OVA Inc. located at 2590, Boulevard Laurier, Office 910, Quebec (Quebec), G1V 4M6, Canada ("OVA" or "we") places particular importance on the protection of your Personal Information. That is why we are committed to ensure the accuracy, security and confidentiality of the Personal Information collected about you, in accordance with applicable laws. 

This Privacy Policy (the "Policy") defines how OVA collects, uses, discloses and retains your Personal Information and is intended to help you understand our practices. By providing us with Personal Information, you consent to its processing in accordance with this Policy. 

This Policy does not apply to third-party websites and software that may be accessed through our website, platform, software, products or applications, as the case may be (collectively, our "Services"). 

For the purposes of this Policy, "Personal Information" means any information about an identifiable individual, as defined in Canadian law.

OVA has appointed a Chief Privacy Officer. If you have any questions, comments or complaints about this Policy, please contact Harold Dumur, CEO, at the following email address: legal@ova.ai.


1. THE PERSONAL INFORMATION WE COLLECT

‍In the course of our business and service provision, the Personal Information collected may include, but is not limited to:

- Your First Name;
- Your Last Name;
- Your Email Address;
- Your Password;
- Your Birth Date;
- Your Company;
- Your Industry;
- Your Occupation;
- Your XR Experience Level;
- Your IP Address;
- Your Location (Latitude, Longitude, Region, City, Country Code, Country Name, Continent Code, Continent Name)
- Your Headset Model;
- Your Graphics Card Name
- Your Graphics Memory Size;
- Your Operating System;
- Your Processor Count;      
- Your Processor Type;
- Your System Memory Size;
- Your Driver Media Type;
- Your Licence Type, Expiration Date, Status;
- Your Space Names;
- Your StellarX App Version;
- Your StellarX Feature Usage;
- Your StellarX Session Token;
- Your Loading StellarX Space Time;
- Your Loading Opening StellarX Time;
- Your Steam Identifiers;
- Your immersive content creations (3D Model, video, image, audio file) while using the Services containing Personal Data; 
- Your activities, stats, friends, and preferences;
- Your use of our Services and other technical information relating to your browsing behaviour;
- Your communications to us.

We do not knowingly collect personal data about anyone under the age of 16, unless a parental consent is provided, but in no event on anyone under the age of 13.

OVA may not refuse to respond to a request for goods or services or to a request relating to employment by reason of the applicant's refusal to disclose Personal Information except where:
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- collection of that Personal Information is necessary for the conclusion or performance of a contract;
- collection of that Personal Information is authorized by law;
- orthere are reasonable grounds to believe that the request is not lawful.
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2. HOW WE COLLECT YOUR PERSONAL INFORMATION

‍OVA collects your Personal Information from you and through cookies. 
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2.1 From you

‍You provide us directly with Personal Information, such as when you create an account on our Services, when you access and use our Services, when you click on an advertisement that we have placed on a third party website (e. g. Google, Facebook, etc.), when you contact us, when you complete an online request form or when you purchase one of our products or services.

2.2 Cookies

‍Cookies are small data files that are commonly stored on your device when using websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. OVA collects Personal Information provided by cookies.

OVA uses different types of cookies:

- Performance and functionality connection cookies: These cookies are not essential to the provision of our services. They facilitate the personalization and enhancement of the user experience. For example, they may store your personal preferences, which prevents you from having to re-enter information more than once, or store your credentials so that you do not have to enter them every time you log in.

- Cookies for advertising purposes: These cookies are not essential to the provision of our services. They store information about your website visit, such as the pages visited or the response to advertisements, to help provide a user experience that is tailored to your needs.

If you wish to disable the use of cookies, you can do so from your browser's preference menu. You may disable cookies or use private browsing mode when using any OVA the services OVA.


3. HOW WE USE YOUR PERSONAL INFORMATION

‍Personal Information collected by OVA will be used for the following purposes:

- Provide, maintain, customize and improve our services;
- Distribute updates and patches for the software;
- Ensure that software’s license is properly managed and to prevent product privacy;
- Allow OVA to perform internal operations related to its services; and
- Send or facilitate communications between yourself and OVA and you in connection with the services.

Except as already provided by applicable privacy legislation, OVA will request your consent before using your Personal Information for purposes not previously identified. 


4. YOUR CONSENT TO THE COLLECTION AND USE

‍Your consent to the collection, use and disclosure of your Personal Information is required, except where inappropriate. (For example, for legal or security reasons, it may be impossible or impractical to obtain consent.).

By agreeing to use OVA’s services, you expressly provide OVA with your consent to collect, process, and use your Personal Information in accordance with the provisions of this Policy.

You represent that you are aware of the purposes for which OVA collects, processes, and uses your Personal Information, how it will be collected, and how we protect the confidentiality of the Personal Information.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. 


5. RETENTION OF PERSONAL INFORMATION

‍Personal Information will be retained as long as necessary for the fulfillment of the identified purposes or for compliance with legal requirements regarding retention periods.

Any user may request that their account be deleted by sending an email request to OVA by email or by deleting his account from their profile at https://www.ova.ai/profile/dashboard


6. OUR SECURITY MEASURES

‍OVA implements industry-standard, state-of-the-art security measures to protect its customers from unauthorized access or use, alteration, unlawful, or accidental destruction or loss of their

Personal Information.Unfortunately, it is impossible for us to guarantee the absolute security of the Personal Information collected or transmitted through our Services. 

