In accordance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016 (hereinafter, “GDPR”), we inform you that all personal data provided by the User through this Website will be incorporated and processed in the files and processing systems owned by the company Pico Immersive Pte. Ltd. (hereinafter, “PICO”) with the sole purpose of being able to attend your requests and keep you informed, even by electronic means, about our products and services.

The completion of all the information requested through the Website is necessary in order to ensure optimum provision of the services offered to the User. If all the information required in the Website is not rendered, it is not guaranteed that the information and services provided may be performed, provided correctly or adjusted to the needs of the User.

The term User/s is used in this policy to refer to all persons over 18 years old who access the Website.

This Privacy Policy (hereinafter, the “Policy”) describes how Pico and its related companies (hereinafter, “PICO GROUP”) collect, use and share personal information that we collect from you as a user of Pico websites, devices, applications and services (together, the “Services”). Pico strives to comply with all laws that apply to our processing of information collected about you.

We may add to, or amend, this Policy with other notices, informing the User the changes made in order to renew the given consent. We may also post different privacy statements for some Services, and when we do so, this policy does not apply. For example, some independent policy is applied to collect information from your device by sending message like “Sending message to Pico” and “Report error to Pico” where applicable.

NOTE: Your wireless operator, mobile operating system provider and/or third-party applications, toolbars, services, “plug-ins”, social media platforms and websites may also collect, use and share information about you and your device and your usage. Pico’s privacy policies do not cover any third parties, their products, actions or their services. For information about third-party privacy practices, please consult their privacy policies. Only download applications from, and interact and connect with, reputable third parties.

DETAILED INFORMATION ON DATA PROTECTION

1.

Data Controller

The controller for the processing of the User’s data is the company Pico Immersive Pte. Ltd.

For any question, doubt or clarification related to this Privacy Policy or the processing of data performed by PICO, you can contact us through the email address service@picoxr.com.

2.

General information: description of the information contained in the privacy policy

For each of the different data processing performed by PICO, you will find in this Privacy Policy a table identifying the following information:

·

The legal basis that allow PICO to process your data for each of the indicated purposes.

·

The possible transfer of your data to third parties, as well as the reason for said communication. For these purposes, we inform you that we do not transfer your personal data to third parties unless there is a legal obligation. On the other hand, those in charge of the processing of PICO, that is, the service providers who have to access your personal data for the development of their functions, may have access to your personal data. The service providers who access your personal data, in general, are professionals of the information systems and technology sectors. The table below will indicate, where appropriate, those other sectors that should access your personal data to provide services to PICO.

·

We inform you that you can request more information regarding the recipients of your data by sending an email to the address service@picoxr.com, indicating the specific processing whose recipients would like information.

·

The existence of potential international data transfers.

·

The retention period of your personal data. Likewise, we inform you that your data will be blocked for the attention of judicial, administrative or fiscal claims during the legal terms that result from the applicable legislation.

3.

Detailed information about the data processing

The User may provide us, on a voluntary basis, personal information, either through certain forms of data collection (included in the Website, social media, records to events in paper format, by phone, etc.), or through email addresses authorized for this purpose.

The data processing is based on the following purposes:

PURPOSE	LEGAL BASE	DATA TRANSFER	RETENTION PERIOD
a) Provide you with a personalized and customized experience, content, marketing and recommendations across all our Services;	Consent	To Pico Immersive Pte. Ltd.	12 months
b) Respond to your comments and questions and provide customer service;	Consent and Legitimate interest	Entities of Pico Group and other collaborators necessary to give a response to the User	2 years
c) To manage the contractual relationship with the client;	Contract performance	Your data may be disclosed to entities of Pico Group and to other necessary collaborators to carry out the performance of the contract.	During 6 years after the contractual relationship has ended.
d) Provide and deliver products and Services that you request;	Consent and contract performance	Entities of Pico Group and other collaborators necessary to carry out the agreed services or delivery of products, such as our storage provider.	During 6 years after the contractual relationship has ended.
e) Send you information related to your requests and purchases, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;	Consent and contract performance	Entities of Pico Group and other collaborators necessary to carry out the agreed services	During 6 years in case of contractual relationship. If not, until consent is revoked.
f) Communicate with you about contests, promotions, rewards, upcoming events and news about products and services offered by Pico and our selected partners (we do this as per your choices, as outlined by our policies) and to process and deliver contest entries and rewards;	Consent	Other entities of Pico Group and other collaborators necessary to manage the contests, promotions or events.	2 years
g) Link or combine your personal information with other information we get about your use of other Pico Services and from third parties for the purposes that we disclose in this policy, including to help understand you and your needs;	Consent	Entities of Pico Group and other collaborators necessary to carry out the agreed services	12 months
h) Protect, investigate and deter against fraudulent, unauthorized or illegal activity;	Legal obligation	Public Administrations, Courts and Forces and law enforcement agencies.	Retention period of the applicable law
i) Filter the content that will be shown on the virtual reality products;	Consent	Necessary collaborators in order to carry out the purpose.	12 months
j) Compile usage information and other statistics and insights relating to the Services and Products; and	Consent	To Pico Immersive Pte. Ltd. as entity of Pico Group and other necessary collaborators to carry out the purpose.	12 months
k) Facilitate sharing information and content that you upload via social media	Consent	Entities of Pico Group and other necessary collaborators to carry out the purpose.	Until the User revokes the given consent.
l) Operate and improve our websites, products, Services and marketing;	Legitimate Interest	To Pico Immersive Pte. Ltd.	12 months

