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Privacy Policy

Last Updated: August 2021

BRINK XR, Inc., (“BRINK”) is a California company that creates Virtual Travel Experience apps as described in more detail at Our Website: www.BrinkXR.com

We care deeply about protecting the privacy of individuals who use our Service. This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Our Services and tells You about Your privacy rights and how the law protects You. We use Your Personal Data to provide and improve our Services. By using our Services, You agree to the collection and use of information in accordance with this Privacy Policy.


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Application means the software program provided by the Company downloaded by You on any electronic device, named BRINK VR or BRINK AR.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to BRINK XR, Inc.
  • Device means any device that can access the Service such as a cellphone, tablet, computer, or a virtual reality headset.
  • Identity Data refers to data submitted or collected, that relates to the identity of an individual.
  • Personal Data refers to any Identity Data or Usage Data that relates to an identified or identifiable individual.
  • Service refers to the Application or the Website or both.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Website refers to BRINK XR, accessible from www.BrinkXR.com
  • Usage Data refers to data collected automatically, generated by the use of the Service.
  • You means the individual using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Your Personal Data

Your Personal Data is comprised of two categories: Identity Data and Usage Data.

Indentity Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.
Identity Data may include, but is not limited to:

  • First and Last Name
  • Account Name
  • Email address

Usage Data

While using Our Service, Usage Data is collected automatically. Usage Data is generally anonymous, and does not include any personally identifiable data.
Usage Data may include, but is not limited to:

  • Areas of our Service that You use
  • The time and date of Your use
  • The time spent on those Areas
  • Your Device's manufacturer, type, and version
  • Your Device's identifiers and diagnostic data
  • Your Device's internet protocol address (e.g. IP address)

Use of Your Personal Data

We may use Your Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • To manage Your requests: To attend and manage Your requests to Us.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Disclosure of Your Personal Data

We do not sell, rent, or lease any of Your Personal Data to third parties. We may disclose any of Your Personal Data with or without notice to you if required by a subpoena, judicial or administrative order or as required by law, or where, in our sole discretion, we have a reasonable belief that it is necessary to protect the safety of any individual or the general public, and in the future to prevent a violation of Our Terms of Service, or Our rights, or any third party. We may also be required to disclose an individual’s personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If We are involved in a merger, acquisition, or asset sale, we reserve the right to transfer Your Personal Data to the acquiring entity. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy, and you may choose to modify any of your information at that time.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Security of Your Personal Data

All personal and anonymous information is stored on physically and electronically secured servers. Access to this information is strictly limited to individuals who have a legitimate reason to use the information. The information is protected with security industry best practices, including; network security controls, logical and physical access controls, segregation of duties, and the principle of least privilege to prevent unauthorized access. While we cannot guarantee that loss, misuse or alteration of your data will not occur, we work hard to prevent such occurrences.

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Removal of Your Personal Data

At any time and for any reason you may choose to correct or update your personal information by emailing us with your request at Legal@BrinkXR.com. If you choose to remove your data it will be deleted from our records within 30 days, but may remain in our backup records for approximately 90 days.

Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.


We use Your Usage Data to monitor and analyze the use of our Service in order to better understand how our Service is used so that we may improve it.

  • Google Analytics. Their Privacy Policy can be viewed at: policies.google.com/privacy

    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: policies.google.com/privacy

  • Unity Analytics. Their Privacy Policy can be viewed at: unity3d.com/legal/privacy-policy


We use Your Personal Data to contact You with newsletters, marketing, or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.


We provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Personal Data from Minors

Our Service is intended for general audiences, and not for children under the age of 13. We do not knowingly collect any personal information (as defined under the Children’s Online Privacy Protection Act, also known as COPPA) from children under the age of 13 years old. We will not ask for the personal information of children under the age of 13 years old, and will only collect information from children for limited purposes that are consistent with applicable law. If We learn that a child under the age of 13 has provided us with personal information that is not subject to a COPPA exception, we will immediately delete the information upon receiving such notice.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Dispute Resolution

We are committed to resolving complaints about our collection or use of Your Personal Data.

If you have any questions or comments about our use of Personal Data collected through the use of our Service, or about this Privacy Policy, please contact us at Legal@BrinkXR.com. We will use reasonable efforts to promptly investigate any complaint you have regarding our use of such information and to comply fully with the legal and regulatory authorities responsible for enforcing our adherence to the privacy principles stated above.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us by email: Legal@BrinkXR.com or through our website: www.BrinkXR.com