You therefore understand and agree that (i) there are limits to the security and confidentiality of the Personal Information we collect that are beyond the control of OVA; (ii) the security, integrity and confidentiality of all Personal Information and data exchanged between you and OVA through our Services cannot be guaranteed; and (iii) such Personal Information may be viewed or altered by a third party at the time of transfer. For these reasons, OVA cannot be held responsible for any loss, capture or alteration of Personal Information. 


7. ACCESS AND MODIFICATION OF PERSONAL INFORMATION

‍You have access to your Personal Information through your user account on our Services, if applicable. You can correct and update this Personal Information from this access at https://www.ova.ai/profile/dashboard.

You may obtain a copy of your Personal Information or have it corrected, if it is incorrect, by sending us a written request by email. 

No request for access, rectification, or deletion may be considered unless it is made in writing by you when you prove that you are the individual concerned (or the representative, heir, or successor of that individual, or the liquidator of the succession, a beneficiary of life insurance or of a death benefit). 

When we receive a request for access, rectification, or removal, we will attempt to respond within a reasonable time frame after receipt of the request.

In certain situations, OVA may not be able to provide access to all the Personal Information it holds about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request. 

Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

A reasonable fee may be charged for the transcription, reproduction or transmission of Personal Information.


8. PERSONAL INFORMATION DISCLOSURE

‍OVA will not disclose your Personal Information to a third party unless you consent, or unless such disclosure or use is required by law.

Personal Information may also be disclosed without your consent for research purposes if the documents containing the Personal Information are not structured so as to allow retrieval by reference to your name or identifying code or symbol and the Personal Information cannot be retrieved by means of such a reference.


9. POLICY CHANGE AND UPDATE

‍OVA may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a change is made to the Policy, you will be notified when you log in and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on our Services. OVA asks its users to consult the amended Policy before continuing to use its services. If you refuse the updated version of the Policy, you will be able to terminate your account.

The continued use of the services provided by OVA, after the amended Policy comes into effect, constitutes consent to such amended Policy.


10. POSSIBILITY TO FILE A COMPLAINT

‍OVA has established procedures to receive complaints and inquiries about its policies and practices for the management of Personal Information. The complaints procedure is easily accessible and simple to use.

OVA will inform persons making an inquiry or complaint of the existence of the relevant procedures. 

OVA will investigate all complaints. If a complaint is found to be justified, OVA will take appropriate measures, including, if necessary, amending its policies and practices.


11. EUROPEAN UNION DATA

‍This Section 11 applies only to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection. 

11.1 Right to erasure

‍With some restrictions applicable, in accordance with the international application of the General Data Protection Regulation, you will be entitled to obtain from OVA the prompt deletion of your Personal Information and OVA is required to delete such Personal Information as soon as possible, where any of the following reasons apply:

- the Personal Information is no longer necessary for the purposes for which it was collected or otherwise processed;
- you withdraw the consent on which the processing is based and there is no other legal basis for the processing;
- you object to the Processing and there is no compelling legitimate reason for the Processing;
- the Personal Information has been unlawfully processed;
- the Personal Information must be deleted to comply with a legal obligation to which OVA is subject; and
- the Personal Information was collected as part of an offer of services normally provided for remuneration, remotely, electronically and at the individual request of a recipient of services.

Where OVA has made the Personal Information public and is required to delete it, OVA, taking into account the available technologies and the costs of implementation, will take reasonable steps, including technical measures, to inform data controller who process such Personal Information that you have requested that such data controller delete any link to or copy or reproduce such Personal Information.

This right to erasure shall not apply to the extent that the processing is necessary:

- the exercise of the right to freedom of expression and information;
- to comply with a legal obligation requiring processing by a public authority authorised by the law to which OVA is subject or to carry out a task in the public interest or in the exercise of a public authority vested in OVA;
- the establishment, exercise or defence of legal claims.

11.2 Right to restrict processing

‍You will be entitled to obtain from OVA a restriction to process when any of the following applies:

- for a period of time that allows OVA to verify the accuracy of the personal data while you dispute the accuracy of the Personal Information;
- the processing is unlawful and you object to the deletion of Personal Information and instead require a restriction to process by limiting the Personal Information use;
- OVA no longer requires the Personal Information for the purposes of the processing, but it is still necessary for you to establish, exercise or defend legal rights;
- you object to the processing during a verification as to whether the legitimate grounds pursued by OVA prevail over your own.


11.3 Right to Data Portability

‍You will be entitled to receive the Personal Information you have provided to OVA, in a structured, commonly used and machine-readable format, and you will be entitled to transmit such Personal Information to a third-party without OVA impeding it where the processing is based on your consent and the processing is carried out using automated processes.

11.4 Right to Object

‍You may object, at any time, for reasons relating to your particular situation, to the processing of your Personal Information which is necessary for the legitimate interests pursued by OVA or by a third party or for the performance of a task carried out in the public interest or in the exercise of a public authority vested in OVA, including profiling. OVA will no longer process Personal Information unless OVA demonstrates that there are compelling legitimate reasons for the processing that prevail over your interests, rights and freedoms or for the establishment, exercise or defence of legal rights.


11.5 Automated Individual Decision-Making, Including Profiling

‍You may not be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner, unless the decision is:

a) necessary for the conclusion or performance of a contract between you and OVA;
b) authorized by the law to which OVA is subject and which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests; or
c) based on your explicit consent.

In the cases referred to in points (a) and (c) above, OVA will implement appropriate measures to safeguard your right to obtain human intervention from OVA, to express your views and to challenge the decision.