Privacy Policy

Effective Date: Feb 03, 2026

Welcome to SANDBOX VR , INC. (“Sandbox VR,” “we,” “our” or “us”) Privacy Policy. At Sandbox VR, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. 

Remember that your use of Sandbox VR's Services is at all times subject to our Terms of Service at https://sandboxvr.com/terms, and should be read in addition to this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

You may print a copy of this Privacy Policy by clicking here.

• What this Privacy Policy Covers

• Personal Data

  • Categories of Personal Data We Collect

  • Categories of Sources of Personal Data

  • Our Commercial or Business Purposes for Collecting Personal Data

• How We Disclose or Transfer Your Personal Data

• Tracking Tools, Advertising and Opt-Out

• Data Security and Retention

• Personal Data of Children

• California Resident Rights

• Other State Law Privacy Rights

• Canadian Privacy Rights

• Changes to this Privacy Policy

• Contact Information

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information or opinion, whether it is true or not, that identifies, reasonably identifies or relates to a particular individual and also includes information referred to as “personally identifiable information”, “personal information” or “personal data” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

We do not collect any sensitive data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where permitted, we collect Personal Data about you from the following categories of sources:

• You

  • When you provide such information directly to us.

    • When you create an account or use our interactive tools and Services.

    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

    • When you book a Service or order our gift card.

    • When you send us an email or otherwise contact us.

  • When you use the Services and such information is collected automatically.

    • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).

    • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

    • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

    • When you take part in an experience and we take your photo and/or video of your experience.

• Third Parties

  • Vendors

    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

    • We may use vendors to obtain information to generate leads and create user profiles.

  • Advertising Partners

    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications. This can include your internet/network activity and personal information such as your name and email address. 

  • Social Networks

    • If you are located in China, we may receive limited information about you through the WeChat Mini Program to enable to you to sign up with Sandbox VR.

Note that we do not disclose mobile phone information or text messaging originator opt-in consents with third parties for their own marketing purposes.

• Providing, Customizing and Improving the Services

  • Creating and managing your account or other user profiles.

  • Processing orders or other transactions; billing.

  • Providing you with the products, services or information you request.

  • Meeting or fulfilling the reason you provided the information to us.

  • Providing support and assistance for the Services.

  • Improving the Services, including testing, research, internal analytics and product development.

  • Personalizing the Services, website content and communications based on your preferences.

  • Doing fraud protection, security and debugging.

  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

• Marketing the Services

  • Marketing and selling the Services.

  • Showing you advertisements, including interest-based or online behavioral advertising.

• Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Sandbox VR or the Services.

  • Sending emails and other communications according to your preferences or that display content that we think will interest you.

• Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations and being in compliance under applicable law, regulation, court order, subpoenas or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities, and disclosing your Personal Data where Sandbox VR reasonably believes that disclosure or use is necessary to respond to lawful requests by public authorities, meet or assist in law enforcement requirements.

  • Protecting the rights, property or safety of you, Sandbox VR or another party.

  • Enforcing any agreements with you.

  • Responding to claims that any posting or other content violates third-party rights.

  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

We disclose or transfer your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures or transfers may constitute a “sale” or “share” of your Personal Data. For more information, please refer to the “Other State Privacy Laws” section below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

  • Hosting, technology and communication providers.

  • Security and fraud prevention consultants.

  • Support and customer service vendors.

  • Payment processors.

    • Our payment processing partners Adyen, Checkout Ltd (Checkout.com), Stripe, Inc. (“Stripe”), or Square collect your voluntarily-provided payment card information necessary to process your payment.

    • Please see Adyen's, Checkout.com's, Stripe’s or Square’s terms of service and privacy policy for information on their handling of your Personal Data.

• Advertising Partners. These parties help us market our Services and provide you with other offers that may be of interest to you. They include marketing providers.

• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

  • Companies that track how users found or were referred to the Services.

  • Companies that track how users interact with the Services.

• Other Players. Videos, photos, or recordings from your experience at Sandbox VR may be displayed on our leaderboard and therefore visible to other Sandbox VR players. Upon entering the Sandbox VR premises, you understand that any activities or conversations may be recorded, and that they cannot be expected to be private.

