Inglobe Technologies Srl
Inglobe Technologies Srl (“Inglobe”) is a leading mixed reality (AR, VR, MR) technology provider. Its technology is available through its SDK, Plugins, and Hyper* platforms. With about 60,000 registered users, Inglobe has become a world’s leading independent AR provider.
• who we are and how you can contact us;
• which categories of personal data we process, the sources from which we obtain personal data, the purposes for which we process personal data and on which legal basis we conduct such processing;
• to whom we transfer personal data;
• for how long we store personal data; and
• your data subject rights in relation to the personal data we process.
- Contact Information
Who we are and how to contact us
- Inglobe Technologies Srl
- Via Giacomo Matteotti 103
- 03023, Ceccano, Italy
You can contact us by E-Mail: [email protected]
- Scope of Application
2.1 The ARmedia SDK
The ARmedia Software Development Kit is a development framework utilizing a variety of
recognition and tracking methods, including images, objects, geolocation technology, beacons and
more in general 3D markerless tracking.
2.2 ARmedia Plugin
ARmedia Plugin is an authoring tool that allows to create, manage and publish Augmented and
Mixed Reality experiences without programming skills. It is available for a variety of third-party 3D
Hyper* is a suite of web-based tools that enable the creation of complex AR experiences using a
variety of tracking methods. The experiences are built and hosted in the cloud. Users also upload
target images in the cloud in order to generate trackables. Hyper* also comes with a variety of
verticalizations and they include Hyperspaces, Hyperindustry and Hyperpublisher.
2.4 ARmedia Player
The ARmedia Player App is a mobile app that allows augmentation of contents created with
2.5 Hyperspaces App
the Hyperspaces App is a mobile or smartglass application that allows to augment contents
created with the HyperSpaces and Hyper* platforms.
2.6 E-mail and newsletter services
From time to time we send information about our own products to our customers. Additionally,
we offer subscription to our newsletter service – our newsletter covers augmented reality news,
product updates and offers, including offers of our partners.
- Data categories and purpose
Which data categories we process for which purpose
3.1 Data we do NOT process
3.1.1 Sensitive (“special”) data categories
We do not process sensitive (“special”) data categories of our customers and service users.
Sensitive (“special”) data categories not processed by us include data that reveal racial and ethnic origin, political opinions, religious or philosophical beliefs, as well as genetic data, biometric data to uniquely identify a natural person, health information or data to the sexual life or the sexual orientation of a natural person. Of course, we also do not process any data on criminal convictions or offenses. If you provide unsolicited information containing sensitive (“special”) data categories to us (e.g. by entering an e-mail revealing sensitive data such as a function within a church or a trade union in a registration form), such data will only be processed as part of the fulfillment of the contract (or the contract initiation), as requested and entered by you.
3.1.2 User behavior data
We do not process any information about individual users’ usage of our services except where, and to the extent that, it is technically necessary for the performance of such services.
3.2 The categories of personal data we process, the respective purpose(s) and legal basis and the sources from which we obtain personal data
3.2.1 Information we collect and process during registration for one of our Services (applies for SDK, ARplugin and Hyper) Data category: Name Purpose of processing: We process your name in order to be able to get in contact with you. Legal basis: This information is necessary for the performance of the contract (Art. 6 no. 1 b GDPR). Source: Your entry in the registration form Data category: E-mail address Purpose of processing: Contact for electronic information and user name for login profile. Legal basis: Necessary for the performance of the contract (Art. 6 no. 1 b GDPR). Source: Your entry in the registration form Data category: Address Purpose of processing: We need your address for billing purposes. Legal basis: Necessary for the performance of the contract (Art. 6 no. 1 b GDPR). Source: Your entry in the registration form Data category: Country Purpose of processing: We need the information about the country you live in and/or operate from for billing purposes. Legal basis: Necessary for the performance of the contract (Art. 6 no. 1 b GDPR). Source: Your entry in the registration form Data category: Town / City / Postcode Purpose of processing: We need the information about the town you live in and/or operate from for billing purposes. Legal basis: Necessary for the performance of the contract (Art. 6 no. 1 b GDPR). Source: Your entry in the registration form 3.2.2 Information we process during usage of one of our Services (ARmedia SDK, ARplugin and Hyper)
Data category : Device and service specific Information (Operating System, SDK Version)
Purpose of processing : Non-personal device information is collected for program evaluation and maintenance. We do not collect or store such information in connection with personal data.
Legal basis: The device and service specific information we collect does not include personal data, therefore it does not require a specific legal justification.
Source: The information is transmitted to us, when a registered user uses one of Inglobe’s products or when an end user uses an application that includes one of Inglobe’s products.
Data category: Internet protocol (IP) addresses
Purpose of processing: Inglobe logs the IP addresses on the servers of the service being used mainly to ensure that the services run smoothly and to detect minuses of our services and for error detection/investigation. These log files are not used for any other purpose and will automatically be deleted 30 days after the IP address was transmitted.
