PRIVACY POLICY
Effective Date: April 1, 2025
1. Introduction
Welcome to Polio's Last Mile, developed by REM5 LLC ("we," "us," "our"). This Privacy Policy explains how we collect, use, share, and protect information about users ("you") of our Meta Quest application (Polio's Last Mile) and any related services (collectively, the "Product").
By accessing or using our Product, you acknowledge that you have read and understood this Privacy Policy. We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Product interface, by posting the updated policy on our website at [Link to Policy on Website], or as otherwise required by law, and we will update the "Effective Date" above. We encourage you to review this policy periodically.
This Privacy Policy is intended to comply with Meta’s Horizon Data Use Policy. In the event of a conflict between this policy and Meta’s requirements, we will comply with the stricter applicable standard.
2. Information We Collect
We collect information to understand how our Product is used and to improve the user experience. We aim to collect only the data necessary for these purposes. The information we collect includes:
We use the information we collect solely for the following purposes:
4. Legal Basis for Processing Personal Information (EEA/UK Users)
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), our legal basis for collecting and using the personal information described in Section 2 (including the headset identifier and associated interaction and performance data) is primarily our legitimate interests.
Specifically, we have a legitimate interest in operating, maintaining, and improving our Product by understanding how it is used, diagnosing technical issues, and identifying areas for enhancement. We have considered the potential impact on your privacy rights and believe that our collection of this pseudonymous usage data for these limited internal improvement purposes is justified by our legitimate interests and does not unduly override your fundamental rights and freedoms.
We may also process information if necessary to comply with a legal obligation. We do not rely on user consent as a legal basis for collecting analytics data through your use of the Product. You have the right to object to this processing based on legitimate interests as described in Section 8.
5. Information Sharing and Disclosure
We are committed to protecting your privacy. We do not sell your personal information. We only share the information we collect (which includes the persistent headset identifier and associated interaction and performance data) in the following limited circumstances:
6. Data Security
We implement reasonable technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of your data.
7. Data Retention
We retain the personal information we collect for as long as necessary to fulfill the purposes outlined in this Privacy Policy (primarily for product improvement and analysis), unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion is not immediately possible (for example, because your information is stored in backup archives), we will securely store it and isolate it from further processing until deletion is feasible.
8. Your Data Protection Rights
Depending on your location and applicable laws, you may have certain rights regarding your personal information. These may include:
California residents have specific rights under the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA). While we do not "sell" personal information in the traditional sense, you have the rights listed above.
9. Children's Privacy
Our Product is not intended for or directed at children under the age of 13 (or the relevant age of digital consent in the European Economic Area/United Kingdom, typically 16, although member states may lower this to 13). We do not knowingly collect personal information, including the pseudonymous headset identifier and associated usage data, from individuals under these ages. If we become aware that we have inadvertently collected personal information from a child below the relevant age threshold without appropriate verification or consent where required, we will take commercially reasonable steps to delete that information as soon as possible. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at [email protected].
10. Tracking Technologies and Third-Party SDKs
Our Product uses internal tracking mechanisms and may integrate third-party Software Development Kits ("SDKs") primarily for analytics and performance monitoring purposes, as described in Section 3. These technologies utilize the persistent headset identifier associated with your installation of the Product.
11. International Data Transfers
Your information may be transferred to, stored, and processed in countries other than your own, including the United States, where our servers or service providers may be located. Data protection laws in these countries may differ from those in your country. We take appropriate safeguards to ensure that your personal information remains protected when transferred internationally, such as by using Standard Contractual Clauses approved for transfers of data outside the EEA/UK, where applicable.
12. Data Breach Protocol
In the event of a data breach involving personal data that is likely to result in a risk to your rights and freedoms, we will take steps to contain and assess the breach promptly. We will notify affected users and the relevant data protection authorities as required by applicable law (e.g., within 72 hours of becoming aware, where feasible, for notifications to authorities under GDPR).
