Privacy

DATA PROTECTION AND LIABILITY

I. Introduction
361 Extended Reality GmbH and its affiliates (together, “361 XR,” “we”, “us” or “our”) is committed to data protection and data privacy. We would like to provide users of our website (“you”) with information regarding the way that we use the information that is collected on our network of websites. We recommend that you read this Privacy Policy (“Policy”) so that you have a clear understanding of the data that we collect and how we use this information. By submitting your personal information to us, you will be deemed as having given your consent, where necessary and appropriate, for the disclosures referred to in this Policy.

II. What Does this Privacy Policy Cover?
This Policy details the personal information we collect about you, the means through which we collect that information, the recipients with whom we share this information, and how you can change your preferences regarding how we collect and use your information.BY VISITING 361 XR’S WEBSITES, YOU ACCEPT THE TERMS AND CONDITIONS SET OUT IN THIS POLICY, INCLUDING CONSENTING TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND PROCESSING OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN.IF YOU DO NOT AGREE WITH THIS NOTICE, PLEASE DO NOT USE THE WEBSITES OR BECOME A REGISTERED MEMBER.

III. Key Definitions
1. “Clickstream Data” means a record of an individual’s activity on our Websites, including, but not limited to data regarding the Websites and content that has been viewed by the User, how long the User was on the Websites, and their interactions with the Websites.
2.“Co-Branded Site” means a website hosted by one of our Sponsors, the Content and branding of which is shared with the respective Sponsor. For the purposes of this Policy, Co-Branded Sites are included in the definition of the Websites.
3. “Content” means white papers, newsletters, reports, advertisements, webcasts, demonstrations, articles, or other documents that are linked to or displayed on the Websites.
4. “Content Sponsors” means Sponsors who promotes the posting and/or creation of Content linked to or displayed on the Websites.
5. “Members” means Users who have completed a registration process to become a member of the 361 XR network by way of (i) completing a registration form on one of our Websites, (ii) subscribing to a 361 XR newsletter, or (iii) registering for a 361 XR event such as a demonstration or webcast.
6. “Member Information” means information which you provide 361 XR which may include your name and professional title, the name of your company and the department in which you work, your industry group, country, zip code, email address, telephone number, as well as Clickstream Data or Supplementary Information which may append your Member Information. Member Information may also be collected from Members and Potential Customers. Member Information may include Personal Information. 361 XR does not collect sensitive personal information.
7. “Personal Information” means any information relating to an identified or identifiable natural person, including an individual’s name, contact information, professional title, and employer. In some regions, an individuals’ internet protocol address (“IP address”) may be considered Personal Information.
8. “Potential Customers” means (i) a User that has registered on one of 361 XR’s corporate websites to receive information about 361 XR’s business to business services, or to schedule a demonstration of 361 XR’s online, media, marketing, or data services products or programs, (ii) an individual who has expressed interest in a trade show in which 361 XR participated or hosted and whose badge was subsequently scanned as part of their attendance of such event, (iii) individuals who have had meaningful interaction with marketing emails sent by 361 XR, (iv) individuals whose information 361 XR has received in connection with a vendor-services list rental or purchase arrangement, or (v) individuals who 361 XR or others have identified as potential customers.
9. “Service Provider” means vendors that provide services to 361 XR with regard to the operation of its Websites or the collection or review of data from its Websites. 10, “Sponsor” means a third party that owns or promotes Content or advertising space on our Website. The term Sponsor includes technology and technology resellers, professional and enterprise service clients, media, sales, and marketing clients, and those clients providing content, products, or services relevant to our Members.
11. “Supplementary Information” means information about an individual that they have made publicy available or information that is made available by third parties that 361 XR may use to supplement Member Information. For example, if a Member provides the name of the company where he or she works, 361 XR may obtain information that is publically available, or through a paid third party service, regarding the company’s number of employees and annual revenue.
12. “Tracking Technologies” means cookies, clear GIFs, web beacons, serving tracking technologies or other technology solutions performing similar functions. These technologies may include first party cookies (i.e., those placed by the website being visited) and third party cookies (i.e., those placed by a website other than the one being visited), local shared objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs).
13. “User” or “you” means any individual who views or interacts with the Websites, whether or not they are a Member or a Potential Customer.

