Effective date: 12th February 2024

Haven Studios Limited ("Haven","we", "us", "our") respects your privacy and is committed to protecting your Personal Data and your right to privacy. Haven is responsible for the Personal Data we collect and process (collectively "we", "us" and "our"). "You" means the individual to whom the Personal Data relates.

This Privacy Policy outlines the way in which we handle information that we receive through our Services, when you visit the YourHaven website at yourhavenapp.com ('Website'), the YourHaven app ('App'), and/or (b) you sign up for a newsletter, provide a service to us, or engage with us by phone, email or other means with respect to any other subject matter ('Services'). The policy includes information on how we collect, use, share and otherwise process or use the data provided. This information includes any data that relates to an identified or identifiable person or makes a person identifiable ('Personal Data'), such as names, addresses, electronic device information (e.g., device IDs and IP addresses), other identifiers, health information, and financial information.

This Privacy Policy also provides information on how you can opt-out of certain uses of your information or correct any errors. This notice will also tell you about your privacy rights and how the law protects you. This policy, however, does not apply to any third-party websites, services or applications, even if they are accessible through our Services. It's important to note that any capitalised terms used in this Privacy Policy have the same meanings as in our Terms of Service. This Privacy Policy applies to Personal Information that Haven collects, records, stores, uses, discloses, or otherwise processes through our Services, whether done automatically or manually.

Thank you for choosing to be part of our community at Haven ("Company", "we", "us", or "our"). If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at support@yourhavenapp.com.

The Website is not intended for children and we do not knowingly collect data relating to children.
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1. Important information and who we are

Haven (registered company number 14524463, with registered office address of 35 Ballards Lane, London, United Kingdom, N31XW) have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice or our data protection practices, including any requests to exercise your legal rights, please contact the data privacy manager using the following details:

Email address: support@yourhavenapp.com
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2. Data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you including:
 

• Contact Data, such as email address;

• Profile Data, such as email/password and preferences for tailoring the sessions;

• Identity Data, such as first and last name;

• Demographic Information, such as your age, gender and location;

• Marketing and Communications Data, application logs from the App, including whether you have signed up for our newsletter or consented to receive other electronic marketing communications, and your preferences regarding the same;

• User data, as follows:
  
  Directly provided data, including various types of information from users of its Services. One category is information that users provide directly to Haven through communication channels such as email or phone. This information may include the user's name, email address, phone number, and postal address, and it may be collected when the user requests information about the Services, subscribes to Haven's newsletter, seeks customer or technical support, or otherwise interacts with Haven.
  
  User Account data, i.e., data Haven collects when users create accounts, including certain identifying information, such as the user's name, age, email address, state of residence, and mobile number. If the user creates an Account using login credentials from one of their social media accounts, Haven may also be able to access additional Personal Information, such as the user's name and email address, as permitted by the privacy settings on the social media account. Additional information that may be collected when a user creates an Account includes the user's gender and date of birth.
  
  Session data, including data in connection with a user's use of the Services, Haven also collects and stores Session data. This includes information related to the user's eye and head movements, heart rate and breathing, and mood and feelings, as measured through surveys and questionnaires in the App. If a user accesses the Services through an Account, Session data may also include Personal Information. Haven uses this information to provide and improve its Services, including managing user Accounts, ensuring the quality and safety of the Services, processing payment sand transactions, communicating with users about their Accounts and activities on the Services, providing newsletters and customer or technical support, and collecting data related to user engagement with the Services.

We may also collect non-Personal Data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as statistics or aggregated information such as anonymised analytics data including (total time spent on session, most popular sessions, sessions cancelled and errors). Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users accessing a specific Website feature.

In limited circumstances we may collect, use or share aggregated data such as statistical or demographic data, or collect special categories of Personal Data about you, including details about your race, ethnicity, or political opinions. We do not collect any Personal Data about criminal convictions and offences via this Website or the Services.  Where we process special categories of data, we will process this data under the correct lawful basis and conditions for processing, as required under applicable data protection legislation, and we will only use your Personal Data when the law allows us to.
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3. How we collect your Personal Data

Our commitment is to collect your personal information in a fair and lawful way. To access and use our App, you will need to register with Oculus and create an account with a unique Oculus ID and Profile. When you register, you will need to provide basic information such as a valid email address and a password. Your personal information will be collected by the App through Oculus and shared with us. We may also use different methods to collect data about you, i.e.., through our Website, collecting data at events or from our partners, or when you correspond with us, for example, to enquire about our activities.
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4. How we use your personal data

Haven uses your information for various business purposes, such as fulfilling our agreement with you and providing our services. To achieve this, we collect, store, use, and process your Personal Information. This includes managing your accounts, verifying or maintaining the quality and safety of our services, processing transactions and payments, and communicating with you about your account, activities on our Services, and any policy changes that may affect you. Additionally, we provide our newsletter and offer customer or technical support as part of our service. Our aim is to continuously improve and enhance our services to meet your needs and expectations.

