VR4Tourism

Our website address is: https://vr4tourism.footar.co.

Introductory Information

FOOTAR, S.A., hereinafter also referred to as “we,” “our,” or “us” respects the privacy of its users (“you” or “your”). This information about the processing of personal data (“Information”) explains how we collect, use, disclose, and protect your personal data in relation to our Website, applications, and platforms, including but not limited to the “FootAR Sports in 3D” application (the “App”) available on Meta platforms (such as Oculus) in any language version or location (collectively referred to as the “Website and App”).

We process your personal data related to your use of the Website and App, registration on the Website and App, in relation to direct marketing, and in connection with the storage of HTTP cookies on your device.

1. Our Identity and Contact Details

1.1. We, as the controller of your personal data, are FOOTAR, S.A., a public limited company headquartered at Campus da Penteada – Startup Madeira, s/n, 9020-105 Funchal, Autonomous Region of Madeira, Portugal, corporate identification number 516.123.343, registered at the commercial registry office.

1.2. Our contact details are as follows: postal address Campus da Penteada – Startup Madeira, s/n, 9020-105 Funchal, Autonomous Region of Madeira, Portugal, email address info@footar.co.

1.3. We have appointed a Data Protection Officer whom you can contact for all matters related to the processing of your personal data and the exercise of your rights by sending an email to info@footar.co.

2. PROCESSING RELATED TO WEBSITE USE AND REGISTRATION

2.1. Specification of processing when using the Website. If you use the Website, we will process records related to your use of the Website (IP address, Geo IP, data about the operating system, browser type and version, and user settings of the Website) that are obtained automatically when you use the Website, and information about your age if you have provided this information to us.

2.2. Specifications of processing for registration and login. If you create an account or log in to the Website using an account previously created on our other platforms or products, we will also process your personal data when using the Website for purposes A, B, and C listed below, such as:

2.2.1. Contact information, including the email address you provided when creating your account;

2.2.2. Information about your age, if required for registration or login;

2.2.3. Data related to the use of Website features (e.g., poll votes or favorite teams);

2.2.4. A pseudonymized identifier to monitor the operation of the Website and report technical failures, other pseudonymized identifiers we implement for your protection, and if you chose to register or log in to the Website through your existing account with a third party (e.g., Facebook, Gmail, Apple), we also process your name, photo, and a pseudonymized identifier generated by the third party authorized to log in;

2.2.5. Data about your purchases, if any, in the Mobile Application.

2.3. Purposes of processing. We process your personal data to the extent necessary for the following purposes:

• • Purpose A: The purpose of processing your personal data is to fulfill a contract between you and us or to allow us to take steps before entering such a contract in relation to your registration or login to the Website.

• • Purpose B: The purpose of processing the above-mentioned personal data is to ensure the technical operation of the Website, i.e., the proper and smooth operation of the Website and troubleshooting related to reported technical errors and the consequent optimization (prevention of future errors) of the Website.

• • We have assessed the possibility of processing your personal data for this purpose and also conducted the necessary proportionality test, balancing the interests in protecting your rights against our interests. We concluded that, considering most of the personal data we process is available for other purposes, we use pseudonymized identifiers, debugging is also in the user’s interest, and subsequent optimization of the Website is in all users’ interest, it does not seem that your interests or fundamental rights and freedoms to protect your personal data outweigh our legitimate interests as set out above.

• • Purpose C: The purpose of processing your personal data is to fulfill our legal obligations, particularly in the areas of taxation, accounting, and advertising regulation.

2.4. Legal basis. The legal basis for processing personal data for each purpose is as follows:

• • For Purpose A, the fact that such processing is necessary for the performance of a contract between you and us or to allow us to take steps before entering into such a contract pursuant to point (b) of Article 6(1) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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) (the “Regulation”).

• • For Purpose B, our legitimate interest, pursuant to point (f) of Article 6(1) of the Regulation, is to ensure the technical operation of the Website.

• • For Purpose C, it is to fulfill our legal obligations pursuant to point (c) of Article 6(1) of the Regulation.