IV. Why Does 361 XR Collect Information?
361 XR collects information about you in an effort to provide you with the best most useful content and services and to offer you opportunities to obtain other products and services from us and our Sponsors. By providing us with your information, we are able to cater our content and services to your interests and ensure that you receive relevant offers. Additionally, the collection and use of information helps us tailor and improve our services and communicate with you effectively as we know many of our Users and Members make use of a range of media channels. Finally, collecting and sharing your information with our Sponsors makes it possible to operate our business and provide you with free content, products, or services relevant to your professional interests.

V. What Information Do We Collect and How is It Collected?
We only collect information with your consent. By using our Websites, you consent to the collection of information as set forth in this Policy. 361 XR is committed to data minimization. As such, we only collect the information which is necessary to facilitate the purposes and uses reflected in this Policy.
1. Information That We Acquire From You Directly. Users have the option to provide 361 XR with Personal Information about themselves to enable 361 XR and Sponsors to provide them with access to premium Content as well as offers, and services catered to their areas of interest. Users who do not share their information with 361 XR may continue to access the vast array of free, publically accessible Content which is readily available on the Websites and does not require a User to become a Member.2. Member Information. 361 XR collects Member Information and Supplementary Information in an effort to provide you with the best and most useful content and services, and to offer you opportunities to obtain other products and services from us and our Partners. Member Information and Supplementary Information may contain Personal Information. We collect your Member Information when you (a) provide it to us by way of your completing a registration form on one of our Websites, (b) subscribe to one of our newsletters, (c) register for one of our events, or (d) otherwise interact with, engage, or communicate with our Websites or Co-Branded Sites and any Content posted on it. The disclosure of your Personal Information is completely voluntary and we will only collect Member Information with your consent; however, once you register with our Websites, you are no longer anonymous to us. We may retain your information for as long as you choose to maintain an active account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. To the extent that we combine any Clickstream Data or Supplementary Information with the information provided by you, it will be considered to be part of your Member Information.3. Information About Others Who May be Interested In Our Services. Our Websites may include an “email-a-friend” feature, which allows someone to email Content to a third party. In the event that you utilize the feature, we will only use the email address of the intended recipient for purposes of emailing the respective Content to that person. You should never share another person’s Personal Information with others without first receiving their consent.4. User Generated Content. Some Websites feature User generated Content in the form of a User review section or forum communities. In order to interact in these forums, an individual must first complete the applicable registration form. The information provided by the individual may be displayed in the individual’s public profile in our forums and can be viewed by all visitors to the Website. To ensure individuals’ privacy, we do not display any the email addresses of individuals who have commented in such forums or who have contributed such content.5. Information That We Acquire Indirectly




6. Supplementary Information. 361 XR may acquire Supplementary Information by using Service Providers in order to confirm your Membership Information, to further enhance the relevancy of our provision of services to you, and to ensure the accuracy of the information.
7. Analytical, Behavioral, Log, and Clickstream Data. We may gather certain information about your use of the Websites, such as your browser type and information about your visit and interaction with our Content.

One of the ways in which we collect this information is through Tracking Technologies such as cookies and web beacons. A cookie is a small file downloaded on to a device when a user accesses certain websites. Cookies are useful because they allow us to recognize your device and provide you with a high level of service and relevant offers. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. For more information about our use of cookies and other Tracking Technologies, please visit our Cookie Policy.We partner with certain Service Providers to collect analytical, behavioral, log, and clickstream data and to engage in analysis, auditing, research, and reporting. We, our Service Providers, and our Sponsors may use Tracking Technologies to identify you when you are online, and to collect information about your online activities, such as the type of browser you use, the websites you visit, your IP address, geographic location, browser type and version, and the content and advertising that you find interesting. This information helps us authenticate your profile; understand your interests and how we can better serve you. Additionally, this information may be combined with information you have provided to us or that we or others have collected about you, so that we may maximize the benefit you receive from the Services and deliver advertising targeted to your specific interests on our websites and mobile applications and when you use other websites or mobile applications. Information about you also may be aggregated with other Registered Users for the purposes identified above.Although Our Websites currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed in the section entitled “Opting Out and Your Personal Rights.” If you do not wish to have Tracking Technologies be used when interacting with the Websites, many web browsers allow you to stop accepting cookies and/or to warn you when a third party is trying to transfer a cookie to you. Please note that some 361 XR features and services may not be available to you if Tracking Technologies are disabled.