We will only use your Personal Data for the purpose for which we collected it, which may include the following:

• to provide, maintain and improve our Website and App's functionality and service, including to administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes and to monitor the usage of our service

• to manage your account: to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user;

• for the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the service, including to carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including managing payments, fees and charges and to collect and recover money owed to us;

• to contact you: to contact you by email, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;

• to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquiredabout unless you have opted not to receive such information;

• to manage your requests: including to respond to your inquiries and fulfil your requests to us;

• for business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our service users is among the assets transferred;

• for other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing, partner relationships and your experience, to protect our Website, employees, or operations;

• for environment recordings: Haven collects and analyses a variety of information about your activities in the virtual environment, including details about your avatar, physical movements, speech data, and social interactions.  This data helps us improve the user experience, personalise content, and monitor for inappropriate behaviour

• to target candidates and invite them to apply for roles as a new member of permanent staff or as a consultant and to evaluate applications and candidate suitability for roles;

• to target candidates and invite them to apply for roles as a new member of permanent staff or as a consultant and to evaluate applications and candidate suitability for roles;

We may use non-Personal Data for any business purpose.
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5. Legal basis for processing

We process your Personal Data:

• where we need to perform the contract we are about to enter into or have entered into with you or your organisation;

• for the purposes of legitimate interest pursued by us (or those of a third party), and your interests and fundamental rights do not override those interests; or

• in order to comply with a legal and regulatory obligation to which we are subject;

• where processing is necessary toprotect the vital interests of the data subject or another natural person;

• for the establishment, exercise or defence of legal claims.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications, such as e-newsletters, to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting using the link which appears atthe bottom of the communication, or by emailing us using the contact details provided in this Notice.
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Legitimate interests
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Where our processing is based on the legitimate interest grounds described above, those legitimate interests are:

• collecting Personal Data to provide a smooth and efficient App experience;

• to make sure you receive updated information on our business activities;

• to provide the Services you have requested, including receiving notifications and App updates; and

• for our own marketing and research.

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6. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a relevant Service.
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7. If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an account).  In this case, we may have to cancel any relevant contract you have with us, but we will notify you if this is the case at the time.
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8. Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
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If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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9. How we share your Personal Data

Except as expressly set out in this Privacy Notice we will not sell, distribute, trade or lease your Personal Data to third parties unless we have your permission or are required by law todo so.

The Personal Data you provide to us may be shared with third-party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our Services, respond to your inquiries or for any of the purposes described in this Privacy Notice. We work with third-party service providers who offer website and application development, hosting, maintenance, data transmission, data processing, and other services for us.  These service providers may have access to or process your information as part of providing those services for us, but we only provide them with the personal information necessary to perform their functions.

We may make certain automatically collected, aggregated, or non-personally-identifiable information available tothird parties for various purposes. This includes participating in medical or behavioural research efforts, monitoring network traffic or activity to detect network intrusions and protect our users from malware, fraud, unlawful uses, or other illegal activity, and complying with various reporting obligations.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may also share your Personal Data with:

• law enforcement agencies, other governmental agencies or third parties if we are required by law or in good faith to comply with state or federal laws, respond to a court order or subpoena, or cooperate with law enforcement or other governmental agencies. We may also be required by law to report information regarding the abuse of vulnerable or disabled adults or minors, and if you provide us with information that could identify you, we may have to record and provide such information to the appropriate authorities;

• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.  In the event of a merger, acquisition, debt financing, sale of assets, or similar transaction involving Haven, information about our users, including personal information, may be disclosed and transferred to the acquirer or successor. If Haven is acquired by or merged with another company, this privacy policy will continue to apply, and we will notify you before any information about you is transferred and becomes subject to a different privacy policy.

We reserve the right to disclose your information when we believe, in good faith, that it is necessary to take precautions against liability, protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, investigate and defend ourselves against third-party claims or allegations, protect the security or integrity of our platform or facilities, or protect our property or legal rights or the rights, property, or safety of others.

Other than as outlined above, we will notify you when information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
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10. International data transfer

Haven is based in the UK, but we may process and store your personal information on servers located in countries in the European Economic Area (EEA) or the USA, as part of the provision of the App and the Services. These countries may have different data protection laws than your country of residence.  By using our platform, you consent to the transfer of your personal information to these countries.
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If you are located in the UK, whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the followingsafeguards is implemented: (i) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection forpersonal data; or (ii) where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the sameprotection it has in the UK.

If you are located in the EEA or Switzerland, we will only transfer your personal information to countries that have been deemed by the European Commission to provide an adequate level of protection for personal data, or to recipients that have agreed to standard contractual clauses approved by the European Commission.

