Gatherプライバシーポリシー
This Privacy Policy is effective as of October 13, 2023
はじめに、Gatherは、お客様の個人データ(氏名、住所、Eメールなどをいいます)を第三者に販売することは決してありませんのでご安心ください。
Gather Presence, Inc. (“Gather”, the “Company”, “we”, or “our”) operates the website www.Gather.Town (the “Site”) and provide certain services (the “Services”) in connection with a software as a service-based platform (the “Platform”) accessible via the Site that enables you to build customized virtual spaces and host virtual events in those customized virtual spaces. For purposes of this Privacy Policy, the Platform is subsumed with the definition of Services. We offer the Services with limited features for free, and we charge money for other uses of the Services (the fees vary based on factors such as event time and features). We also make subscriptions of the Services available.
When you access the Site or Services, you trust us with certain information (we will call this “data” for the sake of consistency). We are committed to keeping that trust, and that starts with helping you to understand our privacy practices. We collect several different types of data for various purposes, but mainly to provide the Services and improve our Services for the benefit of our customers.
This privacy policy (“Privacy Policy”) informs you of our policies regarding the collection, use and disclosure of Personal Data (as defined) when you access the Site or Services in connection with the Site Terms of Service and the choices you have associated with that data. We will also discuss non-personal data such as usage data. We also post a data processing agreement (“DPA”) to the Site, and you may request to countersign a version by contacting legal@gather.town. Gather does not negotiate changes to its DPA.
We have organized this Privacy Policy to first highlight how we use data in connection with aspects of the Platform (the Gather Platform), followed by how we comply with our legal obligations in relation to data privacy to the Site and Services generally. By using the Site or Services, you agree to the collection and use of data in accordance with this policy.
Gather Platform
The Gather Platform is an application for creating and accessing customized virtual spaces that are accessed via web browser or desktop or mobile application. Here are some highlights of our privacy practices on the Gather Platform:
- Gather does not store or view user audio or video, which are encrypted in transit (similar to Google Meet).
- Gather stores meeting recordings taken in Gather in cloud storage for a short period of time in order to make them available for download. While stored, the recordings are encrypted at rest.
- Gather may store chat messages. When stored, they are encrypted at rest.
- Gather stores documents and images uploaded via Mapmaker or the build tool in cloud storage. These documents and images are encrypted at rest.
- Gather stores metadata about users, including their name and email address as well as analytics on their usage of the platform.
- Gather stores metadata about virtual spaces on the Platform, including the spaces’ access restrictions, member and guest lists, and ban lists.
- Gather stores metadata about the maps of virtual spaces, such as the layout, configuration, and design of the maps.
- Gatherは、お客様の明示的な同意なしに、他のユーザーとマップを共有することはありませんが、例えば、ユーザーを仮想空間に招待することによって、お客様自身がマップを共有することがある点にはご留意ください。
- If you provide feedback via feedback forms in the Platform, we store your message, along with your name and email, if you provide them.
本プライバシーポリシーの以下の部分では、上記以外のプライバシー慣行について説明し、本サイトおよび本サービスに関連して、Gatherが個人データに関してより一般的にどのように法的義務を遵守しているかを説明します。
当社が収集するデータ
In connection with your use of the Site and Services, we may receive various types of data related to you, as well as data you provide to us about others. Sometimes you provide us with this data and sometimes data about you is collected automatically. To the extent data is associated with an identified or identifiable natural person and is protected as personal data (or substantially equivalent terms) under applicable data protection laws, it is referred to in this Privacy Policy as “Personal Data.” You acknowledge and agree we may collect, process, store, access, and disclose Personal Data disclosed by you to facilitate the provision of the Site and Services and related support for the Services, as well as analyze potential improvements or new product development related to the Site and Services, in the manner described in this Privacy Policy.