1. What is the Legal Basis for the Processing of Personal Information?
361 XR relies on both consent and legitimate business interests for processing Personal Information. For example, 361 XR may process Personal Information with a User’s consent when a User agrees that 361 XR may place cookies on their devices, or that we can process information that the User inputs into the Websites.On other occasions, 361 XR may process Personal Information pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. For example, 361 XR may process Personal Information pursuant to legitimate business purposes to respond to User inquiries and to fulfill User requests, to send Users relevant marketing information and offers, to complete transactions, provide customer service, send administrative information, to personalize Users’ experiences with the Websites, and where 361 XR is required to do this by law.361 XR also processes Personal Information when it is in 361 XR’s or a Users’ legitimate interests to do so and when these interests are not overridden by individuals’ data protection rights. These legitimate interests include providing services to enable 361 XR to provide Users with more relevant ads and content.

VI. What is the Legal Basis for the Processing of Personal Information?
361 XR relies on both consent and legitimate business interests for processing Personal Information. For example, 361 XR may process Personal Information with a User’s consent when a User agrees that 361 XR may place cookies on their devices, or that we can process information that the User inputs into the Websites.On other occasions, 361 XR may process Personal Information pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. For example, 361 XR may process Personal Information pursuant to legitimate business purposes to respond to User inquiries and to fulfill User requests, to send Users relevant marketing information and offers, to complete transactions, provide customer service, send administrative information, to personalize Users’ experiences with the Websites, and where 361 XR is required to do this by law.361 XR also processes Personal Information when it is in 361 XR’s or a Users’ legitimate interests to do so and when these interests are not overridden by individuals’ data protection rights. These legitimate interests include providing services to enable 361 XR to provide Users with more relevant ads and content.

VII. What Information Do Our Sponsors & PartnersCollect?
Our Sponsors may include Tracking Technologies within advertisements that 361 XR serves to websites. This is in order for our Sponsors to set and read their own cookies. These Tracking Technologies are not subject to the control of 361 XR. Similarly, if you click on an advertisement on our Websites, you may be redirected to the website of one of our Sponsors. We encourage you to read the privacy policies of an websites that you visit outside of our network.

VII. A) Nature and purpose of the processing, type of personal data and categories of data subjects that our Partners collect

Type of processing (according to the definition of Art. 4 No. 2 DS-GVO):
The processing is of the following nature: collection, recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction of data.
The processing serves the following purpose:
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1. the personal data of the Data Subjects at the Controller are collected, processed at a professional level and used by the Controller itself on the basis of the application provided. The partner does not collect or use this data. Processing of customer data by the partner shall only take place on a technical level and exclusively within the scope of service processing.

2. the provision of the contractually agreed data processing shall take place exclusively within the territory of the Federal Republic of Germany.

3. any relocation to a member state of the European Union or to another state party to the Agreement on the European Economic Area shall require the prior consent of the Controller. Any relocation to a third country is expressly excluded.
a) Administrative data:
Master and transaction data of the person responsible for processing and billing;
Address data of interested parties and employees;
Data of suppliers, insofar as they are required for order processing and contract fulfillment.
b) Customer data:
The group of data subjects is determined by the responsible party itself, as the collection of data from the data subjects is carried out exclusively by the responsible party.
c) User data:
The group of users is determined by the responsible party. In the system, the activities of the users are logged on a person-by-person basis.

4. the Controller shall autonomously determine the categories of data subjects affected by the processing on the basis of the application provided.Type of personal data (according to the definition of Art. 4 No. 1, 13, 14 and 15 GDPR): HR master data (surname, first name, user name, email address, company affiliation). Categories of data subjects (according to the definition of Art. 4 No. 1 DS-GVO): The group of persons affected by the handling of their personal data under this contract includes all current, former, or future employees (if the employment relationship has already been contractually agreed) of 361 Extended Reality GmbH.

