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PRIVACY POLICY

Last Updated: September 19, 2022

VERSES, INC. (“Verses”) recognizes the need to protect its users’ privacy rights. This Privacy Policy (the “Policy”) sets forth how Verses — which for the purposes of this Policy includes all divisions, parents, subsidiaries, predecessors, successors and assigns (collectively with Verses, "we", "us", or "our") — will use and handle personally-identifiable electronic information (“PII”) provided by or collected from individual users and what choices they have regarding the collection and use of their PII. By using Verses’ Services (as defined below) or by interacting with any of its various systems and resources, you (as well as any entity or person on whose behalf you are acting) agree to the terms of this Privacy Policy. If you do not agree with the terms outlined herein, you should not provide us with PII or use our Services.

  1. Definitions:

    • "Cookies" are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. 

    • "Data Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes/means of the Processing of PII.

    • "Data Processor" means a natural or legal person, public authority, agency or any other body which Processes PII on behalf of the Data Controller.

    • "Deidenitifed Information" refers to information that cannot reasonably identify, relate to, describe, or be capable of being associated with, or be linked, directly or indirectly to, a particular individual person.  To be “deidentified,” the information must be subject to technical safeguards and business processes that prohibit reidentification of the person to whom the information pertains and seek to prevent any inadvertent release of said deidentified information.

    • “Personally Identifiable Information” or "PII" includes any information relating to or associated with an identified or identifiable natural person, whether alone or in combination with other information. PII includes, without limitation: (i) your first and last name; (ii) your telephone number; (iii) your date of birth; (iv) your email address; (iv) your Social Security number; (v) your Driver’s License or Passport number; (vi) your height, weight and other physical characteristics; (vii) your Internet browsing or search history; (vii) geolocation information; (viii) your employment history; (ix) certain audio, electronic, visual, thermal, olfactory or similar information; (x) biometric data (such as fingerprints); or (xi) purchase records for products or services, including purchasing or consuming histories or tendencies. In some jurisdiction, it also includes information that is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular household, such as a physical address, an Internet Protocol address, or property records. “PII” also includes information that would constitute “personal data” under applicable law.

    • “Processing” means any operation or set of operations that are performed on PII or on sets of personal data, whether or not by automated means.

    • “Pseudonymized Information” refers to PII processed in such a manner that it is no longer attributable to a specific individual without the use of additional information, provided that said additional information is kept separately and is subject to technical and organizational measures to ensure that it is not attributed to an identified or identifiable individual.

    • “Selling” or “Sale” of PII means, for purposes of this Policy, selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

    • “Services” means and includes, without limitation, the www.verses.io website, Verses’ proprietary “Spatial Web” Protocol, any applications (or “apps”) that interface or utilize the Verses Protocol, and any systems or technology resources constituting the Verses network, such as routers, databases, servers, and wired or wireless data connections. 

  2. Scope:   This Policy applies to: i) individuals that provide their own PII to us; or (ii) any agent that provides PII for other individuals or on their behalf.  

  3. PII Collection:  This Privacy Policy applies to the following types of electronic information:

    • PII submitted to us: “PII” (as defined above) that you provide to us.

    • PII supplied by a third party: This may include PII given for identity verification purposes, or to Process a request or an application submitted to us.

    • Financial information: This may include financial account information or financial transaction information when participating in any of our Services where such information is necessary to provide such Service.

    • Automatically-logged usage information: The Services may also record information sent by your browser, application or device when accessing and using the Services or the Internet generally. This information may include your browser type, your Internet Service Provider (“ISP”), a date/time stamp, what page(s) you viewed, what operating system your device uses, certain user preferences information (e.g. Do Not Track preferences) and other similar information.

    • Cookies and other tracking technologies: Cookies and other user tracking technologies devices may be stored on your computer when using the Services. You acknowledge the use of such tracking devices and consent to having such tracking devices stored on your computing devices. If you cannot provide such consent, you should refrain from using any of our Services. 

  4. Use of PII:  We will use PII only for fair, lawful, and legitimate purposes, including to:

    • Provide any information or Services you request;

    • Improve Service performance, quality or reliability;

    • Perform information analysis, compliance audits and data metrics where needed;  

    • Protect the Services and/or integrity of any of our systems or resources;

    • Review or respond to any questions, comments, inquiries, feedback that you submit to us, including those concerning our Services or those provided by affiliates; 

    • Administer participation or registration in any of our Services, including sending electronic communications related to such participation or registration; 

    • Process payments and fulfill a transaction between us and any user, if said user submits payment information in connection with any of our services or programs;

    • Perform relevant contractual obligations with you and/or any appropriate third party; 

    • Provide updates and other information regarding our Services; 

    • Conduct routine accounting and financial tasks; 

    • Comply with applicable laws, rules, regulations, court orders, and law enforcement requests; 

    • Audit our systems, processes and procedures to ensure proper operation; 

    • Protect against imminent harm to our rights, property, or the safety of our users or the public as required or permitted by law;

    • Provide marketing information concerning news, updates, and other information regarding our Services, where doing so is in compliance with applicable law, including without limitation the CAN-Spam Act of 2003.  

