Last revised: May 21, 2024

Your privacy is important to Palatial Platforms, Inc. (“Palatial”, “we”, “us”, or “our”). This Palatial Privacy Policy (“Privacy Policy”) describes how Palatial may collect, use, store, disclose, process, and transfer your personal information, through your access to or use of Palatial products and services, including those at www.palatialxr.com, subdomains, any website of ours that links to this Privacy Policy, related websites, mobile software applications, and other offerings (collectively, the “Services”). By using these Services or opting into this Privacy Policy, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services. Palatial may change this Privacy Policy from time to time by posting changes at www.palatialxr.com/privacy-policy and may send notification emails regarding such changes. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

Palatial encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

Privacy Policy Applicability

This Privacy Policy applies when you access the Services or share information with Palatial. Palatial may revise this Privacy Policy at any time.

Information We Collect from You 

We collect all information that you provide including information you provide via the Services, your devices (e.g., computers, smartphones, and tablets), telephone and email, as well as information we receive from partners and using cookies and other such technologies. This includes, among other things, information collected during registration, during your use of the Services, and information you make available to third parties as a part of using the Services.

How We Use Your Information

We process your personal information only with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Palatial, including marketing the Services and other products or services offered by Palatial.

How We Share Your Information 

We share your information with our partners, service providers, contractors, agents, and third-party vendors as they need it to help us provide the Services or your subscription to the Services, or for other requests you make of Palatial.  We may also share your information to comply with law or for other legitimate interests.

How We Store and Secure Your Information

Palatial may store your information in any country where Palatial or its affiliates, partners, or providers operate facilities, and we will retain your information as long as necessary for the purposes outlined in this Privacy Policy or for so long as permitted by law, whichever is shorter. Palatial takes technological and organizational measures designed to protect your personal information against loss, theft, and unauthorized access, use, disclosure, or modification.

Accessing and Updating Your Information

You can access, get copies of, delete, change, or correct your personal information, or request changes to our use of your personal information by, using the contact information below. You may have additional rights based on where you reside.

Additional Privacy Information 

Palatial’s databases are located in the United States, and you consent to the transfer of your personal information from your location to the United States. The Services are not for use by children under the age of 16 years old or the lowest age permitted by applicable law. You may have additional rights under applicable law. If you have any questions about this privacy policy, please contact us via the information below.

European Union, United Kingdom, and Swiss Data Subject Rights

If you are an EU, UK, or Swiss resident, you may have additional rights under applicable privacy laws and regulations.

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Privacy Policy Applicability

This Privacy Policy applies when you access or use the Services or share information with Palatial. By accessing or using the Services and/or opting into this Privacy Policy (as applicable in your jurisdiction), you consent to this Privacy Policy. Palatial may update this Privacy Policy at any time. If you do not consent to this Privacy Policy for any reason, please do not access or use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services and not to any other third-party website linked to or from it, or any third-party website in which Palatial’s content or functionality is embedded. We do not control the privacy policies or practices of others.

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Information We Collect From You

In general, we receive and collect all information you provide via the Services, including through website input fields (including advertisements), phone, email (including email campaigns), web chat, or other such ways. This includes personal information that can identify or relates to you, including, but not limited to:

• Profile or Contact Data
  • Examples may include: First and last name, Email address, Unique identifiers, such as usernames and passwords
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Commercial Data
  • Examples may include: Records of products or services sold, used, or purchased
  • Categories of sources from which such personal information is collected: You
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Device/IP Data
  • Examples may include: IP address, Browser type, Type of device, Information collected automatically through cookies and similar technology, device type, domain names, and access time/logs
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Geolocation Data
  • Examples may include: IP-address-based location information
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Web Analytics
  • Examples may include: Web page interactions, Referring webpage/source through which you accessed the Services, Browsing activity, including the addresses of website that you visit, Non-identifiable request IDs, Statistics associated with the interaction between device or browser and the Service
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Professional or Employment-Related Data
  • Examples may include: Employer, Job title
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate
• Sensory Data
  • Examples may include: Photos, Videos, Recordings
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Partners you authorize, access, or authenticate
• Other Identifying Information that You Voluntarily Device to Provide
  • Examples may include: Identifying information in emails, texts, letters, or other communications you send us, Identifying information you post to blogs, competitions, live chats, forums, or message boards
  • Categories of sources from which such personal information is collected: You, Palatial's affiliated entities, partners, etc., Other independent third-party sources
  • Categories of third parties or services providers with whom we share such personal information: Data analytics providers, Partners you authorize, access, or authenticate

You have the choice on what information to share and the Services you want to engage. You can choose not to provide information to us, but in general, some information about you is required in order for you to access certain functionalities of the Services.