VII. B) Duties of the partner
The partner shall process personal data exclusively within the framework of the agreements made and in accordance with the 361 Extended Reality's instructions, unless the partner is required to do otherwise by the law of the Union or the Member States to which the Processor is subject (e.g. investigations by law enforcement or state protection authorities); in such a case, the Processor shall notify the Controller of these legal requirements prior to the processing, unless the law in question prohibits such notification due to an important public interest (Article 28 (3) sentence 2 lit. a DS-GVO).
The partner shall not use the personal data provided for processing for any other purposes, in particular for its own purposes. Copies or duplicates of the personal data shall not be made without the knowledge of 361 Extended Reality. In the area of the processing of personal data in accordance with the order, the partner warrants that all agreed measures will be carried out in accordance with the contract. He assures that the data processed for 361 Extended Reality are strictly separated from other data stocks. The data carriers originating from the Client or used for the Client shall be specially marked. Incoming and outgoing data as well as ongoing use shall be documented.
The partner shall cooperate to the necessary extent in the fulfillment of the rights of the data subjects pursuant to Art. 12 to 22 of the GDPR by 361 Extended Reality, in the creation of directories of processing activities and in any necessary data protection impact assessments of 361 Extended Reality and shall provide 361 Extended Reality with appropriate support to the extent possible (Art. 28 (3) sentence 2 lit. e and f of the GDPR).The partner shall notify 361 Extended Reality without undue delay if, in its opinion, an instruction issued by 361 Extended Reality violates statutory provisions (Art. 28 (3) sentence 3 DS-GVO). The partner shall be entitled to suspend the implementation of the relevant instruction until it is confirmed or amended by the Responsible Party at 361 Extended Reality.
The partner shall correct, delete or restrict the processing of personal data from the contractual relationship if the Client requests this by means of an instruction and if legitimate interests of the partner do not conflict with this.The partner may only provide information about personal data from the contractual relationship to third parties or the person concerned after prior instruction or consent by 361 Extended Reality. The partner agrees that 361 Extended Reality - in principle by appointment - is entitled to monitor compliance with the regulations on data protection and data security as well as the contractual agreements to a reasonable and necessary extent itself or through third parties commissioned by 361 Extended Reality, in particular by obtaining information and inspecting the stored data and the data processing programs as well as through on-site reviews and inspections (Art. 28 (3) sentence 2 lit. h DS-GVO).The partner warrants that it will assist in these inspections to the extent necessary.361 Extended Reality shall in principle permit the processing of data in private residences (teleworking or working from home by employees of the partner). Insofar as the data is processed in a private home, access to the employee's home for control purposes of the employer must be contractually ensured in advance. The measures pursuant to Article 32 of the GDPR shall also be ensured in this case. The partner confirms that it is aware of the data protection regulations of the GDPR relevant for the commissioned processing. He undertakes to also observe the following secrecy protection regulations relevant to this order, which are incumbent on the Client: (e.g. banking secrecy, telecommunications secrecy, social secrecy, professional secrecy nor Section 203 of the German Criminal Code, etc.).The partner undertakes to maintain confidentiality when processing the Client's personal data in accordance with the contract. This obligation shall continue to exist even after termination of the contract.
The partner warrants that it will familiarize the employees engaged in the performance of the work with the data protection provisions applicable to them before they commence their activities and that they will be bound to secrecy in an appropriate manner for the duration of their activities as well as after termination of the employment relationship (Art. 28 Para. 3 Sentence 2 lit. b and Art. 29 DSGVO).
The partner shall monitor compliance with the provisions of data protection law in its company.
A company data protection officer has not been appointed at the partner, as there is no legal necessity for an appointment.Translated with www.DeepL.com/Translator (free version)

