17 of the GDPR.
• The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance Article 40-1 of the French Data Protection Act (Loi Informatique et Libertés).

These rights may only be exercised within the limits of VIRTUOSE REALITY STUDIO’s resources as it relates to its use of Facebook Analytics. Some of the data is sent to VIRTUOSE REALITY STUDIO by Facebook Analytics or Google Analytics and cannot be corrected without Facebook’s or Google’s assistance.

The Member can also rectify most of his/her personal data, at his/her own initiative, on the Application itself.

6. Storage of the data

VIRTUOSE REALITY STUDIO will store the Member’s data for as long as required in order for the Member to use his/her Account, namely:

• For the length of the Member’s enrollment, plus one year;
• For the length of the reporting, to process a report on fraudulent behavior;
• For three years when the account is suspended, in compliance with article 16.4 of the Terms of Service;
• For 13 months for cookies, in compliance with legal provisions (see the document on our Use of Cookies).

Furthermore, please note that in accordance with its status as a hosting provider, VIRTUOSE REALITY STUDIO has a legal obligation to retain some of its Members’ personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004.

VIRTUOSE REALITY STUDIO undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.
VIRTUOSE REALITY STUDIO shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be over 18 years of age, the parents of the minor in question should inform VIRTUOSE REALITY STUDIOof this by sending an e-mail to the address mentioned in article 9, requesting the data to be deleted. VIRTUOSE REALITY STUDIO commits to deleting all data on the minor in question as soon as possible.

7. Transfer of Personal Data outside the EU

When registering, the Member expressly consents to his/her data being transmitted to VIRTUOSE REALITY STUDIO’s service providers and subcontractors outside the European Union, to let VIRTUOSE REALITY STUDIO run statistical studies, support members, and if need be, host data processed by the Application.

VIRTUOSE REALITY STUDIO guarantees that the transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection in compliance with regulations (notably the examples of contractual clauses provided by the European Commission)

8. Our Companywide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to VIRTUOSE REALITY STUDIO employees and strictly enforce privacy safeguards within the company.

9. Third-Party Sites and Services
VIRTUOSE REALITY STUDIO websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

10. Contact

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact us:

• by sending an e-mail to our contact e-mail address :
• by sending a letter to the following address: For the Representative for data protection – 22 rue Cardinet 75027 Paris – France.

VIRTUOSE REALITY STUDIO may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

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