2.5. Retention period. Your personal data will be processed:

• • For Purpose A for a period of three (3) years from the end of your contract;

• • For Purpose B during the term of the contract if you have an account with us, or for 1 month after using the Website if you do not have an account; and

• • For Purpose C, for the time necessary to fulfill legal obligations under general applicable law.

2.6. Other recipients. People who provide us with technical activities, including those who provide us with hosting and software development services, and other companies in our group (“our group”) may be other recipients of your personal data. Where we are required to do so by generally binding legislation, the relevant public authorities may also be additional recipients of your personal data for the purpose of fulfilling their obligations under generally binding legislation.

2.7. Your rights. Subject to the conditions set out in the Regulation and depending on the indicated purposes, you have the right to request that we provide you with access to your personal data, the right to rectify or delete your personal data, or to restrict its processing, and the right to the portability of your personal data. Please note that we may request verification of your identity before fulfilling such a request.

2.7.1. If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, in particular, to lodge a complaint with a supervisory authority, in particular, with a supervisory authority of the EU Member State where your primary residence, place of work, or place of the alleged infringement of the Regulation is located.

2.7.2. You have the right to object at any time to the processing of your personal data for Purpose B. If you object to the processing of your personal data for Purpose B, we will not process your personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests or your rights and freedoms or where such data is necessary for the establishment, exercise, or defense of our legal claims.

2.7.3. You are not required to provide us with your personal data. However, providing your personal data is a necessary requirement for Purpose A, i.e., for entering into and executing the contract, and without providing your personal data, the contract cannot be entered into or executed, and this may prevent you from using certain components and acquisitions within the Mobile Application, which are only available to registered users. The processing of your personal data for Purpose C is a legal requirement concerning a possible purchase in the Mobile Application.

3. PROCESSING RELATED TO DIRECT MARKETING TO REGISTERED USERS

3.1. Processing specifications. If you create an account on the Website or log in to the Website through an account previously created on our other platforms or products, we may send commercial communications (marketing offers) about our similar services in accordance with general applicable law, and for this purpose, we process:

3.1.1. Contact information, including the email address you provided when creating your account;

3.1.2. Pseudonymized identifiers we implement for your protection and where you chose to register or log in to the Website through your existing account with a third party (e.g., Facebook, Gmail, Apple); we also process the pseudonymized identifier generated and provided by such third party authorized to log in;

This processing of personal data is not based on your consent, however, you have the right to object to such processing at any time.

3.2. Purpose of processing. The purpose of processing your personal data is to send you, as our customer, commercial communications in accordance with generally binding legal regulations.

3.3. Legal basis. The legal basis for processing your personal data is that such processing is necessary to meet the purposes of our legitimate interests within the meaning of point (f) of Article 6(1) of the Regulation.

3.4. Our legitimate interest. Our legitimate interest is based on the fact that you are our customer (user) and that we provide you with a clear, distinct, free, and simple opportunity to opt-out of using your electronic contact details for sending commercial communications when collecting your personal data.

3.4.1. When sending commercial communications, we act in accordance with generally binding legal legislation.

3.4.2. The preamble of point 47 of the Regulation states, among other things, that “the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest”.

3.4.3. We have assessed the lawfulness of processing your personal data for the purpose of sending commercial communications and also conducted the necessary proportionality test that evaluates the interests in protecting your rights and our interests. We concluded that, considering prior compliance with the prerequisites set out in generally binding legislation for sending commercial communications and also considering the fact that you can refuse further commercial communications at any time, it does not seem that your interests or fundamental rights and freedoms to protect the personal data you voluntarily provided outweigh our legitimate interests in sending commercial communications.

3.4.4. In light of the above and the fact that you can reasonably expect that your personal data will be processed for the purpose of sending commercial communications, we consider our legitimate interest as the legal basis for processing your personal data for the purpose of sending commercial communications.

3.5. Retention period. Your personal data will be processed by us for a period of three (3) years from the end of your contract, and no later than until you object or make any other similar request regarding the processing of personal data for the purpose of sending commercial communications by us, including exercising your right to opt-out of personal data.

