Privacy Policy

Last Updated: January 31, 2023

1. Introduction

Global Virtual Travel (GVT), a service wholly owned and operated by SeiRogai, Inc. (“SeiRogai,” “Global Virtual Travel,” “GVT,” “we” or “us”) respects your privacy. This Privacy Policy explains the collection, use, and sharing of information from or about you, including personal information, in connection with your use of the GVT Services. The term “GVT Services” refers to our video service, including the selection of virtual reality (VR) 360-degree tours, clips, and other media content we offer (collectively, the “Content”) and our player for viewing the Content (the “Video Player”), as well as any other products, features, tools, materials, or other services offered from time to time by GVT through a variety of Access Points. The term “Access Points” refers to, collectively, the www.globalvirtualtravel.com website (the “GVT Site”), applications, and other places through which the GVT Services may be accessed, including websites and applications of GCT’s third-party distribution partners and other websites where users or website operators are permitted to embed or have otherwise licensed the Video Player. The information practices of third-party Access Points are governed by their own privacy
policies and are not governed by this Privacy Policy; accordingly, we recommend you review the privacy policies of these third parties. Please also note that the GVT Services may contain links
to other sites owned or operated by other companies, including our advertisers, and SeiRogai
does not notify you when you have chosen to click through to another website or property when using the GVT Services. We recommend that you review the privacy policies of such other websites or properties.

By viewing any Content or otherwise using the GVT Services, whether you are a subscriber, other registered user, or a visitor who has not subscribed to or registered for the GVT Services, you consent to the collection and use of information from or about you as explained in this Privacy Policy. If you do not consent to the collection and use of information from or about you in accordance with this Privacy Policy, then you may not use the GVT Services.

Please note that the website addresses (i.e., URLs) included within this Privacy Policy may not function as hyperlinks on all the Access Points.

2. Information We Collect

GVT may collect the following information from or about you, including personal information, from the following sources:

Information You Provide to Us. We collect information you provide to us. For instance, when you register to use the GVT Services, we may collect identifiers and personal information including your name, email address, credit card or other payment method information, address, ZIP code, characteristics such as your age (birth date) and gender, and other information. In addition, GVT may collect similar information you provide to us when you respond to surveys or interactive ad units, contact GVT through customer service or communicate with us by other means, or participate in promotions or events. We may also collect information you provide as part of selecting your preferences, including within your account settings, and commercial information, such as the GVT plan(s) you purchase. If GVT allows multiple profiles to be set up under one account, we may collect information you provide to us if you create a profile on these other accounts.

Usage, Technical and Log Data. We collect information when you use the GVT Services or interact with GVT, including when you view GVT advertising outside of the GVT Services. We may collect information from and about the browser or device you’re using and information about your internet or other electronic network activity, including through analytics tools. This information may include your IP address, device type, browser and software characteristics (such as type and operating system), geolocation data (which may include precise location data), referral URLs, network state, device identifiers or other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and identifiers associated with browser cookies (see our description of “Cookies and Local Storage” below), and carrier information. We also collect information about your activity on the GVT Services including information about the content you view on GVT such as video titles and virtual tour themes (“Viewing Information”), page views, and ads you have viewed on GVT.

Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.

• Cookies and Local Storage. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the GVT Services or GVT advertising published outside of the GVT Services, to monitor aggregate usage by our users and web traffic routing on the GVT Services, and to customize Content and advertising. These uses allow us to improve the GVT Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences.
  
  We may collect information through other kinds of local storage (also referred to as “Flash cookies”) and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player. Because these technologies are similar to browser cookies, they are sometimes called “browser cookies,” even though they may be stored in different parts of your computer.
  
  You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For information about disabling cookies or deleting information contained in Flash cookies, please click here.
  
  Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the GVT Services, including not being able to store your preferences or login information.
   
• Web Beacons, Pixels and mobile SDKs. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, the time and date on which you viewed the Content, the IP address of your computer, and the URL of the web page from which the Content was viewed. We may also use or work with third parties including our business partners and service providers who use mobile Software Development Kits (“SDKs”) to collect information, such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and information related to how mobile devices interact with the GVT Services.

The use of these various technologies in connection with advertising on the GVT Services is explained further below.

Account and Profile Data from Third-Party Services. If you choose to log-in, access or otherwise connect to the GVT Services, or contact SeiRogai through a third-party service, we may, for example, collect identifiers including your user ID and user name associated with that service, as well as any information you make public using that service. We may also collect information you have authorized the service to share with us (such as your user ID, billing information, public profile information, email address, birthday, pages you have “liked” and other account and profile data).