We also may periodically obtain information about you from affiliated entities, partners and other independent third-party sources and will add it to our database of information, including any information that you provide to third parties that are associated or whose products and/or services are integrated with the Services. For example, we may have access to information you provide in user forums related to our products and services that we maintain through third-party platforms, such as Discord.

Additionally, you may provide personal information to us to facilitate your access to and interaction with a third-party provider, such as Epic Games through its Unreal Engine product (each provider, a “Palatial Service Provider”). Any usage of that information will be subject to the agreement(s) in place between you and such Palatial Service Provider. Unreal Engine’s Privacy Policy can be found at https://www.epicgames.com/site/en-US/privacypolicy?lang=en-US. 

We may use cookies, heat mapping, log files, and similar tracking technologies, including those from third-party service providers like Google Analytics, LinkedIn Insight Tag, Air Table, Amplitude, Segment, and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. For example, we may collect your IP address, device and Internet service provider information, Web browser details and the address of any referring website. We may also collect information about your online activity, such as pages viewed and interactions with the Services. By collecting and using this information, we may operate and personalize the Services for you.  For more information on how we use cookies, please see the “Cookies” section below.

The Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com.  You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.

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Sensitive Information

Palatial does not collect any sensitive personal information through our Services. Sensitive personal information, as defined by applicable data protection laws, includes information relating to your race, ethnicity, religious beliefs, moral beliefs, philosophical beliefs, sex life, sexual orientation, gender identity, political opinions, trade union membership, medical information (including mental health), genetic data, biometric data, or financial information (such as account numbers). We also do not collect any information about criminal convictions or offences.

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Cookies

Cookies, also known as tracking cookies or browser cookies, and similar technologies such as web beacons, clear GIFs, pixel tags, and JavaScript (collectively, “Cookies”) are small pieces of data, usually text files, placed on a computer, tablet, phone, or similar device when you use that device to access the Services. We use the following types of Cookies:

• Essential Cookies. Essential Cookies are necessary for providing you with services and features that you requested. For example, these Cookies allow you to log into and stay logged into secure areas of the Services, save language preferences, and more. These Cookies are required to make the Services available to you, so they cannot be disabled.
• Functional Cookies. Functional Cookies are utilized to record your choices and settings, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us personalize our content for you, keep you logged in to your account, greet you by name, and remember your preferences.

• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors (like you) use our Services. These Cookies accomplish this by collecting information about the number of visitors to the Services, what pages visitors view the most, and how long visitors view specific pages. These Cookies also help us measure and manage the performance of our advertising campaigns in order to help us improve the campaigns and the Services’ content. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. 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 Use 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 http://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You have the option to decide through your internet browser’s settings whether or not to accept Cookies. Most browsers allow users to choose whether to turn off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the browser) allow you to toggle whether to accept each new Cookie. You can also clear 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 the Services and some functionalities may not work.

To explore what Cookie settings are available to you, look in the “settings”, “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 generally, please visit http://www.allaboutcookies.org/.

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How We Use Your Infomation

We process your personal information with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Palatial as described in this Privacy Policy.

More specifically, we may use your personal information to: 

• Optimize and improve the Services. We continually try to improve the Services based on the information and feedback we receive from you and our other users, including by optimizing the content on or functionalities of the Services.
• Personalize the user experience. We may use your information to measure engagement with the Services and to understand how you and our other users interact with and use the Services and other resources we provide.
• Improve customer service. Your information helps us to more effectively develop the Services and respond to your support needs.
• Process transactions. We may use the information you provide to fulfill your requests. We do not share this information with outside parties except to the extent necessary to provide the Services and related activities.
• Send periodic general and marketing communications. The communication methods you provide through our contact forms will be used to send information and updates pertaining to the Services. It may also be used to respond to your inquiries or other requests. If you opt into our mailing list, you may receive emails that include Palatial news, updates, product offerings and service information, and marketing material. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below.
• Carry out other legitimate business interests. We may use the information you provide to carry out other legitimate business purposes, as well as other lawful purposes. 