VIII. How is Your Information Used?
We use, aggregate, and retain your information as needed to provide you with and access to premium Content, products, and services catered to your areas of interest and for other legitimate business reasons. At a high level, we use the information that we collect about you to:provide you with services, publications, and information that you request, access, or which may be of interest to you;deliver or display content that matches your professional interests and responsibilities;contact you with information about, and invitations for, products and services from 361 XR and Sponsors directed to your professional interests and responsibilities;communicate with you, advertise to you or invite you to join us on social media platforms on which you participate;offer you opportunities to connect directly with your peers and with providers of technologies, goods, and services that may be of interest to you; orfor any other purpose that we tell you about when you give us the information.By way of example, we analyze information collected from you indirectly to (a) help us recognize your computer as a previous visitor, and save and remember any preferences that you may have while you were visiting one of our Websites or a Co-Branded Site, (b) track, accumulate and report information on our Website and Content usage to our Sponsors so that they can measure the effectiveness of advertisements and content viewed on the Website, (c) help us customize the Content you are shown while visiting the Websites and potentially other websites, (d) to help us improve our Content and Websites, (e) to personalize your user experience, (f) for the purpose of identifying trends, statistics and measurements that could contribute to the enhancement of our services, and (g) identifying market sensitivities and relative market interest in specific product categories. We may also use the information that we collect to send you satisfaction questionnaires, surveys, and marketing information. The information that we collect may also be used by 361 XR for the purposes of online behavioral advertising. For example, third parties may use the fact that you visited the Sites to target online ads for 361 XR to you on non-361 XR websites. In addition, our third-party advertising networks might use information about your use of the Sites to help target specific technology-related or other non-361 XR advertisements to you based on your online behavior. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.361 XR also uses the information that is collected indirectly to link Users’ activities to their Member Information. Linking User activity to Member Information allows our system to confirm a User’s identity on our Websites and to facilitate easy access to our Content by saving and recognizing Member log-in information.In addition to providing you with our own editorial content, we offer you the opportunity to access the branded content and expertise of our Sponsors. When you choose to take advantage of our Sponsor’s content or expertise, you choose to have your Member Information shared with them as well. 361 XR and its Sponsors may use information collected from you directly to provide you with access to Content related to your interests based on your activity on our Websites and other information that you have shared with us. For example, 361 XR and its Sponsors may send you emails on topics of your interest, marketing research surveys, incentives, as well as promotional emails and direct marketing offers for products and services. We also use Member Information in aggregated form to understand our Member base, and to market our services to our customers. In addition, under certain conditions we will inform a customer of 361 XR that a pre-existing contact in their marketing and sales databases is also a Member. By sharing your information with us, you agree that 361 XR and its Sponsors can contact you by way of email, telephone, mail or other means of communication to provide you with access to Content, surveys, direct marketing, and promotional materials in connection with your activity on the Websites.

IX. Who do we Share Your Information With?
We only share your personal information with third parties as outlined in this Policy.Sponsors. 361 XR may provide Sponsors with access to reports which may include your Member Information and information about your areas of interest derived from your activity on our Websites. This may include the provision of summary reports, based on our analysis of Clickstream Data, which may include a description of your activity on our Websites and interaction with Content or related to editorial and vendor content. For example, a summary report may include a statement similar to the following “3,000 people looked at the xyz white paper this week and, of those 3,000 people, 60% clicked through to read the full white paper.” Information provided in summary reports is aggregated and does not disclose any Member Information. 361 XR may also disclose aggregated user statistics (for example, “25% of our users are interested in Networking”) to our customers, prospective customers and Partners and other third parties, and for other lawful purposes. 361 XR may also provide Sponsors with access to information wherein Membership Information and Clickstream Information are aggregated to enable Sponsors to improve their marketing outreach to their target audience and to optimize their marketing strategies. 361 XR’s contractual arrangements with its Partners: (a) provide that they may use this information to contact you via email, telephone, mail or other means of communication; (b) that they must secure and protect your information in accordance with applicable law and 361 XR’s instructions, (c) implement technical and procedural safeguards to protect your information, and (d) prohibit disclosure of your information to any third parties other than agents of the Sponsors for the permitted marketing purposes set forth above, provided that the third parties have entered into contractual provisions wherein they are required to protect your information under terms in line with those that we have put in place with the Partner directly. If you do not want this information shared, please see “Opting Out and Your Privacy Rights” below. Please contact the Sponsors directly if you have any questions about their use of this information or if you would like to cease receiving communications from a specific Sponsor, but you want to continue to receive emails from 361 XR or to have access to 361 XR’s premium Content.Service Providers. 361 XR may provide your Personal Information to certain Service Providers who are working for or with 361 XR as described in this Policy and who require access to such information to facilitate the provision of services, such as the provision of data storage or processing activities. 361 XR will always attempt to limit the information we provide to what is reasonably sufficient for those Service Providers to carry out their responsibilities as they relate to the fulfillment of the services.Other. We may also share the information that we collect for legitimate business interests and for the following for the following purposes.Compliance with applicable laws. We may disclose the information that we collect to a third party where we are legally required to do so in order to comply with any applicable laws, regulations, legal processes, or government requests, including to meet national security or law enforcement requirements.Vital interests and legal rights. We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.Business transfers. We may share or transfer the information that we collect in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.Other ways in which you specifically consent. We may share the information that we collect in other ways that you specifically consent to.

