Privacy Policy

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This Privacy Policy explains how we collect, use, process, and disclose your information across the Whirlwind FX Platform and related applications (the "Company Platform").

If you see an undefined term in this Privacy Policy, it has the same definition as outlined in our Terms of Service.

When this policy mentions "Company," "we," "us," or "our," it refers to the Company that is responsible for your information under this Privacy Policy (the "Data Controller"). The Data Controller is Whirlwind Virtual Realities Inc.

1. INFORMATION WE COLLECT

There are two general categories of information we collect. We collect information from users ("Members" or "Subscribers" or "Customers") who may provide Member Content and we may collect information from third-party subscribers or customers of such users (Third-Party Users). Some categories of information apply to both Members and Third-Party Users (such terms may be used interchangeably).

1.1 Information from Members and Third-Party Users.

• Account Information. When you sign up for a Company Account, we require certain information such as your name and email address. We also may ask you to choose between account verification questions such as your date of birth, or other identifying information you provide.

• Other Authentication-Related Information. To help create and maintain a trusted environment, we may ask you to provide identification (like a photo of your government-issued ID) or other authentication information.

• Communications with Company. When you communicate with Company, we may collect information about your communication and any information you choose to provide in such communication.

• Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Company Account or use other features of the Company Platform.

• Connecting with Members. Use of Whirlwind FX may result in connecting Members with Third-Party Users where Members can share information to which Whirlwind FX may have access.

• No Sensitive Information. Whirlwind FX does not collect and will not share any personal health information, sensitive personal data, or other similar information.

1.2 Intentionally Omitted

1.3 Information We Automatically Collect from Your Use of the Company Platform.

When you use the Company Platform, we collect information about the services you use and how you use them in order to create a better experience for you.

• Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Company Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a "Do Not Track" signal in the HTTP header from your browser or mobile application.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information about for the limited purposes of putting Members in touch with Customers and Third-Party Users and to create a trusted and safe environment.

2.1 Provide, Improve, and Develop the Company Platform.

• Enable you to access and use the Company Platform.
• Enable communication between Members and Customers.
• Operate, protect, improve and optimize the Company Platform and experience, such as by performing analytics and conducting research.
• Provide customer service.
• Send you service or support messages, such as updates, security alerts, and account notifications.

2.2 Create and Maintain a Trusted and Safer Environment.

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct investigations and risk assessments.
• Verify or authenticate information or identifications provided by you (such as to verify your Company address or compare your identification photo to another photo you provide).
• Conduct checks against databases and other information sources.
• Comply with our legal obligations.
• Resolve any disputes with any of our users and enforce our agreements with third parties.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about Company or partner campaigns and services).
• Personalize, measure, and improve advertising.
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Company or its third party business partners.

3. SHARING & DISCLOSURE

3.1 With Your Consent.

By using the Company Platform, you agree to consent to the limited sharing of your information as set out in this Privacy Policy.

3.2 Service Providers.

We may use a variety of third party service providers to help us provide services related to the Company Platform. Service providers may be located inside or outside of the European Economic Area ("EEA"). For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this Privacy Policy.

3.3 Safety and Compliance with Law.

Company may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary: (i) to comply with legal process and to respond to claims asserted against Company, (ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iii) to enforce and administer our Terms of Service or other agreements with Members, (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of Company, its employees, its Members, or members of the public.

We will attempt to notify Members about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Company's property, its Members and the Platform (collectively, "Risk Scenarios"). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

3.4 Business Transfers.

If Company undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4. YOUR CHOICES

4.1 Access and Update.

You may review, update, or delete the information in your Company Account by logging into your Company Account and reviewing your Account settings and profile.

Customers and Subscribers may request that Company delete Subscriber Information at any time. If requested, Company will delete such information and Customer/Subscriber shall no longer be entitled to receive any information from Member(s) using the Company Platform.

4.2 Account Cancellation.

For information on how to cancel your Company Account, Please use the Contact form at www.whirlwindfx.com . Note that information that you have shared with others (like Reviews or forum postings) may continue to be publicly visible on the Company Platform in association with your first name, even after your Company Account is canceled.

5. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a 100% secure environment so we can't guarantee the security of the transmission or storage of your information.

6. CHANGES TO THIS PRIVACY POLICY

Company reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Company Platform and update the "Last Updated" date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access or use of the Company Platform will constitute acceptance of the revised Privacy Policy.

7. CONTACT

If you have any questions or complaints about this Privacy Policy or Company's information handling practices, you may contact us at www.whirlwindfx.com.

You may also email us at support@whirlwindfx.com.

Effective Date: Feb 2021