3.6. Other recipients. Other recipients of your personal data are people who provide us with marketing services in accordance with our instructions, people who operate our website or mobile applications (data processors), and other companies in our group.

3.7. Your rights. Subject to the terms of the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectify or delete your personal data, or the right to restrict the processing of your personal data.

3.7.1. If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, in particular, to lodge a complaint with a supervisory authority, in particular, with a supervisory authority of the EU Member State where your primary residence, place of work, or place of the alleged infringement of the Regulation is located.

3.7.2. You have the right to object at any time to the processing of your personal data for marketing purposes, including profiling, where the profile is related to such direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for these purposes.

4. PROCESSING RELATED TO DIRECT MARKETING (WITH YOUR CONSENT)

4.1. Processing specifications. With your consent, we process your:

4.1.1. Contact information, including the email address you provided when creating your account;

4.1.2. Information about your age, if you have provided it;

4.1.3. Pseudonymized identifiers we implement for your protection and, where you chose to register or log in to the Website through your existing account with a third party (e.g., Facebook, Gmail, Apple), we also process the pseudonymized identifier generated and provided by such third party authorized to log in;

4.1.4. Data about your use of the Website (e.g., IP address and Geo IP) and identification data relating to your device (e.g., operating system, browser, browser version), which are collected automatically when you use the Website;

for the purpose of sending you commercial communications (marketing offers) that promote us, our group, or third parties, or for the purpose of carrying out other marketing activities for you, including marketing profiling and subsequent personalization of displayed advertising. This processing of personal data is based on your explicit consent, which you have the right to withdraw at any time.

4.2. Purpose of processing. The purpose of processing your personal data is to send you commercial communications and carry out other marketing activities directed at you, including marketing profiling.

4.3. Legal basis. The legal basis for processing your personal data is the consent you have given us within the meaning of point (a) of Article 6(1) of the Regulation.

4.4. Retention period. We will process (store) your personal data for a period of four (4) years from the receipt of your consent for processing, and the processing will cease if you withdraw your consent for processing your personal data for this purpose.

4.5. Other recipients. Additional recipients of your data are people who provide us with marketing and advertising services, in particular, the entities listed here, as well as people who operate our website or mobile applications and other companies in our group (data processors), and the most used social networks, such as Facebook, Twitter, LinkedIn (as controllers or joint controllers, as the case may be).

4.6. Your rights. Subject to the conditions set out in the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectify or delete your personal data, or restrict its processing, and the right to the portability of your personal data.

4.6.1. At any time, you can exercise your right to withdraw consent for processing the personal data you provided to us. This does not affect the legality of the processing of your personal data before such withdrawal of consent. You can withdraw your consent for processing your personal data by clicking on the link provided in any commercial communication we send you or by sending an email to our contact email address (see Article 1.2 of this Information).

4.6.2. If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, in particular, to lodge a complaint with a supervisory authority, in particular, with a supervisory authority of the EU Member State where your primary residence, place of work, or place of the alleged infringement of the Regulation is located.

4.6.3. You are not required to provide us with personal data. The provision of your personal data is not a legal or contractual requirement, nor is it a requirement necessary for entering into a contract.

5. PROCESSING RELATED TO PLACING HTTP COOKIES ON YOUR DEVICE

5.1. Processing specifications. Through the cookie bar located on the Website (the “Bar”), you can give us consent for the processing of your personal data related to the storage of HTTP cookies on your device.

5.2. Purpose of processing. The purpose of processing personal data varies depending on the nature of the stored cookies, and more detailed information will be provided to you within the Bar or in any other document published by us.

5.3. Legal basis. The legal basis for processing your personal data is the consent you have given us within the meaning of point (a) of Article 6(1) of the Regulation.

5.4. Retention period. Information on the retention period of personal data concerning the storage of individual cookies varies depending on the nature of the stored cookies, and more detailed information will be provided to you within the Bar or in any other document published by us.

5.5. Other recipients. The categories of recipients of your personal data vary depending on the nature of the stored cookies, and more detailed information will be provided to you within the Bar or in any other document published by us.

5.6. Your rights. Subject to the conditions set out in the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectify or delete your personal data, or restrict its processing, and the right to the portability of your personal data.