In all cases, PICO will keep the data duly blocked, without giving it any use, while they may be necessary for the establishment, exercise or defence of legal claims or may derive some type of judicial, legal or contractual responsibility from the processing, which must be attended to and for which its recovery is necessary.

Regarding the processing of your data for promotional or advertising purposes, the data subject will be provided, together with the corresponding data collection form, the appropriate procedure, simple and free of charge, so that the User can freely give the consent for this purpose. The consent granted may be revoked at any time and at no cost for the data subject.

Regarding the processing of data carried out by celebrating raffles and contests, we inform you that PICO can perform them through third-party websites other than our Website, as well as contract the services of specialized websites in the provision of these services. In these cases, we strongly recommend that you read their Privacy Policies and Terms and Conditions carefully.

4.

Categories of Data

In accordance with the aforementioned purposes, PICO processes the following categories of data, which some of them are optional, provided both online and offline by the User:

·

Identification data in order to perform a contract or provide the service to users: name, surname, company, email address, phone number, fax number, date of birth, location, occupation, gender, icon, nickname and language.

·

pFinancial data: bank account, credit card number and purchase and payment records, in case you purchase Products from us.

·

In the case of organizing events, promotions or contests: images, recordings or videos of the user, with their prior consent.

·

Also, through the use of cookies we collect certain information linked to your browsing as, for instance, device identifiers, your provider information, language preference, location and time zone. Its processing and purposes is explained in our Cookie Policy.

We may hold and associate any information you provide us with information gathered from other sources, including the social accounts that you choose to associate with your use of the Services, or with information we receive from other companies.

On the “CONTACT US” page, it is possible to briefly explain the reason for the communication by completing a contact form. Keep in mind that there can be no personal questions except those strictly requested by current legislation. Under no circumstances will be communicated data regarding special categories (such as health data, religion, etc.). In case of doing so, the User exempts PICO from total liability. In the event that inappropriate inquiries or content are sent, PICO will proceed to their elimination.

By providing us with the personal data, the User guarantees that they are true, accurate, complete and up-to-date, taking responsibility for any direct or indirect damage or loss that may be caused as a result of the breach of such obligation. If you provide third-party data to PICO, the User must have their consent and commit to transfer the information contained in this Policy, exempting PICO from any responsibility in this regard. However, PICO may carry out the verifications to check if the consent is valid, adopting the appropriate due diligence measures, in accordance with the data protection regulations.

5.

Sharing of personal information

The Services may allow you to connect and share your actions, comments, content and information publicly or with people you specify. You may also connect to, and share your information on, third-party social media platforms, websites, applications and services (“Third-Party Sharing Services”) through “plug-ins,” widgets, buttons, and other third party features made available on and connected with our Services. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information that you choose to make public or share with others. We also cannot control and are not responsible for any Third-Party Sharing Services or their actions, including the data that these Third-Party Sharing Services collect from you and your device, or how they use such data. Please review the privacy policies of all Third-Party Sharing Services to understand their privacy practices.

·

5.5 INFORMATION WE SHARE

In regards to the data transfers shown in the table above, we may share your personal information as follows:

1) With your voluntary consent. For example, you may let us share your personal information with our partners on a co-branded website, or you may use the Services to connect to our partners’ services or to request information from them. Our partners’ use of your personal information will be subject to their privacy policies. Please, read carefully their Privacy Policies before using their services.

2) For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets. Business deals may include any merger, financing, acquisition or bankruptcy transaction or proceeding.

3) For legal, protection, security and safety purposes, including:

·to comply with laws or regulatory requirements and to respond to lawful requests and legal processes;

·to protect the rights and property of Pico, our agents, customers and others, including enforcing our agreements, policies and terms of use and protecting our network and physical assets; and/or

·in an emergency, including protecting the safety of our employees and agents, our customers or any other person.

