Privacy Policy

This Privacy Policy explains which personal data Futuclass OÜ (henceforth referred to as Futuclass), when providing the services as specified below, collects about You, how we use that data and how Your privacy rights are protected.
Futuclass as a data controller is committed to respecting Your privacy. Futuclass works to responsibly manage and protect Your personal data, to be transparent about our data processing practices, and to ensure our privacy standards are up to date. We will only collect, store, use and disclose Your personal data in accordance with this Privacy Policy.

INTERPRETATION AND DEFINITIONS

Interpretation

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.

Definitions

For the purposes of this Privacy Policy:
  • Account means a unique user account to access our Service or parts of our Service.
  • Application means the software program provided by the Company which can be downloaded by You on any electronic device, including but not limited to “Futuclass Education” or “Kitchen Assembly”.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Futuclass OU, Narva mnt 20, Tartu, Tartumaa, 51009, Estonia.
  • Device means any device that can access the Service such as a computer, a cellphone, a digital tablet or a Virtual Reality headset.
  • GDPR means the Regulation EU 2016/679 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).
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the usage of any Application, including Virtual Reality (VR) Application “Futuclass Education”, VR Application “Kitchen Assembly”, as well as Futuclass Teacher Portal available for subscribed users at https://portal.futuclass.com and Futuclass Website.
  • Third Party Service Provider means any natural or legal person who processes the Personal Data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company who provide services to the Company, e.g. 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, such as Google Analytics, Mixpanel, Facebook, Sentry, Unity Cloud Diagnostics.
  • Third Party Social Media Service refers to any website or any social network website through which a User can verify their identity for logging in or creating an account to use the Service.
  • Usage Data refers to data collected and stored automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a playthrough of a study module).
  • Website - Futuclass website available at https://futuclass.com, including its sub-pages and Futuclass Teacher Portal.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

COLLECTING AND USING YOUR PERSONAL DATA

Types of Personal Data Collected

Contact Data
While using Our Service, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Contact data may include, but is not limited to Your e-mail address, Your name or pseudonym or other identifier; Your other contact details that you may provide to Us.
Usage Data
Usage Data is collected and stored automatically when using the Service via an Application.
Usage Data may include information such as the name or pseudonym of a user, the duration of a playthrough of a study module; answers to the multiple choice questions presented in-game; in-app purchases (IAP) of modules; indicators of the different mode of the Application (demo, home, and school mode); build version of the Application; Unique Device Identifiers (UDI); IP addresses, Your browser type, browser version, the pages of Our Application and Website that You visit, the time and date of Your visit, the time spent on those pages and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Website Visitor Data
Website visitor data is collected and stored automatically when You visit Our Website. Website visitor data may include the following categories of Personal Data: the date and time of the visit, IP-address (may also indicate the country You are visiting the Website from), Your web browser, the type and the operation system of Your device, the referring site and information about Your user behaviour events.

Use of Your Personal Data

The Company may use Personal Data under GDPR Article 6, paragraph 1 (b) (the processing is necessary for the performance of a contract) 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.
  • 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.
  • To contact You: To contact You by email, 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 manage Your requests: To attend and manage Your requests to Us.
The Company may use Personal Data under GDPR Article 6, paragraph 1 (f) (the processing is necessary for the purposes of the legitimate interests of the controller or by a third party) for the following purposes:
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For business and product development purposes: We may use Your information for improving our Services, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products, services, marketing and user experience.
  • For resolving legal disputes: We may retain Your Personal Data which pertains to our contractual relationship to resolve disputes, and enforce our legal agreements.
  • For improving user experience: We may use the Website visitor data (as described above) to improve the Website visibility and the relevant user experience - modify and enhance the Website design and content based on the users’ activities on the Website) and its technical functioning.