13. Changes to This Privacy Policy
As mentioned in Section 1, we may update this policy. Material changes will be communicated through the Product or our website. Your continued use of the Product after the effective date of the revised policy constitutes your acknowledgment of the changes.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
REM5 LLC
Email: [email protected]
Effective Date: April 1, 2025
1. Introduction
Welcome to Polio's Last Mile, developed by REM5 LLC ("we," "us," "our"). This Privacy Policy explains how we collect, use, share, and protect information about users ("you") of our Meta Quest application (Polio's Last Mile) and any related services (collectively, the "Product").
By accessing or using our Product, you acknowledge that you have read and understood this Privacy Policy. We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Product interface, by posting the updated policy on our website at [Link to Policy on Website], or as otherwise required by law, and we will update the "Effective Date" above. We encourage you to review this policy periodically.
This Privacy Policy is intended to comply with Meta’s Horizon Data Use Policy. In the event of a conflict between this policy and Meta’s requirements, we will comply with the stricter applicable standard.
2. Information We Collect
We collect information to understand how our Product is used and to improve the user experience. We aim to collect only the data necessary for these purposes. The information we collect includes:
- Interaction Data: This includes details about how you use the Product, such as features accessed, buttons clicked, screens visited, navigation paths taken within the app, session duration, and frequency of use.
- Performance and Technical Data: This includes data about the Product's performance on your device, such as crash reports, frame rates, loading times, your device model, and operating system version.
- Usage Patterns: We associate interaction and performance data with a pseudonymous identifier unique to your installation of the Product. This identifier is not linked to your real-world identity (like your name or email address) by us. It allows us to understand usage trends for a specific installation over time solely for the purposes described below, without directly identifying the individual user. While this identifier does not reveal your real-world identity, it allows us to link usage data to a specific installation over time and is therefore treated as personal information under applicable data protection laws.
- Sensitive personal information such as precise geolocation, biometric data, health information, or financial information.
- Audio recordings from your device's microphone or video from its cameras.
- Your Meta account information beyond what is necessary for basic platform integration (if any).
- We do not collect, store, or link any Meta user IDs, Meta usernames, or account-level identifiers to the pseudonymous data we process.
We use the information we collect solely for the following purposes:
- Product Improvement: To understand how users interact with our Product, identify usability issues, diagnose and fix bugs or crashes, evaluate the effectiveness of features, and make enhancements to improve the overall user experience.
- Performance Monitoring: To monitor the technical performance and stability of our Product on different devices and operating system versions.
- Aggregated Analysis: To analyze aggregated and anonymized usage trends to inform our product development roadmap and general marketing strategies. We do not use your individual data for advertising or share individual usage data externally for marketing purposes.
- Legal Compliance: To comply with applicable laws and regulations.
4. Legal Basis for Processing Personal Information (EEA/UK Users)
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), our legal basis for collecting and using the personal information described in Section 2 (including the headset identifier and associated interaction and performance data) is primarily our legitimate interests.
Specifically, we have a legitimate interest in operating, maintaining, and improving our Product by understanding how it is used, diagnosing technical issues, and identifying areas for enhancement. We have considered the potential impact on your privacy rights and believe that our collection of this pseudonymous usage data for these limited internal improvement purposes is justified by our legitimate interests and does not unduly override your fundamental rights and freedoms.
We may also process information if necessary to comply with a legal obligation. We do not rely on user consent as a legal basis for collecting analytics data through your use of the Product. You have the right to object to this processing based on legitimate interests as described in Section 8.
5. Information Sharing and Disclosure
We are committed to protecting your privacy. We do not sell your personal information. We only share the information we collect (which includes the persistent headset identifier and associated interaction and performance data) in the following limited circumstances:
- With Service Providers: We work with third-party companies that provide services on our behalf, helping us operate and improve the Product. These services include data analytics and cloud hosting. We may share the headset identifier and related usage data with these providers solely for the purpose of enabling them to provide these services to us. Examples of providers we may use include AWS, Unity, Amplitude, and Google. These providers process this data, which is typically pseudonymous (linked to the identifier, not your real name), according to our instructions and are required to implement appropriate security measures to protect it.