We will not use PII for any other purpose other than as set forth in this Privacy Policy. However, we may use deidentified or pseudonymized information in the same manner and for the same purposes as PII, at our sole discretion and without additional notice to you. 

5.    Selling PII:  Verses does not sell PII. However, we may, from time-time, share PII with some affiliates that are wholly owned by, or under common control of, Verses, in accordance with the restrictions outlined in this Policy. We may also share PII with Service Providers to perform specific tasks that you request from us, or for other reasons similar to those described in the previous section. Our policies require that any parties receiving PII from us agree to handle it in compliance with appropriate confidentiality obligations and security measures. Service providers are also bound by written, signed agreements restricting any use/disclosure beyond the specific context justifying the original disclosure. Verses will, upon written request, provide you with information about affiliates and/or service providers that we have shared your PII with, including but not limited to a list of the categories of PII and the purpose(s) for doing so.  

6.   Information Security and Integrity:  Verses uses commercially-reasonable industry standard safeguards (which may include physical, procedural and technical measures) to protect against the unauthorized disclosure of PII it collects and holds. We take such steps to ensure that PII collected is complete and relevant for its intended use. However, due to the open communication nature of the Internet generally, we cannot and do not represent, warrant or guarantee that any information stored on our servers will be free from unauthorized access, loss, misuse, disclosure, alteration or destruction. While we will take reasonable and appropriate security measures to protect against such unauthorized access, loss, misuse, disclosure, alteration or destruction, Verses disclaims any and all liability for same to the maximum extent permitted by applicable law.

  • Third-Party Sites:  Please be advised that one or more Services may link to or interface with other third-party websites, social media applications including Twitter, Facebook and LinkedIn, or other online resources. These are subject to the specific privacy policies of their respective proprietors, and Verses is not responsible for the privacy practices of such linked third-party sites or resources, or of their proprietors.

7.   Retention: We will retain certain PII stored on our servers in accordance with our general archival practices and as required or permitted by law. We will store PII only for as long as is required to fulfill the purposes set out above. However, where we are required by law to retain a PII longer or where PII is required for us to assert or defend against legal claims, we will retain the said PII until the end of the relevant retention period or until the claims have been resolved.

8.  European Residents: By using our Services or providing us with your PII electronically, you are directly transferring PII to us in the United States. While United States law is not subject to a European Commission Adequacy Decision, we ensure an adequate level of protection of EU data subjects’ rights by adopting the Standard Contractual Clauses (according to EU Commission Decision 2021/914/EU) or other applicable data transfer arrangements where such mechanisms are available to us.

Data Subject Rights for EU Residents:  You may be entitled to obtain access to information on the Processing of your PII, or to object to said Processing, or to have PII rectified, deleted, or restricted as permitted under EU law. You may also request that your PII be made “portable,” such as by making it available for download or external access in one or more standard commercial formats. Finally, you also may be entitled to withdraw any consent you may have given with respect to the Processing of your PII. To exercise these rights or learn more about the Processing of your PII, send us a written request to privacy@verses.io. Please note that certain PII may be exempt from such access, correction, objection, or deletion rights pursuant to local laws.

9.   California Residents:  Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”)  Verses is providing the following information concerning rights now available to California residents. While Verses does not sell PII, California residents may request certain disclosures from businesses that collect and/or use PII. For example, California Residents may request a list of all the categories of PII that we currently have on our systems, or have had within the past twelve (12) months. They may also seek a disclosure of specific pieces of PII. They may also request that any such PII be deleted within a reasonable timeframe. Any data disclosure or deletion request is subject to strict identity verification. California Residents should send an email explaining the desired request(s) to: privacy@verses.io, and referencing “CALIFORNIA CCPA RIGHTS REQUEST” in the subject line. 

  • Non-Discrimination:  Be advised that Verses will not knowingly engage in any form of discriminatory treatment toward a California resident exercising a right granted under   the CCPA. If you feel that you have been subjected to any such discriminatory treatment, please write to us at privacy@verses.io with a detailed explanation of your concerns. 

10. Nevada Residents:  In accordance with Nevada Revised Statutes 603A.340, reference is made to Sections 3, 4 and 5 above, which described the categories of PII we typically collect from users (including those residing in Nevada) and with whom it is shared. As mentioned, Verses does not sell PII. However, Nevada residents may still review and request changes to their PII by sending a written request by email to privacy@verses.io and referencing “NEVADA PRIVACY RIGHTS REQUEST” in the subject line.

11. Minors:  We do not knowingly collect or require PII from children under the age of 13. If you believe we have collected or used any PII of your child, aged 13 years of age or under, please notify us in writing by sending an email to: privacy@verses.io.  If you are a minor between 14 and 16 years of age and reside in California, you may have certain “opt-out” and disclosure rights under California Law, as described in Section 9 above.  Please drop us a line at privacy@verses.io to learn more about these rights and steps you can take to exercise them.   

12. Revisions to our Privacy Policy:  We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page prior to going into effect. While you are responsible for periodically monitoring and reviewing any updates to this Policy, your continued use of our Services after such amendments have been publicly disseminated on this page will be considered as your acknowledgement of and consent to said changes.

13.  Questions:  Should you have any questions or concerns about this Privacy Policy or any of our privacy practices, please drop us a line at: privacy@verses.io