GENERAL PRIVACY POLICY OF WOLVIC

General information

This application has been developed by Igalia, SL (hereinafter IGALIA), with registered office at Bugallal Marchesi, 22 - 1º, 15008, A Coruña, Galicia (Spain), whose contact details are:

• Phone number +34 981 913991;
• Email: info@igalia.com

The content and elements that make up the application have been implemented and/or developed by IGALIA under open source licenses, being protected, without limitations, by the intellectual and industrial property laws of the Kingdom of Spain and by the international Treaties and Agreements that may result of application.

DATA PROTECTION

IGALIA is committed to complying with the legal provisions regarding the protection of personal data: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) and in the Organic Law 3/2018, of December 5, on Data Protection and Guarantee of Digital Rights (LOPDGDD).

“Personal data” is any information related to an identified or identifiable natural person, provided that their identity can be traced, directly or indirectly, in particular by means of an identifier, such as their name, an identification number, location data, etc. alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as one or more elements of the physical, physiological, genetic, mental, economic, cultural or social identifiers of the aforesaid person.

IGALIA does not collect personal data in such a way that the user can be identified. Therefore, you can use the application, consult and browse the virtual reality environment without revealing your identity or providing personal data to IGALIA, either directly or indirectly; therefore, IGALIA will not be liable for any the data that is entered in WOLVIC.

The only data and information that IGALIA will obtain for the use of this application, which at no time will be individually linked to the user, are the following:

• Analytical, purely statistical, and non-identifying data.
• In order to capture and translate the voice into text, the user’s sound data is sent to the servers owned by the third party company responsible for each platform, through an API for this purpose: for example, in Oculus, from Facebook, a service that sends it to Oculus Voice SDK. At no time is the aforementioned data processed, accessed, or incorporated into the servers owned by IGALIA. The data transmitted will be the exclusive responsibility of the third party companies that own each platform (hereinafter, the Third Parties), which may be located outside the European Union and subject to a legal regime that is less protective of user privacy. We recommend that you carefully read the privacy policy and terms of use of each of these external platforms before accepting and using their services. IGALIA will not be directly or indirectly responsible for the processing of personal data by said Third Parties.
• Geographic location information maybe be obtained from the browser, instead of the one used by the system. However, in order to do so, you must set the location permissions of your device through a specific notice in this regard and IGALIA will in no way link the aforementioned information to you as an identified or identifiable person, although the Third Parties mentioned in the previous point could do so, if applicable. We recommend you to pay attention to their legal terms.
• IGALIA will not access or store, in any way, the addresses or URLs visited by you.
• Integration with Cloud services (such as Firefox Accounts or Google Accounts) to synchronize data such as your browsing history or your user bookmarks may be possible. In this case, IGALIA will not access or process any information in any way, nor will it pass through IGALIA’s servers.

Likewise, you will notice that the application will request a series of special permissions with respect to your device, which we clarify below in terms of their function and purpose:

• Permission for audio recording: If you authorize this, it will be used for the aforementioned voice-to-text translation function in addition to the voice search functionality (“voice search”) provided by Meetkai, whose privacy policy can be read here: https://meetkai.com/privacy
• Permission to capture photos and videos: This may be requested if the user’s device uses cameras to record the environment and place the user in the physical space through tracing or “tracking” systems. IGALIA does not access or process any information.
• Permission to read, modify or delete photos, multimedia content and files on the memory card: This is necessary so that the browser can save local information on the device such as cache files, settings, pages visited and favorites, etc. IGALIA does not access or process said information.
• Permission to obtain location information based on sources such as GPS, telephone stations or WIFI: If you authorize this, an icon will be displayed at all times with the type of connection in your application, as well as, where appropriate, the aforementioned geolocation function mentioned above. IGALIA will in no way link the aforesaid information to you as an identified or identifiable person, although the Third Parties mentioned above may do so, if applicable. Pay attention to their legal terms. Specifically, in Huawei devices GPS information is also accessed and provided to a service of that company called “LocationService”.

We remind you again that the Third Party platforms that you access or use with this application could collect this or other identifying data about you, either filling them in voluntarily or involuntarily and/or consciously or unconsciously, possibly outside the scope of European data protection legislation. Therefore, we recommend that you inform yourself and pay special attention to the legal terms of said Third Parties, such as, for example, the following:

• Facebook: https://www.facebook.com/about/privacy/update
• Google: https://policies.google.com/privacy
• Huawei: https://www.huawei.com/es/privacy-policy

Likewise, IGALIA informs you that while using the voice recognition option of the browser, Meetkai will keep totally anonymized voice transcriptions of your voice with the purposes of improving the service provided by them. Your voice will not be kept or will be any way to connect the transcriptions with your identity. More information about MeetKai privacy policy in the following link: https://meetkai.com/es/privacy. Igalia neither has any interest in linking transcriptions with any user nor in affecting their privacy; consequently, Igalia requests that no personal or confidential information of any kind is included in their sound voice addresses.

In any case, IGALIA guarantees to the interested parties the exercise of the rights of access, rectification, deletion, opposition, limitation of treatment, and portability, regarding their personal data.

For such purposes, IGALIA has established an internal protocol/procedure to carry them out.

Interested parties can exercise their rights are as follows: by sending a request to IGALIA’s physical address: Calle Bugallal Marchesi, 22, 1o, 15008, A Coruña, Reference: “Data Protection”; or, to the following email address: info@igalia.com.

In both cases, the interested party must attach a copy of their national ID, passport, or identification document to prove their identity.

The Data Protection Officer or the department entrusted with the management of the rights will record the exercises of rights in the form, available for this purpose, in which the following data will be recorded:

• Application number: a number will be assigned to each of the received applications.
• Headquarters: if the person in charge has several headquarters, the headquarters where the request was received will be stated.
• Channel to file claims: the channel through which the request was received will be indicated: physical mail address, mail, etc.
• Filing date: the date when the request has been filed will be indicated.
• Exercised rights: the type of right the person exercised.
• Response day: the day on which the response was sent to the interested party.

The supporting documentation (receipt of request/response, communications, etc.) will be archived for the purpose of proving its correct management.

Likewise, you are reminded that you have the right to file a claim with the Spanish Data Protection Agency.

APPLICABLE LAW AND ORIGINAL LANGUAGE

This Privacy Policy is subject to Spanish law. The Privacy Policy language of this application is Spanish. For this reason, any possible divergence between the original version in Spanish and its translation into another language will be considered as predominant in the Spanish version that can be found here.