4) With those who use the information to provide services to us or on our behalf.

5) With wireless carriers. Their use of your information is subject to their privacy policies. Please, read carefully their Privacy Policies before using their services.

We may share aggregated and de-identified data with others for any purpose, as there are no personal data involved.

6.

Children

Children underage may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts performed through the Website by minors at their charge, including the completion of the forms with the personal data of said minors and the marking, where appropriate, of the opt-in boxes that accompany them.

7.

Exercise of rigths

We inform you that you may exercise the following rights:

·

Right of access to your personal data to know which ones are being processed and the processing operations carried out with them;

·

Right to rectify any inaccurate personal data;

·

Right to delete your personal data, when this is possible;

·

Right to request the restriction of the processing of your personal data when the accuracy, legality or the need for the processing of the data is doubtful, in which case, we may keep them for the exercise or defence of claims;

·

Right to the portability of your personal data, when the legal basis that enables us for its processing of those indicated in the section “Purpose of the Processing” of this Policy is the contractual relationship or consent;

·

Right to object to the processing of your personal data, when the legal basis that enables us to process those indicated section “Purpose of the Processing” of this Policy is the legitimate interest. For these purposes, we will stop processing your data unless we have a compelling legitimate interest or for the formulation, exercise or defence of claims.

·

Right to revoke your consent at any time.

You can exercise your rights at any time and for free by sending an email to service@picoxr.com, REF: Data Protection, indicating the right you wish to exercise and your identification data or by postal mail by writing to: service@picoxr.com

The data subject guarantees the veracity and accuracy of the data provided and agrees to keep them duly updated.

If you believe that we have not treated your personal data properly, you can contact the Data Protection Officer at service@picoxr.com. However, we inform you that you have the right to file a complaint with the competent supervisory authority if you believe that a violation of the legislation on data protection regarding the processing of your personal data has been committed.

8.

Security measures

We strive to protect personal information by taking appropriate physical, technical and organizational measures to help guard against unauthorized or unlawful access, use, processing or alteration of the personal information that we obtain from you through our Services and against any breaches or loss of such personal information. Notwithstanding the foregoing, technical security in a medium such as the Internet is not impregnable and there may be fraudulent actions by third parties, although PICO puts all means at its disposal to avoid such actions. If you become aware of a technical vulnerability affecting Pico Services, please email service@picoxr.com or visit this website to report it.

We are not responsible for the security of any independent third-party applications and services or the data those third-party applications and services may collect about you. Please ask those third parties how they keep your data safe.

9.

International Data Transfer

We do not disclose your personal data to third parties other than our service providers and to our holding and other affiliates of Pico’s Group (whether within or outside of the European Economic Area) for the purpose of processing the commercial transaction, where necessary, and store information on our servers in Singapore and the US by means of third party collaborators that have previously proven that are compliant with the European data protection laws and with whom we have signed a data protection agreement. Thus, in the event of an international data transfer, all appropriate technical and organizational measures will be taken to ensure the safety of the personal data and will protect it in accordance with this Policy. Moreover, if the data processing is carried out by a provider located in a country without the corresponding data protection laws, the processing will be protected by international contracts in accordance with European requirements, as it is the case.

We can provide information on the appropriate guarantees, as well as the option to obtain a copy of them, upon request.

10.

Scope of application

In order to comply with the applicable legislation on data protection, the structure of files, equipment and information systems, will be applied to all files, temporary or permanent, owned by PICO containing personal data, as well as any other equipment or information system that process them.

11.

Commercial and promotional information

If the User has authorized us to do so, PICO will process the personal data provided with the aim of notifying you of advertisement content and commercial communications of PICO.You can revoke your consent at any time by clicking on the link provided in each newsletter or by email at service@picoxr.com.

Newsletters may also contain links to third party sites. We will store your data for as long as you are subscribed to our newsletter. After you unsubscribe, we will block your data in this context so that you will not receive any more newsletters from us in the future.

12.

Objection or processing revocation

If you have given your consent for the processing of your data, you can revoke this consent at any time in the future. You can send your revocation to service@picoxr.com.

Please note that despite any objection or revocation made, we may still be legally required to store the data. Of course, you can object and revoke your consent at any time to the processing of your personal data for advertising purposes. Contact details can be found in Clause 1.

13.

Information choices and changes

Our marketing emails tell you how to “opt out” of receiving further marketing emails, according to section 11 of this Policy. If you opt out, we may still send you non-marketing emails related to our commercial relationship and your user accounts, although may include a request to participate in surveys related to your use of, and satisfaction with, the Services.