X. Data Retention
361 XR will retain the Personal Information that you provide while your membership is in existence or as needed to provide you services. We may retain your Personal Information after you have cancelled your membership if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Policy and our Terms of Use. We may also retain Personal Information, for a limited period of time, if requested by law enforcement.

XI. How do We Protect Your Information?
361 XR takes the security of the data that it collects very seriously. 361 XR has implemented a myriad of technical, organizational and administrative measures which are generally accepted by the industry to protect the Personal Information in its possession. These measures include, but are not limited to the implementation of current security technologies and processes to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. In particular, our security systems include authenticated access to internal databases, regular audits of processes and procedures, scheduled reviews of overall web security, and the use of restrictions of access to Personal Information in our possession. Additionally, we use encryption (HTTPS/TLS) to protect data transmitted to and from our Websites.
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XII. Opting Out and Your Privacy Rights
361 XR will only use your Member Information for the purposes described in this Policy or as subsequently authorized by you. We strive to offer you with choices about how your Personal Information is used and shared, as further outlined below.If, after becoming a Member, you wish to access, rectify, erase, restrict, transfer, or object to the use of your information, withdraw your membership, or if you have any questions in connection with this policy or the use of your information, please contact us at mw@361xr.com.Opting-Out. 361 XR provides Users and Members with several ways in which they can easily opt-out of 361 XR’s services.Web Browser Opt-Out. Users and Members may opt-out of 361 XR’s internet-based advertising by removing cookies or by setting your web browser settings to refuse cookies and similar tracking mechanisms. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you simply delete your cookies, you will need to remove cookies from your device after every visit to Websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.Please note that the use of online tracking mechanisms by third parties, such as our Sponsors, is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Although our Sites currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.Unsubscribing from 361 XR Emails.Members: Following the registration process, Members may at any time choose to unsubscribe from our emails, while retaining access to our premium Content. Every email sent by or on the behalf of 361 XR includes information as to how you can easily unsubscribe from such future communications. You may also unsubscribe from all or some of 361 XR emails by updating your account settings with 361 XR. Residents of the EU may also unsubscribe from 361 XR emails by completing 361 XR’s EU-US/Swiss-US Privacy Shield Complaint Form.Members may receive email marketing messages from us about relevant content, products, and service offerings as part of Sponsor marketing programs. You have the option of contacting Sponsors directly if you click on the unsubscribe links provided in the emails. To opt out of our Sponsor marketing programs, you may follow the instructions at the bottom of any email sent to you as part of the program.Potential Customers: We process Potential Customers’ Personal Information for certain legitimate business purposes related to Potential Customers request to receive information about our business to business services or to schedule a demonstration of our online, media, marketing, or data services products or programs. In an effort to ensure that Potential Customers continue to receive the latest information about our offerings, 361 XR provides Potential Customers with a dedicated email address by which they can update their Member Information. In the event that Potential Customers do not wish to receive further marketing or sales emails from 361 XR, Potential Customers may opt-out of receiving additional emails by way of following the unsubscribe mechanism provided at the bottom of emails sent by 361 XR or by completing our Opt-Out Form.Deletion of Membership. Members may request to have their membership deactivated and their Member Information erased by emailing mw@361xr.com. 361 XR will still process the requests without undue delay. Although 361 XR may deactivate a Member’s registration pursuant to their request, it may continue to retain their information for legitimate business purposes as set forth above.Accessing and Updating Your Information. Members may change or update the information associated with their membership at any time and as often as necessary by way of clicking on the [Edit Profile Link located in the upper right hand corner of our websites] or by sending an email to mw@361xr.com.Requests for Information, Records, and Restrictions of Use. At any time during their membership, Members may submit a request for a copy of their information in 361 XR’s possession by sending an email to mw@361xr.com. Members may also request that 361 XR transfers their information or provides the Member with copies of their information to enable the transfer of their information to a third party. 361 XR will respond to all such requests without undue delay.

