BRINK XR, Inc., ("BRINK XR") is a California company that creates the virtual travel experience application "BRINK Traveler" as described in more detail at Our Website: www.BrinkXR.com

Your privacy is important to us, and we want to ensure that you feel comfortable and informed about how we handle your personal data. This Privacy Policy explains how We collect, use, and disclose Your information when You use Our Services. It also outlines Your privacy rights and how the law safeguards Your information. By using our Services, You agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

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.

• Account means a unique account created for You to access our Service or parts of our Service.
• Application means the software programs provided by the Company downloaded by You on any electronic device, named BRINK Traveler.
• 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 Services 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.
• Services refers to the Application or the Website or both.
• 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 Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used.
• Website refers to BRINK XR, accessible from www.BrinkXR.com
• Usage Data refers to data collected automatically, generated by the use of the Services.
• You means the individual using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.

Your Personal Data

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

Identity 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
• User Profile
• 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 Services that You use
• How those Services are being used
• The time, date, and duration of Your use
• 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.
• To manage Your requests — to attend and manage Your requests to Us.
• To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services.
• To provide You with news, special offers and general information about goods, services and events which we offer.
• For the performance of a contract — the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased.
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service.

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.

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.

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. 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.

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, and the principle of least privilege.

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, resolve disputes, and enforce our legal agreements and policies.

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 at contact@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

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.

APIs

We may use Your Personal Data to enable features of our Services using third-party technology providers.

• Google Cloud — cloud.google.com/terms/cloud-privacy-notice
• Amazon AWS — aws.amazon.com/privacy
• OpenAI — openai.com/policies/privacy-policy
• Wit.ai — wit.ai/privacy
• Photon — photonengine.com/account/privacyandcookiepolicy

Analytics

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 — policies.google.com/privacy
• Unity Analytics — unity3d.com/legal/privacy-policy

Marketing

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.

• Sendy — sendy.co/privacy-policy

Payments

We provide paid products and/or services within the Service. We use third-party services for payment processing. We will not store or collect Your payment card details. These payment processors adhere to the standards set by PCI-DSS.

• Meta Store — meta.com/legal/privacy-policy
• Steam Store — steampowered.com/privacy_agreement
• Apple App Store — apple.com/legal/privacy
• Google Play Store — policies.google.com/privacy

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 from children under the age of 13 years old. 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, please contact us at contact@brinkxr.com.

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 and updating the "Last Updated" date at the top. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

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