A. 個人データ
Types of Personal Data we collect includes:
- 電子メールアドレス
- 氏名
- The nickname or other data you might provide in connection with an avatar
- お客様が本サイトのお問合せフォームを通じて当社に連絡する際に提供される個人データ
If you use the Services to make payments of any kind, or to set up the capability to make payments, you may provide us (or our third-party payment processors) additional Personal Data including financial data (such as your credit card data or other applicable payment method, billing address, billing telephone number, or date of birth). We store very little, if any, customer financial data and such financial data is typically stored by our third-party payment processors, but we may use this data under certain circumstances to create and to provide support related to your account and to communicate with you relating to customer support inquiries as well as other communications related to the Services. We encourage you to review the privacy policies of any third-party payment processors used in connection with and to contact them directly if you have questions relating to your data, including Personal Data, as it relates to such payments. We currently use Stripe to process debit and credit card payments and their data policies can be found here.
B. Usage, Location and Tracking Cookies.
We collect data which may or may not be anonymized and other analytics on how the Site and Services are accessed and used (“Usage Data”). This Usage Data may include data such as your user email address, computer’s Internet Protocol address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
We may use and store data about your location (“Location Data”) when you visit the Site. We use this data to improve and customize our Site or Services. You can enable or disable location services when you use our Site and Services at any time by way of your device settings.
For general visitors to the Site, we may use “cookies” (a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive) and similar tracking technologies to track the activity on our Site, and these Cookies and similar technologies hold certain data. We may also use (and enable third-party service providers to use) other tracking technologies such as beacons, tags, hashed emails and scripts to collect and track data and to improve and analyze our Site and Services and for targeted advertising purposes related to the Site. We only use Cookies with your consent. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent.
To opt out of receiving targeted advertising use the link to the DAA opt-out site www.aboutads.info or the NAI opt-out site at networkadvertising.org/choices, in Europe, the EDAA opt out site at youronlinechoices.eu.
We have a cookie policy and you may access that by emailing privacy@gather.town
個人データの使用方法
Gather reserves the right to use your Personal Data for any legitimate business purpose as set forth in the California Consumer Privacy Act (the “CCPA”). Specifically, we use Personal Data:
- 本サイトおよび本サービスの提供、維持および改善
- 本サイトおよび本サービスの利用状況の管理
- 本サイトおよび本サービスに関する技術的な問題の検出、防止、および対処のため
Additionally, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about updates to the Services or your use of the Services. These promotional emails contain the ability to opt-out. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services.
お客様の個人データの保持、転送、および開示方法について
In general, we retain your Personal Data only for as long as is necessary for the legitimate business purposes set forth in this Privacy Policy.
Typically, if you use our Services, we retain Personal Data about you for as long as you have an open user account with us and will not retain it for more than thirty (30) days after you close your user account, unless a different policy is otherwise agreed upon in an executed agreement. Thereafter, we retain some data in a depersonalized or aggregated form but not in a way that would identify you personally.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time than Personal Data, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.
Your data, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the United States and choose to provide data to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Your consent to this Privacy Policy by using the Site or Services followed by your submission of such data represents your agreement to that transfer, although we do offer a data processing agreement (“DPA”) for certain enterprise customers.
We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable data protection laws and that no transfer of your Personal Data take place to an organization or a country unless there are adequate controls in place for that transfer including the security of your data and other personal data.
Except as described in this Privacy Policy, will not use or disclose Personal Data for any purpose other than to the extent reasonably necessary to perform the Services and related support for the Services. As a matter of policy, we will not disclose data about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation, unless we obtain your express consent.
That said, we will process and disclose your Personal Data to the extent necessary to comply with our legal obligations, complete corporation transactions, resolve disputes, and enforce our legal agreements and policies as follows:
A. 企業間取引
If the Company is involved in a merger, acquisition, or asset sale, we may disclose or transfer Personal Data for purposes consistent with that transaction. .
B. Human Resources and Personnel Matters
Gather may collect, process and disclose the Usage Data of its employees and those individuals applying for employment with Gather for the sole purpose of legitimate business reasons and personnel matters. For data regarding your privacy as a candidate for a position with Gather, please visit our Candidate Privacy Statement.