XIII. How Do We Transfer Information?
Personal Information collected outside the United States, including in the European Economic Area (“EEA“), is transferred to and stored on our servers in the United States and potentially in or to other countries whose data protection laws may be different to the laws in your country. We will protect your Personal Information in accordance with this Policy wherever it is processed.361 XR has certified to the United States Department of Commerce and the European Commission that it adheres to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework ([together,] the “Privacy Shield.” The Privacy Shield is a set of guidelines that establishes an adequacy standard which governs data-sharing between the European Union and Switzerland and the United States.361 XR has certified that (1) it has certain protections and procedures in place which meet EU and Swiss data protection and privacy standards and (2) further, that it adheres to the Privacy Shield principals of notice, choice, security, data integration and purpose limitation, access, accountability for the onward transfer of personal data, recourse, enforcement, and liability. To learn more about the EU-US Privacy Shield, and to view 361 XR’s certification, please visit https://www.commerce.gov/page/eu-us-privacy-shield.

XIV. GeneralThird Party Websites.
Some of the Content made available through our Websites is hosted on the website of the respective Content Sponsor. This means that when you are on a 361 XR Site and click through to that Content, you may leave the 361 XR Site and be redirected to the site of the Content Sponsor, at which time you will be subject to the policies of the Content Sponsor.Our Websites feature advertisements from Advertisers. In the event that you click on an advertisement posted on a 361 XR Site, you may be redirected to the Advertiser’s website and leave the 361 XR network of Sites, at which time you will be subject to the Advertiser’s policies. Please note that there are two indicators of when you have left a 361 XR website. 361 XR takes pride in streamlining the “look and feel” of its websites. When you leave a 361 XR site, the look and feel of the site will change. Additionally, the URL of the 361 XR site that you were browsing prior to clicking on the advertisement will no longer reference the 361 XR Site.361 XR is not responsible for the privacy practices or the content of those sites. Users should be aware of this when they leave our Sites and review the privacy statements of each Web site they visit that collects information. This Policy applies only to information collected on 361 XR’s Websites.Modifications and Amendments. 361 XR may modify or amend this policy from time to time. We will not reduce your rights under this Privacy Policy without your consent. If we change our Privacy Policy, we will post those changes on this page in addition to updating the “Last Updated” date at the bottom of this Policy. For these reasons, we encourage you to read this Policy regularly. Your continued use of the Website or accessing Content posted on the Website shall constitute your acceptance of the modified Policy. If there will be any changes made to the use of your Personal Information in a manner materially different from that stated [at the time of collection, we will notify you by posting a notice on our Website. If you object to any of the changes, or the overall Policy, please contact us via the contact information set forth in Section XV below.Domestication and International Requests. 361 XR requires that any individual issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) to 361 XR properly domesticate the process or request and serve 361 XR in a jurisdiction where it is resident or has a registered agent to accept service on its behalf. 361 XR does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where 361 XR is located.Translations. The English language version shall prevail. Any translations of this Policy are provided for convenience only.Children. Our products, services, events and offerings are directed to professionals. Our business is not directed at children, and we do not solicit or knowingly collect any personal information from children under the age of 13 without verifiable parental consent. If you are not 18 or older, you are not authorized to use the Services. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If you learn that a child under 13 has provided us with personal information without consent, please contact us.

XV. Questions, Complaints and Enforcement
This Policy was drafted with transparency, accuracy, and clarity in mind; however it does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Requests should be sent to the address below.361 XR is committed to resolving complaints about your privacy and our collection or use of your personal information. If you believe that 361 XR has not complied with this Privacy Policy, or if you have any other complaint with regard to collection, use or disclosure of information by 361 XR, please complete the online EU-US/Swiss-US Privacy Shield Complaint Form or send your complaint by mail to the following address. If you are a resident of the European Union, you should submit any such privacy complaints using the EU-US/Swiss-US Privacy Shield Complaint Form. 361 XR will investigate your complaint and respond to you promptly. However, if you do not believe that we have responded to your complaint appropriately or in a timely manner, you may contact our Data Protection Authority, the Information Commissioner’s Office.

361 Extended Reality GmbH
Goethestraße 21
80336 Munich
E-mail: info@vonmorgen.io

Effective Date: January 20, 2021