Legal basis: It is necessary for performance of the contract you concluded with us that we track
functionality and errors to ensure a smooth AR experience (Art. 6 no. 1 b GDPR).
Source: The transmission of your IP address is a technical requirement, when you use our cloud based services (Hyper*).
Data category: Analysis of page visits
Legal basis: Your consent, Art. 6 no. 1 a GDPR.
Source: Whenever you use our services, we automatically collect and store this information.
3.2.3 Information we process during usage of the ARmedia SDK and Plugin trial version
Data category: E-mail address.
Purpose of processing: During a trial usage of our SDK and Plugins, we may process data about how often your trial key was used as well as the app-id. We receive the e-mail address so that we can observe (i) how, (ii) how often and (iii) when the free-trial version was used by you as a potential customer for the purpose to inform you about technical details, and – when the program was not used as expected – to ask about your reasons for not using the program. In case a trialuser does not buy a commercial license of the SDK or ARplugin product after the end of a free-trial period, we might send additional personalized e-mails for direct marketing reasons.
Legal basis: The purpose of the data processing is based on the legitimate interests of product improvement and direct advertising for promoting our own products and addressing potential customers directly (Art. 6 no. 1 f GDPR).
Source: Every time you use the trial version of SDK, the e-mail address of your account under which you downloaded the trial license will be processed by us. We request you to provide your email address to us during the registration process. In exchange we offer you a trial license.
Data category: Device and service specific information (Operating System, Product version)
Purpose of processing: Non-personal device information is collected for program evaluation and maintenance. We do not collect or store such information in connection with personal data
Legal basis: The device and service specific information we collect does not include personal data, therefore it does not require a specific legal justification.
Source: We collect this information automatically whenever you log on to the SDK trial version.
Data category: Target assets
Purpose of processing: The functionality of the SDK may allow users to process and store personal data (eg pictures of natural persons or documents) as target objects or target images. Such use is
enabled by the technology of Inglobe but not conducted under the control of Inglobe.
Legal basis: A user that intends to store target images or target objects on servers hosted by Inglobe needs to seek approval of Inglobe and may be required to conclude a data processing agreement with Inglobe. If such data is processed by use of our technology without being stored on servers hosted by us, we are not involved in the processing within the meaning of Art. 4 no. 8 GDPR.
Source: Target assets are uploaded by the user.
3.2.4 Information we process during the payment/procurement process (ARmedia SDK, ARmedia
Plugin and Hyperspaces)
Data category: Address
Purpose of processing: Your address helps us to stay in contact with you as our customer. We further need your address for individualization reasons.
Legal basis: The storage of addresses is necessary in order to fulfill our contractual obligations
(Art. 6 no. 1 b GDPR).
Source: You share your Address with us when signing up for one of our services.
Data category: VAT-ID
Purpose of processing: If applicable we need your VATID for tax purposes.
Legal basis: If you provide us you’re your VAT-ID we are required by law to process this information in connection with our invoicing. (Art. 6 no. 1 c GDPR).
Source: If applicable, you enter your VAT-ID during registration for the service.
Data category: Credit Card Information
Purpose of processing: Your Credit Card information will only be used during the payment process. Only the last four digits of the credit card information will be stored.
Legal basis: Processing of credit card information may be necessary for conducting your payment (Art. 6 no. 1 b GDPR).
Source: When you use Credit Card as a payment method, you disclose your Credit Card Information to us and/or our payment provider(s).
Data category: Contracts and nondisclosure-Agreements
Purpose of processing: We process and store information about contract conclusion to fulfill our legal obligations and for evidence purposes.
Legal basis: Legal requirement for accounting purposes (Art. 6 no. 1 c GDPR); legitimate interest of preserving evidence for the case of dispute and/or default of payment.
Source: Your entry during the registration and/or payment process.
Please note that all payment related data will be forwarded to the payment provider chosen by you.
3.2.5 Information we process with our e-mail and newsletter services
(a) Product information e-mails
Data category: E-mail address
Purpose of processing: Source Information about our own products, including advertising for our own products.
Legal basis: Our legitimate interest in advertising (Art. 6 no. 1 c GDPR)
Source: E-mail address(es) you entered during registration for one or several of our services.
(b) Newsletter services
Data category: E-mail-address
Purpose of processing: Provide you with augmented reality news, product updates and offers – including advertising for our own products as well as for products of our partners.
Legal basis: Your request and your consent to receive our newsletter (Art. 6 no. 1 a, b GDPR).
Source: E-mail address(es) you entered when you subscribed for our newsletter.
- Data recipients
Information about when we share personal data with others
We will not share your personal data with any third party companies, organizations or individuals for their own purposes as an independent company unless we do have your active (meaning: optin)
consent. In addition, we will share your personal data only if one of the subsequent circumstances applies.