- For Legal Reasons: We may disclose your information if we believe in good faith that it is necessary to:
- Comply with a valid legal obligation, court order, or governmental request.
- Protect the safety, rights, or property of REM5 LLC, our users, or the public.
- Detect, prevent, or otherwise address fraud, security, or technical issues.
- In Connection with Business Transfers: If REM5 LLC is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or sale of all or a portion of its assets or business, your information may be transferred as part of that transaction, subject to confidentiality agreements and notification as required by law.
- Aggregated or De-Identified Data: We may share information that has been aggregated or anonymized (processed so that it can no longer be used to identify an individual headset or user) for purposes such as statistical analysis, industry reporting, or improving our services.
6. Data Security
We implement reasonable technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of your data.
7. Data Retention
We retain the personal information we collect for as long as necessary to fulfill the purposes outlined in this Privacy Policy (primarily for product improvement and analysis), unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion is not immediately possible (for example, because your information is stored in backup archives), we will securely store it and isolate it from further processing until deletion is feasible.
8. Your Data Protection Rights
Depending on your location and applicable laws, you may have certain rights regarding your personal information. These may include:
- Access: The right to request access to the personal information we hold about you.
- Correction: The right to request correction of inaccurate or incomplete personal information.
- Deletion: The right to request deletion of your personal information under certain conditions.
- Restriction: The right to request the restriction of processing of your personal information under certain conditions.
- Objection: You have the right to object to our processing of your personal information where we rely on legitimate interests as our legal basis (as described in Section 4).
- Portability: The right to request a copy of your personal information in a machine-readable format.
California residents have specific rights under the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA). While we do not "sell" personal information in the traditional sense, you have the rights listed above.
9. Children's Privacy
Our Product is not intended for or directed at children under the age of 13 (or the relevant age of digital consent in the European Economic Area/United Kingdom, typically 16, although member states may lower this to 13). We do not knowingly collect personal information, including the pseudonymous headset identifier and associated usage data, from individuals under these ages. If we become aware that we have inadvertently collected personal information from a child below the relevant age threshold without appropriate verification or consent where required, we will take commercially reasonable steps to delete that information as soon as possible. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at [email protected].
10. Tracking Technologies and Third-Party SDKs
Our Product uses internal tracking mechanisms and may integrate third-party Software Development Kits ("SDKs") primarily for analytics and performance monitoring purposes, as described in Section 3. These technologies utilize the persistent headset identifier associated with your installation of the Product.
- Activation: These tracking technologies are activated automatically when you use the Product. We collect interaction and technical data based on our legitimate interests (detailed in Section 4) to improve the Product.
- Third Parties: We may use analytics providers such as AWS, Unity, Amplitude, and Google. These providers process data according to their own privacy policies.
- Control: We do not offer an in-app mechanism to opt-out of this data collection. If you object to the collection of this data based on our legitimate interests, you must exercise your right to object by contacting us as described in Section 8. Alternatively, you may cease using the Product.
11. International Data Transfers
Your information may be transferred to, stored, and processed in countries other than your own, including the United States, where our servers or service providers may be located. Data protection laws in these countries may differ from those in your country. We take appropriate safeguards to ensure that your personal information remains protected when transferred internationally, such as by using Standard Contractual Clauses approved for transfers of data outside the EEA/UK, where applicable.
12. Data Breach Protocol
In the event of a data breach involving personal data that is likely to result in a risk to your rights and freedoms, we will take steps to contain and assess the breach promptly. We will notify affected users and the relevant data protection authorities as required by applicable law (e.g., within 72 hours of becoming aware, where feasible, for notifications to authorities under GDPR).
13. Changes to This Privacy Policy
As mentioned in Section 1, we may update this policy. Material changes will be communicated through the Product or our website. Your continued use of the Product after the effective date of the revised policy constitutes your acknowledgment of the changes.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
REM5 LLC
Email: [email protected]