We may use any aggregated information (as described below) for any purpose.

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How We Share Your Information

We share your information with our partners, service providers, contractors, agents, and third-party vendors as needed to fulfill Services. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, or respond to a request you submit.

Third-party vendors who provide products, services or functions on our behalf may include business analytics companies, customer service vendors, chat forums, communications service vendors, marketing vendors, and security vendors. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of the Services. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

We also may share your information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our Terms of Service, available at www.palatialxr.com/terms-of-use, and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas. When you post a message in a Palatial forum, chat room, message board, review, or customer feedback, whether maintained by Palatial or a third-party platform, the information you post may be accessible to other users of the Services and the public. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full risk and responsibility for posting such information and agree that Palatial is not responsible in any way for personal information you choose to post in these public areas.

Aggregated Information.  We may publish, share, distribute, or disclose personal information that has been aggregated with information from other users or otherwise de-identified data in a manner that does not allow third parties, including Palatial partners, sponsors, and advisers, to de-aggregate the data and identify it as originating from you (“Aggregated Information”). Such information may help Palatial identify and analyze training, demographic, usage, psychographic, and other trends and information, and report to third parties how many people saw, visited, used, or clicked on certain content, areas of the Services, ads, or other materials. We may also use such data for research purposes and optimizing the Services’ functionality.

Palatial may use Aggregated Information to train or improve or otherwise in connection with an artificial intelligence model. However, Palatial will never share your personal information to train or improve or in connecting with an artificial intelligence model, and Palatial will not share your information in a way that would allow any third party to do so.

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How We Store and Secure Your Information

Personal information collected by Palatial may be stored and processed in your region, in the United States, and in any other country where Palatial or its affiliates, subsidiaries, or service providers operate facilities. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Palatial takes technological and organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure, or modification. For example:

• we transmit data over secured communication channels using SSL Login credentials,
• all personal information is stored by trusted third party providers (e.g., CoreWeave and Cloudflare R2),
• all systems used to provide the Services are password protected,
• all Services usage is restricted on a per-user basis on the principle of least privilege, and
• all data is encrypted during transfer and while at rest.

We rely on CoreWeave’s and Cloudflare R2’s security programs to protect personal information while stored in their respective controlled facilities.  For more information on CoreWeave’s security practices and processes, please see https://docs.coreweave.com/policies/terms-of-service/security-and-compliance. For more information on Cloudflare R2’s security practices and processes, please see https://developers.cloudflare.com/r2/reference/data-security/. 

Palatial currently uses Stripe, Inc. for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to each of their services. Stripe uses this information to operate and improve the services they provide to Palatial, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/legal/privacy-center. As with all third-party providers, Palatial is not a party to any agreement between you and Stripe and does not control Stripe’s privacy and data security policies. Palatial reserves the right to change payment processors at any time.

Palatial complies with applicable data protection laws, including applicable security breach notification requirements.

Data Retention

Palatial will retain your information as long as necessary for the purposes outlined in this Privacy Policy, in a manner consistent with our data retention policy discussed below, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes. Palatial will retain your personal information consistent with the original purpose of collection or as long as necessary to comply with our legal obligations; maintain accurate accounting, financial and other operational records; resolve disputes; and enforce our agreements. We will never retain your information for a period longer than permitted by law.

We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed; the potential risk of harm from unauthorized use or disclosure of the personal information; whether we can achieve the purposes of the processing through other means; and on the basis of applicable legal requirements.

After expiration of the applicable retention periods, your personal information will be deleted.

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Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may: 

1. Have the right to access certain personal information we maintain about you and request details about how we process it; 
2. Request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes; 
3. Request that we update or correct inaccuracies regarding your personal information; 
4. Object to our use of your personal information; 
5. Ask us to block or delete your personal information from our database; 
6. Request to download the information you have shared on the Services; and 
7. Confirm whether Palatial stores your data in the United States. 