Information from Partners and Other Sources. We collect information from companies through which you may access or interact with the GVT Services (e.g., distribution partners, including device partners and voice assistant platforms) or through which you pay for the GVT Services or otherwise receive access to the GVT Services as part of your relationship with such company (e.g., mobile phone carriers or other companies that provide services to you). The information we collect from these partners may include email address and other identifiers that support authentication, activation, and personalization of the GVT Services, as well as payment processing and other billing-related matters. We may also collect information about you from other sources, including service providers (e.g., data licensors, research and analytics companies, and payment processors), public databases, our marketing partners, and advertisers. This may include information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed).

We may use the information we collect from or about you to better understand your preferences and behaviors, including to customize Content and advertising for you. We may combine the information we collect from or about you and use it in the manner described in this Privacy Policy or as otherwise permitted by law.

3. Use of Information We Collect

Use in General. We use the information we collect from or about you in order to help deliver a first-class user experience, including for the following purposes:

• providing the GVT Services, including customer support;
• contacting and communicating with you, including for promotions, updates, and
• notifications;
• customizing the Content and advertising you view and evaluating how well the Content
• and advertising perform;
• identifying Content you share;
• administering surveys, sweepstakes, contests, and other promotional activities or events;
• customizing recommendations;
• operating and optimizing the GVT Services, such as by conducting analytics and research;
• compiling aggregate data for internal and external business purposes;
• detecting security incidents, preventing potentially fraudulent, illegal or harmful activities
• and otherwise enforcing our Terms of Use and other policies;
• protecting your and our rights and complying with legal obligations;
• other uses in accordance with our Terms of Use; and
• any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.

• Use of Payment Information. We use payment information, such as credit card numbers and billing ZIP code, and commercial information, such as the GVT plan(s) you purchase, to help provide the GVT Services. For example, we use payment information to process payments from a subscriber (we use a third-party payment processor to do this), to retrieve account information for a subscriber, to determine whether a subscriber is eligible for promotions, and to detect abuse of the GVT Services.

  Use of Aggregate or De-Identified Information. In addition to the individual data use described in this Privacy Policy, we may aggregate information about you and other individuals together, or otherwise “de-identify” the information about you (which means that the information does not directly or indirectly identify you). We may use information in these forms for any legitimate business purpose, including for research and analysis, administration of the GVT Services, advertising (e.g., improving our targeting efforts), and promotional purposes.

4. Sharing Information with Others

We may share information collected from or about you with others, including business partners, social networking services, service providers, advertisers, and other companies that are not affiliated with GVT, for the purposes described below.

Partners. We work with a number of business partners who help us offer the GVT Services, including, for example, our content programmers, distributors and device partners, and corporate owners. We may share information collected from or about you with such business partners, including email address, Viewing Information, information about the ads you view on GVT and account or device information (e.g., age, gender, device type, IP address, ZIP code, advertising identifiers). This information may be shared for different purposes depending on the partner, including for reporting and analytics, activating, administering, and improving and personalizing your experience with GVT or such partner, including by providing you with more tailored content, features, and ads on GVT as well as on other platforms and services. We may also engage with companies from time to time to provide you joint promotional offers and opportunities and may share with these companies the data you provide or that is collected in connection with those offers (e.g., name and mailing address to fulfill a giveaway). Service Providers. We may share information collected from or about you with companies that provide services to us, our business partners, and advertisers, including companies that assist with payment processing, analytics, data processing and management (e.g., to facilitate our targeted advertising and marketing efforts), account management, hosting, customer and technical support, marketing, advertising, measurement, and other services. The categories of information that we share with service providers will vary depending on the types of services they provide. For example, we share payment information with our third-party payment processor to assist us in our billing efforts, email addresses with our marketing service providers to assist with our email campaigns, and IP address, hashed emails, and advertising identifiers with service providers to assist in our advertising and marketing efforts.

Audience Measurement Providers. Our business partners, such as content programmers, as well as our advertisers, seek to measure the performance of their creative material across many platforms, including the GVT Services. Accordingly, GVT may permit the use of third-party measurement software that enables third parties (such as Nielsen) to use information collected from or about you (e.g., Viewing Information, ad exposure data, IP address, advertising identifiers) to include your viewing on the GVT Services in calculating measurement statistics such as TV Ratings.