You may send requests about your personal information to us through the procedure establish in section 7 of this Policy. You can request to change contact choices or marketing choices and to update, access, delete or make other changes regarding your personal information or content that you post on the Services. In some cases, we may not accept all the requests unless required by law.

When you use our Services, we and third parties may give you choices about use of certain mechanisms for tracking, including tracking of your online activities over time and across different websites, applications and online services. We may provide settings on your device that allow you to change how we, and others, collect certain information about you. Read your product manual for more information about settings on your device. Currently, browsers must be configured to accept, reject or configure cookies. Removing or rejecting our cookies could affect how our websites and Services work for you and could delete or disable opt-out cookies set by us and third parties.

Some of our third party ad service providers also provide choices for use of cookies to deliver ads tailored to your profile and preferences. To learn more visit:

·

http://www.networkadvertising.org/choices/

·

http://www.adobe.com/privacy/opt-out.html#measure

While we and others give you certain choices, as further outlined in this Policy, there are many ways in which Web browser signals and similar mechanisms can indicate your choice to disable tracking, and we may not be able to honor every such mechanism when they are necessary to provide our service.

14.

Social Networks

IWe have set up social media icons on our website. With a simple mouse click you can access the following social media platforms: Instagram and Facebook. When visiting our website, no personal data is transmitted to the providers. You can recognize the platform provider by the logo. We offer you the opportunity to go directly to PICO publications on each social network through the icon. We have no influence on the data collected and the data processing procedures on these social networks, nor are we aware of the full scope of the data collection, the purposes of the processing and the retention periods. We also have no information on the erasure of the same.

In the event that the followers of our profiles contact Quantium through said networks or publish images or information in our profile that contains personal data, it will be the sole responsibility of the User and/or follower, being Quantium Medical exempt from all responsibility regarding the content that the User and the follower incorporate in our public profiles. Due to the fact that the profile of Quantium Medical on social networks is public, Quantium Medical is not responsible for any direct or indirect action carried out by third parties derived from the publication of the User of their personal data in our profiles. Therefore, we strongly ask you to not share any personal or sensitive information and that you carefully read the Privacy Policies and Terms and Conditions of these social platforms to configure your profile with the degree of privacy you want. Anyone who does not wish to continue to be a follower of PICO in the social networks in which it is present, can stop following said profile as provided in the Terms and Conditions of the corresponding social platform.

Below you can find the addresses of the social media platforms where you can view their privacy statements:

·

Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA; www.facebook.com/policy.php. Facebook is subject to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

·

Instagram Inc, 1 Hacker Way, Menlo Park, CA 94025, USA; https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Ayuda%20de%20Instagram&bc[1]=Centro%20de%20privacidad%20y%20seguridad

15.

Confidentiality and professional secrecy

The data collected in all the private communications between PICO and the Users will be processed with absolute confidentiality, committing PICO to the obligation of secrecy of the personal data, to its duty to keep them and adopt all the measures necessary to prevent their alteration, loss and unauthorized access, in accordance with the applicable legislation.

In addition, information of any kind that the parties exchange with each other shall also be classified as confidential, as well as any information that the parties agree to have such nature, or the one that simply deals with the content of such information. The visualization of data over the Internet, will not imply direct access to them, unless there is express consent from its holder for each occasion.

16.

Links

In relation to the links to other portals or web pages not managed by PICO that may appear on the portal for information purposes, PICO does not exercise any control over them, nor does respond to the information accessed. We ask you to visit these websites directly to obtain information on their Privacy Policy that provides information regarding data protection, security, data collection and provisions regarding the transmission of data. PICO will not be responsible for any action taken by, or the contents of, these websites.

Unless PICO has authorized it in advance and in writing, you cannot insert a link, hyperlink, framing or similar link on the Website.

In case of following us on social media such as Instagram and Facebook, please review their privacy policies to find out how they process and shares your personal data , since PICO does not exercise any control over them or has any liability regarding the information that the social media has access to.

17.

CONTACT INFORMATION

We welcome your comments or questions about this Policy. Please email us at service@picoxr.com.

18.

Changes in security and data protection policy

PICO reserves the right to modify its security and data protection policy in order to adapt it to new legislation or jurisprudence, as well as those that may derive from existing standard codes in the matter, or by strategic corporate decisions, with effect from the date of publication of this modification on the Web page.

19.

Cookies

PICO will only use data storage and retrieval devices (“Cookies”) when the User has given his prior consent for it in accordance with what is indicated in the pop-up window of the user’s browser when accessing the Website for the first time and in the other terms and conditions indicated in the Cookies Policy that every user must know about.

Last Updated: January 26, 2022