• Subsidiaries. Our U.S. subsidiaries Glostation USA, Inc., GloStation Franchising USA, Inc. and Glostation Core USA, Inc. assist us in our U.S. operations and franchise management. 

• Franchisees. We may share information collected through the Services with the owner of any one of our franchisee locations that you have visited or in which you have expressed interest. These franchisees are permitted to share your information with their employees for the purposes of operating their business and to use your information for their own marketing purposes and in a manner otherwise consistent with this Privacy Policy and our franchise agreements. While we require our franchisees to adhere to the principles and practices outlined in this Privacy Policy when handling personal information, each franchisee operates as an independent business. As such, we do not control and are not responsible for the privacy practices of our franchisees. We obligate our franchisees, through contractual agreements, to use personal information only for the purposes permitted under this Privacy Policy and applicable law.

• Publicly Available. Information that is publicly available such as any Personal Data included in social media posts that tag us from social media plugins.

Note that we do not disclose mobile phone information or text messaging originator opt-in consents with third parties for such third parties to use for their own marketing purposes. 

We and our service providers may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the subsection “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Any or all of your Personal Data that we collect may be transferred to a third party if in relation to a prospective or completed merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we may make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

We may create aggregated or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, operate and improve our Services and deliver ads. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies and the lack of a standard for “Do Not Track”, the Services do not support “Do Not Track” requests sent from a browser at this time. We will honor the global privacy control signal.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services, set your privacy preferences, or fill in forms. Disabling these Cookies may make certain features and services unavailable.

• Performance Cookies. Performance Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited the website, and will not be able to monitor its performance. Sandbox VR’s website uses the Google Analytics services to provide better content and service. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Service and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at https://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on  at https://support.google.com/analytics/answer/181881?hl=en. 

• Targeting Cookies. Targeting Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” For example, we use retargeted advertising cookies from LinkedIn and Facebook.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. Depending on your location, you may also opt-in or opt-out of certain cookies such as performance cookies or targeting cookies by accessing the Cookie Settings, https://sandboxvr.com#cookies by contacting us.

To explore what Cookie Settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org or https://ico.org.uk/for-the-public/online/cookies if you are located in the European Union.

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors social media, research firms, and other websites, to serve advertisements and targeted advertisements through the Services to you or other users. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site. The legal basis for processing this information is legitimate interests which is detailed in “Our Commercial or Business Purposes for Collecting Personal Data” section.  We may also provide a hashed version of your email address or other information to the platform provider for such purposes. 

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://m.facebook.com/help/568137493302217?_rdr. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

You can opt out of the use of your information by sending us a request using any of the methods set forth in the “Contact Us” section below. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/ or the Digital Advertising Alliance in Canada https://youradchoices.ca/choices, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.

We seek to protect your Personal Data from unauthorized access, use and disclosure using reasonable physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

We do not target and our Services are not directed to children under the age of 13. The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from a child under 13 (or children under the age of 14 in Canada) without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (“Required Information”). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent. If you are a child under 13 years of age (or a child under the age of 14 in Canada), please do not attempt to send any Personal Data about yourself to us before we obtain Parental Consent, except for the Required Information in the context of the Parental Consent process. If you believe that a child under 13 years of age (or a child under the age of 14 in Canada) has provided us with Personal Data (beyond the Required Information) without our obtaining Parental Consent, please contact us at [email protected]. We do not condition participation in our Services on disclosure of more Personal Data from a child under 13 years of age (or a child under the age of 14 in Canada) than is reasonably necessary for that participation, and we do not retain Personal Data from children under 13 years of age (or children under the age of 14 in Canada) longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.

If you are a parent or guardian of a user of our Services who is under 13 years of age (or 14 years of age if the child is in Canada), you may contact us at any time to ask that (a) we stop collecting Personal Data from such user, (b) we delete any Personal Data already collected from such user (although note that we may further retain information in an anonymous or aggregated form where that information would not identify such user personally), or (c) we stop disclosing Personal Data collected from such user to third parties, but continue to allow for collection and use of Personal Data collected from such user in connection with the Services.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to request information about and/or to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.