4.1 Transmission within the group
No personal data regarding customers of Inglobe Technologies are transmitted by Inglobe Technologies to other companies controlled or owned by Inglobe, unless we do have your active (meaning: opt-in) consent.
4.2 Transmission to external processors
We only transfer personal data to external processors if we have concluded a data processing agreement with them that meets the legal requirements under art. 28 GDPR. This means Inglobe may transfer or disclose personal data to a third party that agrees to process personal data strictly limited to our respective instructions and to provide appropriate technical and organizational data security measures. We primarily cooperate with processors located in the European Union and will only transfer personal data to processors outside the European Union if an appropriate level of data protection is guaranteed. The processors we cooperate with include:
Your payment data will be processed by PayPal (a service by PayPal (Europe) S.a.r.l. et Cie, S.C.A., a company registered with the commercial register of Luxembourg under R.C.S. Luxembourg B 118
349) 4.2.2 Studio Associato Ferrante & Mollicone (Tax consultant)
For accounting and documentation purposes, we send bills and contract documentations to our tax consultant Studio Associato Ferrante & Mollicone (a tax advisor professional studio under
4.2.3 Google Analytics
We only process non-personal (anonymized) data on a regular basis for analytics purposes to Google Analytics. Google Analytics is a service by Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA.
4.2.4 Amazon EU or US
We may use Amazon EU or US cloud services to store assets (ie target images and AR experience that you upload via our products. To be able to offer you these services, we need to share your personal e-mail address with Amazon.
4.2.5 Aruba Spa and Seeweb srl
We may use Aruba Spa and Seeweb srl cloud services to store assets (ie target images and AR experience that you upload via studio or via our products. To be able to offer you these services, we need to share your personal e-mail address with these companies, that are already GDPR compliant.
- Storage period
How long we store collected data
5.1 General storage period
Our storage of personal data is always limited to the period necessary to achieve the purpose of the storage. Where a storage period prescribed by European regulations and directives and/or any
other relevant legislation has expired, the personal data will be routinely blocked or deleted in accordance with the statutory provisions. If you have purchased a product from Inglobe Technologies (SDK, ARplugin or Hyper*), your data will be stored for as long as their use is required for the execution of the contract (e.g. for payment and contract handling) and, moreover, for the fulfillment of legal obligations (retention or accounting obligation). Your data will be deleted as soon as they are no longer needed to fulfill the contract and, moreover, all legal obligations for storage have expired.
5.2 Personal data of trial users
Your personal data will be stored at least for as long as necessary for you to access the trial products. During this period we may send you e-mails about products corresponding to your trial license (similar products). If you have not used your trial license in six months (or for the whole period of the trial) we will consider you as a “non-active” user. If you do not react to any of our follow-up emails within two years from when you have become a non-active user, we will delete all personal data related to your trial license (unless the same data is required for fulfilment regarding another product license we have granted to you.
- Rights of the Data Subject
Your rights under the applicable data protection law
Inglobe Technologies Srl is a company located in the European Union. Under the GDPR and ancillary data protection law, as a person affected by data processing you have the following rights:
• Right of access: Upon request, we will inform you about the scope, the origin and the recipients
of your personal data processed by us as well as of the purpose(s) of such processing. In case of excessive Requests for Access (more often than 4 times a year), we reserve the right to charge an expense reimbursement.
• Right to rectification: Should any personal data related to you as processed by us be incorrect or incomplete despite our efforts to ensure that the data is accurate and up to date, we will correct it
at your request.
• Erasure: Under certain circumstances, you have a right to erasure, for example, in connection with a contradiction or when data was collected illegally. If the legal prerequisites for an erasure are present (meaning that there are no legal obligations or predominant interests against the request), we will carry out the requested erasure immediately.
• Restriction: You may also request a restriction of the data processing for the same reasons that justify an erasure. In that case, the stored data must remain stored (ie for evidence purposes) but may no longer be used otherwise by us.
• Right to object and withdrawal of consent: You are entitled to object against any data processing conducted by us based on a legitimate interest. Upon objection we will cease to process the respective personal data except for exceptional cases where we hae compelling
legitimate grounds for the processing which override your interests; as regards data processing for direct advertising purposes, this right of objection has an absolute nature, we will thus never invoke compelling legitimate grounds overriding your legitimate interests if you object to use of your data for advertising purposes; Any consent you have given to processing of your personal data can be revoked at any time in writing and free of charge (for contact see sec. 1 above).
• Data portability: If you wish to transfer provided data to another controller, we will provide the data in an electronically transferable format.
• Right of appeal to the Data Protection Authority: We also remind you of your right of appeal to the Data Protection Authority. You have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, your place of work or the place of the alleged infringement, if the data subject considers that the processing of the personal data is in breach of this Regulation. You may also contact us directly at any time.
To exercise these rights, please use the contact information under point 1. Please note that we will request submission of documents and/or information to verify your identity when treating your request. We do so in order to make sure that your personal data is never disclosed to a third party not entitled to receive your personal data.
Valid from: 25th May 2018