If you have any questions or concerns about our international transfers of personal information, please contact us at support@yourhavenapp.com.
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11. Your legal rights

You have the following rights under data protection laws in relation to your Personal Data:

• to request access to or a copy of Personal Data which we hold about you;

• to request deletion of your Personal Data; Haven has a mechanism to delete customer data from its logs upon request and users can request to delete their data by emailing: support@yourhavenapp.com

• to rectification of your Personal Data, if the information we are holding is inaccurate or incomplete;

• to withdraw consent to our processing of your Personal Data (to the extent such processing is based on previously obtained consent);

• to ask us to stop or start sending you marketing messages as described below in the marketing section;

• to request the transfer of your Personal Data to you or to a third party;

• to request the restriction of processing of your Personal Data; and

• to object to your Personal Data being processed in certain circumstances.

Any request from you for access to/a copy of your Personal Data must be in writing and we will endeavour to respond within a reasonable period in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a Data Subject.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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12. How long we keep your Personal Data

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.

This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.

We will typically only retain your personal information for two years after we become aware that you have stopped using our services, unless we are required to retain it by law.  We may indefinitely retain de-identified or non-personally identifiable information for backups, archiving, prevention of fraud and abuse, analytics, or other legitimate interests.

Where we are permitted to send you direct marketing communications, we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you optout from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
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13. Cookies

When you interact with the Website, certain information about your use of the Website is automatically collected.  This information includes your domain name and host for Internet access; the Internet address of the website from which you came; the date and time of your access; your computer's IP address and information about its operating system, browser and host; the date and time you access the Website and the pages you visit.  Much of this information is collected through cookies, web beacons, pixel tags, local storage and analytics tools and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.). This may also include mobile carrier, unique identifiers (e.g., cookie identifiers), browser and device details, location information, Internet service provider, the pages you view before, during and after using our Services, links you click on and other information on how you use the Services.

The tracking technologies employed when you use our Website may be first party or third-party. We use cookies for the following purposes:

• Necessary: these cookies are required for core Website functionality such as security, network management, and accessibility. You may disable these by changing your browser settings to disable cookies, entirely but this may affect how the Website operates.

• Performance/Analytics: we use these cookies to analyse how the Website is accessed, used or is performing. We use this information to maintain, operate and continually improve the Website.  We may also obtain information from our e-mail newsletters, to learn whether you opened or forwarded the newsletter or clicked on any of the content. This information tells us about our newsletters' effectiveness and helps us ensure that we're delivering information that you find interesting.

• Advertising: Interest-based advertising is the collection of data across different websites and/or difference devices for the purpose of tailoring advertising based on preferences or interests known or inferred from the data collected.  We allow third parties, such as Google, Facebook, and Twitter, who assist us in serving advertising regarding the Website when you leave the Website, to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and target ads.

We may also collect information that is associated with your account and other devices you use. Additionally, we may collect data about your activities on the Services, such as the types of content you interact with and how frequently and for how long you engage with such content. Haven uses cookies to enhance your experience, analyse trends, and personalise content and advertising. We use both session and persistent cookies, and some are essential for our platform to function properly.

The third-party Website analytics tools that collect automated information about visitor traffic on our Website include Google Analytics. Google Analytics is a web analytics service provided by Google, Inc., on our Website. Google Analytics uses cookies or other tracking technologies to help us analyse how users interact with and use the Website, compile reports on the Website's activity, and provide other services related to the Website's activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies. You can learn how Google collects and processes data and how to opt out of tracking of analytics by Google, by clicking here.

If you do not want to receive cookies, you may set your browser to reject them.  However, if you turn cookies off, you may not have access to some of the Website's services and features. We also may allow third parties to issue cookies, pixels, web beacons and other tracking technologies on our Website to help us compile aggregated statistics regarding the operations of our Website. You can learn more about ad serving companies and the options available to limit their collection and use of your visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, Adchoices (for Canada) and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Because an industry-standard Do-Not-Track protocol has not yet been established, our information collection practices on our Website will continue to operate as described in this Privacy Notice regardless of any "Do Not Track" signals that may be sent by certain browsers.  However, you may refuse to accept cookies in order to prevent tracking activities.
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14. Security

We are committed to trying to ensure that your information is secure. In order to prevent unauthorised access or disclosure, we use reasonable physical, electronic and managerial procedures intended to safeguard and secure the information we collect online. We store your personal information on secure servers and use encryption technology to protect sensitive data.
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15. Links to other sites

Our Website may contain links toother websites, plug-ins and applications, including via our social media buttons such as Facebook, Instagram and Twitter. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.  Once you link to another website from our Website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices, so we encourage you to read the privacy policy of every website you visit.

While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website.
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16. Complaints

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to support@yourhavenapp.com.

If you have any concerns about our use of your information, you also have the right to make a complaint to the applicable data protection authority in the European Economic Area or the UK. We would, however, appreciate the chance to deal with your concerns before you approach such an authority so please contact us in the first instance.
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17. Changes to this Privacy Notice and your duty to inform us of changes

Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Notice.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address: support@yourhavenapp.com.