• The categories of sources from which that Personal Data was collected.

• The business or commercial purpose for collecting or selling your Personal Data.

• The categories of third parties with whom we have shared your Personal Data.

• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. You also have the right to receive your Personal Data in a transmittable format. 

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

You have the right to have corrected any inaccurate Personal Data that we have collected and retain.

Sandbox VR does not sell your Personal Data to third parties for monetary consideration. We use online analytics to measure the ways users engage with our websites, services, and to provide targeted marketing. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics for cross-contextual behavioral advertising and facilitate online advertising, we use third parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our digital properties and on third party digital properties as set forth in our https://sandboxvr.com#cookies.  As such, California law may classify this sharing with contracted third parties as a “sale” or “share” of Personal Data. You may opt-out of our “selling” and “sharing” by accessing the Cookie Settings, https://sandboxvr.com#cookies or by contacting us.

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.You may submit a Valid Request using the following methods:

• Email us at: [email protected]

• Submit a webform at this link: https://preferences.sandboxvr.com/privacy

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Sandbox VR may offer benefits that could qualify as a financial incentive under certain state laws, in the form of a discount or special offers. If you opt-in to these financial incentives, Sandbox VR may retain, use and/or disclose your Personal Data as described in this Privacy Policy. Participation is entirely voluntary and you may opt- out at any time by contacting us at [email protected]. The value of your Personal Data under such benefits varies according to your engagement with the program.

We may add or change incentive programs and/or their terms by posting notices on the program descriptions and terms linked to the above so check them regularly. 

Please note that we do not currently sell your Personal Data within the scope of, and according to the defined meaning of “sale” under the Nevada Revised Statutes Chapter 603A.

If you are a resident of Colorado, Utah or Texas, you may have the following rights with respect to Your Personal Data: 

• Right to access and data portability. You can request and receive a copy of the Personal Data we have collected, used, or otherwise processed and you can confirm what Personal Data has been collected. 

• Right to correct inaccuracies. You can request that we correct any inaccurate Personal Data we may have.  

• Right to delete. You can request deletion of your Personal Data. 

• Right to opt-out.  You can opt-out of targeted advertising, the sale of your Personal Data or limited sharing of your Personal Data. Please click here https://sandboxvr.com#cookies to opt-out. Right to appeal. At times we may be unable to process requests relating to your Personal Data, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request via emailing [email protected]. 

You may exercise such rights by emailing us at [email protected] to submit requests for deletion, access, correction or appeals, or to opt-out of targeted advertising.

Marketing Communications 

If you have signed up to receive email or text updates or other marketing communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by replying “STOP” to any of our text messages. You may also withdraw your consent by contacting us as set out in the “Contact Information” section below. Please note that you may continue to receive transactional or account-related communications from us.

Exercising Your Privacy Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in, and withdraw consent to our collection, use and disclosure of, your Personal Data in our custody or control. You may make such a request or withdraw your consent by using the contact information set out below. We may request certain Personal Data for the purpose of verifying your identity.

Transfer of Personal Data 

We and our service providers may access, store and otherwise process Personal Data outside of Canada (including, for residents of the province of Quebec, outside of Quebec), including in the United States and other foreign jurisdictions. We and our service providers may disclose your Personal Data if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate. For information about the manner in which we or our service providers treat Personal Data, please contact us as set out below.

Information about our Privacy Governance Policies and Practices

We are committed to protecting Personal Data and have implemented a comprehensive set of policies and practices that govern our treatment of Personal Data. These policies and procedures include, among other things, the following:

• We have implemented policies and procedures to protect Personal Data in our custody and control from unauthorized access, use or disclosure.

• We have implemented processes to respond to data subject requests and complaints in a timely and effective manner.

• As set out above, we have implemented a framework for the retention and destruction of Personal Data to ensure compliance with legal obligations, and to securely destroy Personal Data once no longer required.