Advertisers. We display advertisements from other companies on the GVT Services, often enabling users to interact with the advertisements or click through to websites or other properties owned or operated by other companies. These advertisers and their service providers may use cookies and similar technologies to collect information, from or about you through the GVT Services in order to tailor advertisements, measure advertising effectiveness, and enable other enhancements. We may also compile and provide reports, including in encrypted, aggregated, or de-identified forms, to advertisers about the effectiveness of their campaigns.

Third Parties When Required By Law or When Necessary to Protect Your or Our Rights. In some instances, we may disclose information from or about you without providing you a choice. For example, we may disclose your information in the following ways: to protect the legal rights of SeiRogai and our affiliates or partners; to protect the safety and security of users of the GVT Services or third parties; to enforce our Terms of Use; to protect against fraud; and to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required.

Third Parties in Connection with Certain Transactions. If we sell all or part of our business, make a transfer of assets, or otherwise might be involved in a change of control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including the due diligence process.

Parties with Your Consent or When You Otherwise Choose to Share. We may also share information from or about you with any party when we have your consent or when you otherwise choose to share such information. For example, certain functions within the GVT Services may give you the option to share information about your activities on the GVT Services, for example, by email, text message, social networking services, or other sharing function. In addition, you may have the option to choose to share information with our advertisers or other partners through an interactive ad unit. Information you share through third party platforms and with social networks, advertisers, and other third parties is subject to their terms of use and privacy policies which we recommend you review.

5. Sharing What You Watch

We may ask for your consent to GVT sharing Viewing Information together with certain personal information that we may collect (such as your name, address, email address, and precise location data) with our content programmers, service providers, and other third parties. This information may help GVT or these companies personalize your experience by providing you with more tailored content, features, and ads on GVT as well as on other platforms and services. Please note that we request consent on a per-profile basis (i.e., for each profile) and therefore the consent provided for one profile does not apply to the consent of any other profile associated with the account. For clarity, even if you have not consented to GVT sharing Viewing Information together with your personal information, we may still share information collected from or about you as otherwise permitted in this Privacy Policy. For example, we may still share Viewing Information together with account or device information (e.g., IP address, ZIP code, advertising identifiers).

6. Your Controls and Choices, Including Opt-Out Options

You have the following controls and choices regarding how we and third parties use certain information collected from or about you.

Options for Sharing What You Watch. As set forth in Section 5 (“Sharing What You Watch”), we may ask for your consent to GVT sharing your Viewing Information together with certain personal information with our content programmers, service providers, and other third parties. If we have asked for your consent, you may view or change your consent preference by logging into GVT on your computer, going to your account settings, and editing your profile. If you would like to consent to GVT sharing your Viewing Information together with your personal information, set your “Manage Video Sharing” preference to “Yes.” If you would like to

withdraw your consent, set your “Manage Video Sharing” preference to “No.” You can change your consent on a case-by-case basis by changing your “Manage Video Sharing” preference before viewing a video. Please allow us a few minutes to process any changes to your preference.

Additional Rights and Choices for California Residents. Certain additional rights may be available to you if you reside in California. Please visit the California Consumer Privacy Act (CCPA) to learn more about your rights and how to exercise them.

7. Security and Account Access

The security of your information is important to us. We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to those GVT employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission.

Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur and we cannot guarantee the security of any information from or about you 100% of the time.

Please note that if you allow others to use your account (including others you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account, including information about the videos you view and your email address.

8. Children

Children under 13 years of age are not permitted to register with GVT. The GVT Services are not intended to be used by children without involvement and approval of a parent or guardian.

9. Deleting Your GVT Account

You may delete your GVT account, in accordance with our Terms of Use. You must cancel your subscription before you are able to delete your account. Please note that, after you delete your account, we may retain some information from or about you in accordance with applicable law, including for various legal, operational, accounting, and auditing purposes.

10. Applicable Law

SeiRogai is headquartered in Tokyo, Japan. By viewing any Content or otherwise using the GVT Services, you consent to the transfer of information to Japan to the extent applicable, and the collection, storage, and processing of information under Japanese laws.

11. Changes to this Privacy Policy

From time to time, we may revise this Privacy Policy to reflect changes in the law or the GVT Services or for other reasons. Therefore, it is important to check the date posted at the top of the Privacy Policy each time you visit the GVT Site or use any of the GVT Services to ensure you are familiar with our most updated policies and practices. If we make any material change to this Privacy Policy, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on the GVT Site, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.

12. Questions/Contacting Us

At GVT, we expect that our dedicated customer support team will be able to resolve most issues you may have using the GVT Services. If you have any questions regarding this Privacy Policy, you may email us at [email protected].

Thank you for taking the time to read this Privacy Policy. We hope you enjoy the GVT Services!