C. Disclosure for Law Enforcement
当社は、法律により要求された場合、または公的機関(裁判所や政府機関など)の有効な要請に応じる場合に、お客様の個人データを開示する場合があります。
D. Other Legal Requirements
当社は、以下のような行為が必要であると判断した場合、お客様の個人データを開示することがあります:
- 法的義務に従うため
- 当社の権利または財産を保護するため
- 本サイトまたは本サービスに関連する不正行為ないしその可能性について、防止または調査するため
- 本サイトまたは本サービスの利用者または一般の個人の安全を守るため
- 法的責任から免れるため
データの安全性
当社は、お客様のデータのセキュリティを重要視しており、データの暗号化と暗号鍵の管理について、業界標準の方法を使用し、公共ネットワーク上で送信されるデータおよび当社のシステム上で保存されるデータを保護しています。当社は、商業的に許容される手段を用いてお客様の個人データを保護するよう努力いたしますが、インターネット上の送信方法や電子的な保存方法が100%安全であるとは言えないため、その絶対的な安全性を保証することはできません。
お客様の個人データの削除を要求する方法
If you would like to request that Gather delete your personal data, you may contact us directly at privacy@gather.town to submit your request. Gather will respond within a reasonable time frame in accordance with applicable laws and regulations.
Jurisdiction-Specific Notices
1. Your Rights under California Online Protection Act (“CalOPPA”)
We do not support Do Not Track (“DNT”). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.
CalOPPAに基づき、当社は以下のことに同意します:
- サイト利用者は、匿名で本サイトを利用することができます
- 本プライバシーポリシーを変更する場合、当社のプライバシーポリシーに関するウェブページで通知いたします
- Site users are able to change their personal data (as defined by CalOPPA) by emailing us at privacy@gather.town
2. Your Rights under the General Data Privacy Regulation (“GDPR”)
If you are a resident of the European Union (EU) and European Economic Area (EEA), GDPR affords you certain rights. These include:
- 当社が保有するお客様に関するデータにアクセス、削除、または更新する権利
- お客様のデータが不完全または不正確である場合に、そのデータの修正を求める権利
- お客様のデータの処理に異議を唱える権利
- お客様のデータの処理を制限することを要求する権利
- 機械で可読な、一般的に使用されるフォーマットで、お客様の個人データのコピーを要求する権利
- 当社がお客様の個人データの処理についてお客様の同意に依拠している場合、いつでも同意を撤回する権利
To exercise any of the above rights, please send a request to privacy@gather.town. Please note that we may ask you to verify your identity before responding to such requests.
Additionally, you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more data, please contact your local data protection authority in the European Economic Area (EEA).
3. Your Rights under the California Consumer Privacy Act (“CCPA”)
If you are a California resident, you are afforded certain rights under the CCPA, such as the right to access what personal data (as defined by the CCPA) we collect about you, the right to ask us to delete your personal data, and the right to tell us not to sell your personal data.
You may ask us to provide you with what personal data we have collected up to two times in a rolling twelve month period. When you make this request, the data provided may be limited to the personal data we collected about you in the previous year.
Please note that Gather does not sell your personal data and we will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to privacy@gather.town.
子どものプライバシーに対する当社のコミットメント
At Gather we take children’s privacy very seriously. The Services are designed for businesses and individuals 18 and over. Gather does not knowingly collect Personal Data from individuals under the age of 18. If you are under 18, you should not use or attempt to use the Services or send any data about yourself to Gather. If we discover that we have directly collected Personal Data from a person under the age of 18, we will take the appropriate measures to promptly remove that data from our Services.
If you believe that Gather may have directly collected Personal Data about a person under the age of 18 and wish to have us remove that Personal Data, please contact us at privacy@gather.town to let us know. We’ll work with you to make sure that data is removed from our Site and Services, as applicable.
本ポリシーおよびその他のプライバシーに関する条項の変更
We may update our Privacy Policy from time to time. We will notify you of any material changes by sending an email notification to all current users, posting the new Privacy Policy on this page and by updating the “effective date” at the top of this Privacy Policy. Please review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted.
お問い合わせ
Questions or concerns about this Privacy Policy or your Personal Data may be addressed by email at privacy@gather.town You may also reach us by mail sent to 2261 Market St. #4095, San Francisco, CA, 94114.