• We have designated a Privacy Officer who is responsible for overseeing the company’s compliance with privacy legislation.

• We have implemented a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of Personal Data.

• We provide our employees with regular privacy training and awareness.

If you are a resident of the European Union (“EU”), Switzerland, United Kingdom, Lichtenstein, Norway or Iceland, we should like to provide you with some additional information about our data processing practices. You also have specific rights as a data subject. 

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Sandbox VR Inc. (548 Market St PMB 51330 

San Francisco, California 94104-5401 US, [email protected]) will be the main controller of your Personal Data processed in connection with the Services. Our U.S. subsidiaries Glostation USA, Inc., GloStation Franchising USA, Inc. and Glostation Core USA, Inc. act as both processors on our behalf and as independent controllers for certain U.S. operations and franchise management, depending on the specific Personal Data. Our data protection officer can be contacted under [email protected].

If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected].

PERSONAL DATA WE COLLECT

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you. 

PERSONAL DATA USE AND PROCESSING GROUNDS 

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data. 

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity pursuant to Art. 6 para. 1 lit. b GDPR: We process inter alia the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. 

  • First and last name 

  • Unique identifiers such as passwords 

  • Digital Signature 

  • Payment information 

  • Full credit or debit card number 

  • Billing address, phone number, and email 

  • Age/date of birth 

  • Zip code 

  • Data about the use of the Service 

• Legitimate Interest pursuant to Art. 6 para. 1 lit. f GDPR: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: 

  • User Photo or video taken during your experience at Sandbox VR 

  • Web page interactions 

  • Referring webpage/source through which you accessed the Services 

  • Non-identifiable request IDs 

  • Statistics associated with the interaction between device or browser and the Services o Browsing or search history 

  • Gender 

  • Photos, videos or recordings of your environment 

  • We may also de-identify or anonymize Personal Data to further our legitimate interests. 

Our legitimate interests are mostly identical to the purposes mentioned in the “Our Commercial or Business Purposes for Collecting Personal Data” section and include (as described in more detail above): 

• Providing, customizing and improving the Services.

  • Marketing the Services. 

  • Corresponding with you.

  • Preventing fraud and ensuring security of the systems and Services. 

  • Meeting legal requirements and enforcing legal terms. 

  • Completing corporate transactions. 

• Consent pursuant to Art. 6 para. 1 lit. a GDPR: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 

• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest. 

As far as we process your Personal Data for purposes of tracking or advertising including interest-based advertising or in case we use cookies or similar technologies, the “Tracking Tools, Advertising and opt-out” section above explains how we use your Personal Data with the proviso that we can only use cookies that do not classify as “Essential Cookies” if you have provided your opt-in consent, which you can withdraw at any time. 

SHARING PERSONAL DATA 

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with service providers and third parties. 

EU, SWISS AND UK DATA SUBJECT RIGHTS 

If you are a resident of the EU, Switzerland, United Kingdom, Lichtenstein, Norway or Iceland, you have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be required to fully comply with your request, such as if it is 

manifestly unfounded or excessive, if it jeopardizes the rights of others, or if it is not required by law for other reasons, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. 

• Access (in accordance with Art. 15 GDPR): You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account. You can also make an access request by submitting a webform at this link: https://preferences.sandboxvr.com/privacy .

• Rectification (in accordance with Art. 16 GDPR): If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 

• Erasure (in accordance with Art. 17 GDPR): You can request that we erase some or all of your Personal Data from our systems in case a relevant ground for the erasure applies. You can also request that we erase your Personal Data by submitting a webform at this link: https://preferences.sandboxvr.com/privacy. 

• Withdrawal of Consent (in accordance with Art. 7 para. 3 GDPR): If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. The lawfulness of the processing that took place on the basis of consent until the withdrawal, remains unaffected. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. 

• Portability (in accordance with Art. 20 GDPR): You can ask for a copy of your Personal Data that you have provided to us in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. 

• Objection (in accordance with Art. 21 GDPR): You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes. 

• Restriction of Processing (in accordance with Art. 18 GDPR): You can ask us to restrict further processing of your Personal Data. 