5.6.1. At any time, you can exercise your right to withdraw consent for processing the personal data you provided to us. This does not affect the legality of the processing of your personal data before such withdrawal of consent. You can withdraw your consent for processing your personal data through the Website.

5.6.2. If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, in particular, to lodge a complaint with a supervisory authority, in particular, with a supervisory authority of the EU Member State where your primary residence, place of work, or place of the alleged infringement of the Regulation is located.

5.6.3. You are not required to provide us with personal data. The provision of your personal data is not a legal or contractual requirement, nor is it a requirement necessary for entering into a contract.

6. SECURITY OF YOUR INFORMATION

6.1. To protect your personal data, we use administrative, technical, and physical security measures in accordance with generally binding legal legislation.

7. OTHER INFORMATION

7.1. Automated Decision-Making. We do not conduct individual automated decisions within the meaning of Article 22 of the Regulation.

7.2. Third-Party Activities. We are not responsible for the actions of third parties to whom you disclose personal or confidential information and do not have the authority to direct or control the sending of offers by third parties. If you wish to stop receiving correspondence, emails, or other communications from third parties, please contact those third parties directly.

8. TRANSFER OF PERSONAL DATA OUTSIDE THE EU

8.1. We do not intend to knowingly transfer your personal data to a third country (a country outside the EU) or international organization. However, some of our partners, such as the other recipients of personal data mentioned above, may be based in countries outside the EU or store data on servers outside the EU. In such cases, there may be a “transfer of your data to third countries (to a country outside the EU)” within the meaning of the Regulation, including to countries for which the European Commission has not yet decided on adequate protection identical to European law. In such cases, we will ensure that your personal data will be processed and protected in accordance with our standard privacy policy but also through appropriate safeguards established in Article 46 of the Regulation and available, for example, here.

9. CHANGES AND ADDITIONS

9.1. We will notify you of any changes to this Information.

9.2. We encourage you to check this information regularly to be aware of your rights.

10. FootAR Sports in 3D on Meta Platforms

10.1. This policy also applies to the “FootAR Sports in 3D” application available on Meta platforms, such as Oculus.

10.2. Processing specifications. When using the App, we may collect and process additional data specific to the virtual reality environment, including but not limited to interaction data, movement tracking, and other sensor data relevant to your experience.

10.3. Purpose of processing. The processing of your personal data within the App is aimed at enhancing your user experience, ensuring the proper functioning of the App, and enabling personalized services.

10.4. Legal basis. The legal basis for processing your personal data within the App is the performance of a contract, our legitimate interests, or your consent, as applicable.

10.5. Retention period. Data collected through the App will be retained in accordance with the periods specified above unless otherwise required by law or if you withdraw your consent.

10.6. Other recipients. Data may be shared with third-party service providers for analytics, technical support, or marketing purposes, in compliance with applicable laws.

10.7. Your rights. You have the right to access, correct, delete, or restrict the processing of your data, as well as the right to object to or withdraw consent for data processing within the App.

Comments

When visitors leave comments on the site, the data shown in the comments form is collected, as well as the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

When uploading images to the website, you should avoid uploading images with embedded geolocation data (EXIF GPS). Visitors can download and extract geolocation data from the images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit the login page, a temporary cookie will be set to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, several cookies will be set to save your session information and your screen display choices. Login cookies last for one year. If you select “Remember Me”, your session will persist for two weeks. When you log out, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and only indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the same way as if the user visited those websites.

This site may collect data about you, use cookies, embed third-party tracking, monitor your interactions with it, including recording interactions with embedded content if you have an account and are logged in to that website.

Who your data is shared with

If you request a password reset, your IP address will be included in the reset email.

How long is your data retained?

If you leave a comment, the comment and its metadata are saved indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights do you have over your data?

If you have an account on this site, or have left comments, you can request to receive an export file containing the personal data we hold about you, including any personal data you have provided. You can also request that the saved data be deleted. This does not include any personal data that we are required to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments can be checked through an automated spam detection service.

FOOTAR, S.A.