You may make these requests and any other inquiries about this Privacy Policy by emailing privacy@palatialxr.com or calling us at 1(888) 612-0030. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

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Additional Privacy Information

Data Transfer. Our databases are currently located in the United States. Palatial makes no claim that its Services are appropriate or lawful for use or access outside the United States. If you access the Services from outside the United States, you are consenting to the transfer of your personal information from your location to the United States. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By sending us your information, you further consent to its storage within the United States.

Collection of Data from Children. The Services are not directed to children, and you may not use the Services or provide any personal information to Palatial if you are under the age of 16 (or the lowest age permitted by applicable law) or if you are not old enough to consent to the processing of your personal information in your country.

California Resident Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or write to us at the addresses below.

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European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Switzerland, Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) or the Swiss Federal Act on Data Projection with respect to your Personal Data. The following discusses these rights.

For this section, the GDPR definition of “Personal Data” and “processing” are used. Generally, “Personal Data” means information that can be used to individually identify a person, and “processing” relates to actions that can be performed in connection with collecting, using, storing, and disclosing such data. Palatial is the controller of your Personal Data processed in connection with the Services.

If a conflict exists between this this section and any other provision of this Privacy Policy, the more protective policy or portion shall govern to resolve such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@palatialxr.com. 

We may also process Personal Data of our customers’ end users in connection with our provision of services to our customers. In this case, we are the processor of Personal Data. If you have any questions regarding Personal Data when Palatial is the data processor, please contact the controller party in the first instance to address your rights with respect to such data.

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

Personal Data Use and Processing Grounds. The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data as explained in this Privacy Policy and if we have a lawful basis for doing so. The lawful bases include receiving your consent, having a contractual necessity, and furthering our legitimate interests or the legitimate interest of others. The following sections describe these in greater detail.

Consent

We process Personal Data based on the consent you expressly grant to us at the time we collect the data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Contractual Necessity

We may process the Personal Data as a matter of “contractual necessity”. This means that we need to process the data to perform under our agreement with you and enable 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.

Legitimate Interest  

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties providing products or services in connection with the Services:

• Profile or Contact Data

• Device/IP Data
• Geolocation Data
• Web Analytics
• Professional or Employment-Related Data
• Social Network Data
• Sensory Data
• Other Identifying Information that You Choose to Provide

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

Examples of these legitimate interests include (as described in more detail above in the “How We Use Your Information” section):

• Providing, customizing, and improving the Services.

• Marketing the Services.

• Corresponding with you.

• Meeting legal requirements and enforcing legal terms.

• Completing corporate transactions.

Other Processing Grounds

Occasionally, we may also need to process Personal Data to comply with legal obligations, to protect the vital interests of you or other data subjects, or to carry out a task necessary for the public’s interest.

Sharing Personal Data. The “How We Share Your Information” section above details how we share your Personal Data with third parties.

EU and UK Data Subject Rights

EU and UK data subjects have certain rights with respect to Personal Data. This is further set forth below. For more information about these rights or to submit a request, please email us at privacy@palatialxr.com. Please note that in some circumstances, Palatial may be unable to fully comply with your request, including if the request is frivolous, extremely impractical, jeopardizes other’s rights, or not required by law. In those circumstances, we will still notify you of such a decision. Generally, we may also need you to provide us additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include:

• Access: You can request information related to the Personal Data we store about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we store about you is incorrect or incomplete, you can request we supplement or correct such Personal Data.
• Erasure: You can request we erase part or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based upon your consent (as indicated at the time of collection of such data), you have the right to withdraw consent at any time. However, please note that if you change or withdraw consent, you may have to then provide express consent on a case-by-case basis if use or disclosure is necessary to enable you to use the Services.
• Portability: You can request for a copy of your Personal Data in a machine-readable format. You can also request we transmit the Personal Data to another controller to the extent such transmission is technically feasible.
• Objection: You can contact to object to our further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes, by contacting us as described above.
• Restriction of Processing: You can request Palatial to restrict further processing your Personal Data.
• Right to File Complaint: You have the right to submit a complaint about Palatial's practices with respect to your Personal Data to the 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.

Transfers of Personal Data. The “Data Transfer” information in the “Additional Privacy Information” section above details how and where we transfer your data. Most significantly, our databases are currently located in the United States, and you are consenting to Palatial transferring your Personal Data to the United States.