Disclosure to Third Parties

We may share Your personal information in the following situations:
  • With Service Providers: We may share Your Personal Data with Service Providers to the extent this is necessary for them to provide their services to Us (including to assist us with monitoring and analyzing the use of our Service), and to contact You.
  • For business transfers: We may share or transfer Your Personal Data 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.
  • With other users: When You share Your Personal Data or otherwise interact with other users in the public areas within the Applications or on the Website (including the relevant chat channels), such information may be viewed by other users and may be publicly distributed outside the Applications. Also, users using the Services in the role of a teacher (e.g. in the Futuclass Teacher Portal) may have access to the Personal Data of other users participating in a class managed by them. Please note that if You interact with other users outside the Applications, e.g. via a Third-Party Social Media Service, the terms and conditions of such Third Party Social Media Service apply and Futuclass does not accept any liability for such interactions.
  • With Your consent: We may disclose Your personal information to any other third parties for any other purpose only upon Your prior written consent.

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).
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for 5 years from its generation.

Transfer of Your Personal Data

Your Personal Data is processed at the Company's operating premises and in any other places where the parties involved in the processing are located. It means that Your Personal Data may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction, including a third country as specified below, where the data protection laws may differ from those of Your jurisdiction.
A third country is a country other than an EU member state, EEA country or a country that does not offer an adequate level of data protection according to a relevant European Commission adequacy decision.
We do not store or transfer Your Personal Data to third countries, except in cases described herein. If necessary, Your Personal Data will only be transferred if We have concluded an agreement with the recipient which meets the requirements established in GDPR for the transfer of personal data outside the EEA (including the Standard Contractual Clauses) and have applied other relevant measures to make sure Your Personal Data is processed according to the high standards of GDPR.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred to the potential investor or other transaction counterparty. Futuclass shall take measures to minimise the scope of disclosed Personal Data, e.g. by removing specific identifiers, aggregating the data and rendering the data anonymous, if possible.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us and We apply the necessary legal, organisational, physical and technical security measures to protect Your Personal Data. The main security measures include the following.
Physical measures – the offices are locked and a “clean desk policy” is applied.
Technical measures – computers are password protected and encrypted as necessary; firewalls and antivirus programmes are applied; backups are done regularly.
Organisational measures – data protection, information security and access management rules are in place; awareness raising for the employees; , confidentiality requirements applied on employees.
However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

Right to Delete Your Personal Data

At any time a user may contact us via email ([email protected]) to request that any data collected or stored is deleted. Please keep in mind that We cannot delete any data that We process to fulfill a contractual or a legal obligation.

Protection of Your Personal Data Under GDPR

If You are a resident of the European Economic Area (EEA), You have certain data protection rights. Futuclass takes all the required steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.
If You wish to be informed what Personal Data We hold about You and if You want it to be removed from our systems, please contact us at: [email protected]
In certain circumstances, You have the following data protection rights:
  • The right to access, update or to delete the Personal Data we have on You. Whenever technically feasible, You can access, update or request deletion of Your Personal Data directly by contacting us.
  • The right of rectification. You have the right to have Your Personal Data rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to Our processing of Your Personal Data.
  • The right of restriction. You have the right to request that We restrict the processing of Your Personal Data.
  • The right to data portability. You have the right to be provided with a copy of the Personal Data we have on You in a structured, machine-readable and commonly used format.
  • The right to withdraw consent You also have the right to withdraw Your consent at any time where Futuclass relied on Your consent to process Your personal information.
Please note that we may ask You to verify Your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of Your Personal Data. For more information, please contact Your local data protection authority in the European Economic Area (EEA).

CHILDREN'S PRIVACY

Our Service does not address anyone under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

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.

IN-APP PURCHASES AND SUBSCRIPTION LICENSES

VR Applications “Futuclass Education” and “Kitchen Assembly” are free to download and try, but more content can be unlocked via In-App Purchases (IAP) or Subscription Licenses.
Please note that in case of subscribing via external providers (e.g. Meta), the relevant external provider’s policies apply. IAP are offered according to Platform In-App Purchases and Subscription Licenses are only offered in bulk to educational institutions, subject to separate contractual arrangements, both as defined by Meta in https://developer.oculus.com/policy/app-policies/.

CHANGES TO THIS PRIVACY POLICY

Futuclass retains the right to update this Privacy Policy any time by publishing the updates on Our Website.
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:
Last updated: January 23, 2023