• Automated Decision-Making, Profiling (in accordance with Art. 22 GDPR): You have the right to contact us and let us know that you do not want to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects on you. 

• Right to File Complaint (in accordance with Art. 77 GDPR): You have the right to lodge a complaint about Sandbox VR'S practices with respect to your Personal Data with a supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en. Please also see Transfers of Personal Data below for complaint process. If you are in the UK, you can contact the UK's data protection authority at https://ico.org.uk/make-a-complaint/. If you are in Switzerland, you can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html. 

TRANSFERS OF PERSONAL DATA 

The Services are hosted and operated in the United States (“U.S.”) through Sandbox VR and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. Customers in Switzerland have therefore to be aware that their data may be processed both in Europe and in the US; in exceptional cases, in any country in the world. In the absence of an adequacy decision

applying to the data transfers by Sandbox VR, we may rely on other mechanisms to provide appropriate safeguards, such as the EU Standard Contractual Clauses (“SCCs”). 

Sandbox VR, Inc. and its U.S. subsidiaries Glostation USA, Inc., GloStation Franchising USA, Inc. and Glostation Core USA, Inc. (individually and collectively referred to as”Sandbox VR” hereunder) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (collectively the “DPF Principles”) as set forth by the U.S. Department of Commerce. The Federal Trade Commission has jurisdiction over Sandbox VR’s compliance with the DPF Principles. Sandbox VR has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF and from Switzerland in reliance on the Data Privacy Framework Principles (Swiss-U.S. DPF Principles). If there is any conflict between the terms of this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the Data Privacy Framework website, and to view our certification, please see here https://www.dataprivacyframework.gov/ . If you would like to exercise any of your rights detailed above, please contact us at [email protected]. 

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Sandbox VR commits to resolve DPF Principles-related complaints about our collection and use of your personal information through an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledge of your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. Finally, if you have a complaint that we have violated the DPF Principles that has not been resolved by other means, you may have the ability to invoke binding arbitration as outlined more fully on the DPF website. 

If we transfer your personal data onward to a third party, we will continue to remain liable under the DPF Principles if the information is processed in a manner inconsistent with the DPF Principles unless Sandbox VR is not responsible for the event giving rise to the liability. 

Depending on the circumstances, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Information about our Privacy Governance Policies and Practices 

We are committed to protecting Personal Data and have implemented a comprehensive set of policies and practices that govern our treatment of Personal Data. These policies and procedures include, among other things, the following: 

• We have implemented policies and procedures to protect Personal Data in our custody and control from unauthorized access, use or disclosure. 

• We have implemented processes to respond to data subject requests and complaints in a timely and effective manner. 

• As set out above, we have implemented a framework for the retention and destruction of Personal Data to ensure compliance with legal obligations, and to securely destroy Personal Data once no longer required.

• We have designated a Privacy Officer who is responsible for overseeing the company’s compliance with privacy legislation. 

• We have implemented a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of Personal Data. 

• We provide our employees with regular privacy training and awareness. 

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Sandbox VR website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

If you have any questions or comments about this Privacy Policy, the ways in which we or our service providers collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: [email protected].

General Data Protection Regulation (GDPR) – European Representative Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Sandbox VR has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: -by using EDPO’s online request form: https://edpo.com/gdpr-data- request/ -by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium 

Swiss Federal Act on Data Protection – Switzerland Representative Pursuant to Article 14 of the FADP, Sandbox VR has appointed EDPO Switzerland as its Representative in Switzerland. You can contact EDPO Switzerland regarding matters pertaining to the FADP: -by using EDPO Switzerland's online request form: https://edpo.com/swiss-data- request/ -by writing to EDPO Switzerland at Rue de Lausanne 37, 1201 Geneva, Switzerland 

UK General Data Protection Regulation (GDPR) - UK Representative Pursuant to Article 27 of the UK GDPR, Sandbox VR has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR: - by using EDPO’s online request form: https://edpo.com/uk-gdpr-data- request/ - by writing to EDPO UK at Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom