Date of last revision: Monday, March 16, 2020
What this Policy Covers
This policy applies to information we collect across all of our products and services, including our Device and our Services (collectively, our “Platform”), and when you otherwise interact with us. When we refer to our “Services” in this policy, we mean Magic Leap’s websites, apps and online services, including the online services we provide via our Device. When we mention “Device,” we mean our hardware devices, which include Lightwear, Lightpack and Control. Here are the topics covered by this policy:
- Information We Collect
- How We Use Information
- How We Share Information
- Your Choices
- Your Rights
- Other Important Details
- California Privacy Notice
- Individuals in the EEA, UK or Switzerland
- Contact Us
Information We Collect
The information we collect varies depending on the products and services you use. Please refer to the relevant product or service below for more details:
Our Devices are at the heart of our platform. Please review this section to understand what information your Device collects and what Device information Magic Leap receives through the Services we provide for our Devices.
Overview: Our Device uses a variety of sensors:
Peripheral Cameras: Outward-facing cameras on the Device collect wide view images of your surroundings in grey scale, which can be used, for example, to help determine the position of your head, refine spatial maps of your environment and measure light intensity around you.
Depth Sensors: Depth sensors collect depth images of your surroundings, which can be used, for example, to build spatial maps of your environment (by identifying the relative distance of nearby objects), as well as to identify gestures made by your hands.
Motion Sensors: Motion sensors in your Device and in your Control measure the relative motion of your head and of the Control, which direction you are facing, and the speed and direction of your motions.
Eye Cameras: The Device also has inward-facing cameras, which can be used, for example, to figure out where you are looking and, if you enable Iris ID, to authenticate you on your Device.
Microphones: Microphones on the Device capture audio of your voice during video recordings, calls, and when you use voice-to-text dictation features and Speech Commands. The microphones also collect acoustic sound from the world around you, which can be used to help improve the spatial maps of your surroundings and create realistic digital sound effects.
Picture Camera: The Device also has a picture camera that you can use to take pictures or videos of the world around you. Apps and certain Magic Leap Platform features with your permission may also access the picture camera.
Storage of Sensor Data: Of all the raw data collected by the Device sensors, only the depth images, audio, and picture camera content are designed to be collected by Magic Leap via the Services, and then only if you have enabled the applicable Service(s). Please review the Device Features section below for more information. All other raw sensor data is meant to remain on your Device.
Status Indicator: The external status indicator light on our Device provides certain information that helps to alert others about when certain Device sensors are capturing information. Additional information regarding the lights on the Device may be found here.
Our Device has several features that offer you choices around whether or how you use them. Depending on how you setup or use these features, we may collect additional information from your Device via our Services. For example:
Spatial Mapping: Spatial maps are a critical part of the Magic Leap ecosystem and help the Platform enable interactions between digital content and your actual physical surroundings. As mentioned above, Device sensors continuously scan your environment, process that information, and use it to create 3D representations of your area (which we refer to as spatial maps). Spatial maps can include up to three different levels of detail:
World Features: World Features are 3D representations (also called “point clouds”) of the world around you, and serve as the basic building blocks of a spatial map. World Feature points can be used as references to place and persist content (so you can come back to that content later, at the same place).
World Models: World Models add more detail to your spatial maps, including dense mesh data and planes. The result is spatial maps that provide much more accurate representations of the world around you, enabling digital content to respond to the environment in a more natural way.
World Understanding: World Understanding is an optional component of spatial mapping that allows our Devices to recognize some types or classes of objects in your environment from images that your Device captures, such as the ability to identify chairs and posters, and include data about those objects in your spatial maps.
You can decide whether to store World Features on your Device, or in one of our cloud-based storage options, (Personal World or Shared World). World Models are designed to be processed locally on your Device. You can also choose whether to enable or disable World Understanding through Device settings. If you enable World Understanding, you, agree to contribute your World Understanding results to Shared World. Additionally, the World Understanding feature can only be enabled and used if you select Shared World storage for your World Features. If there are spaces you do not want to be part of the collective spatial maps in Shared World, we encourage you to change your settings before entering that space. Learn more about spatial mapping and your options for storing your spatial maps.
Iris ID: Our Device offers an optional hands-free unlock option through software designed to enable iris recognition. The data used to support Iris ID is designed to remain locally on the Device. Learn more about Iris ID.
Speech Commands: If you use Speech Commands (like “Hey Lumin, take a picture”), the audio recorded is designed to remain locally on your device. However, if you have chosen to share additional analytics information with Magic Leap, the resulting text strings and event success or failure data from your use of Speech Commands may be collected by Magic Leap. Learn more about Speech Commands.
Gestures: If you enable it, Gestures can use depth sensor information to allow you to take system actions with your hands, like moving an app without using your Control. Processing of depth sensor information to enable this feature is designed to take place locally on your Device. Learn more about Gestures.
Other Device Information
Below is a description of other information we collect via the Services we provide for your Device, regardless of the features you have enabled:
Wi-Fi and Location Information: We collect information about the Wi-Fi routers detected by your Device, which includes MAC address, signal strength and similar connection data. We use Wi-Fi information to derive your precise location (through Google’s Geolocation API). We also use IP address to derive your approximate location. Learn more about our detection and processing of location information.
Settings Information: We collect information about the settings on your Device, including a list of paired Bluetooth devices, volume preferences, and which apps have received permission to access Device data or functionality, such as the Device microphones or picture camera.
Log Information: We collect log files when your Device connects to our Services. This information includes access times, Services used, hardware and software versions, Device identifiers, and IP address.
App Download and Usage Information: We collect limited information about apps that you download and install to your Device from Magic Leap World, including the apps you start, stop, pause and resume.
Performance Information: We collect certain thermal and battery performance information from all Devices connected to our Services.
Additional Information with Your Permission: In addition to what is described above, Magic Leap collects additional types of analytics data and crash reports with your permission, which includes information about how you use your Device, such as volume levels and buttons pressed; eye tracking data, such as pupil measurements and gaze information; data about performance of our operating system software; as well as crash reports that include log files from the Device, performance of the software being used at the time of the crash and information about what the Device was doing at the time of the crash. Please refer to Your Choices below to review the choices available to you with respect to this additional information.
Apps for Our Device
We collect any information you provide through the apps we publish for the Device, such as feedback or other text. We also collect telemetry and usage data, including features or screens you access, time spent engaging in an activity, interactions with other users and other usage information.
Certain of our Services extend across our Platform and other platforms. This section describes the information that Magic Leap collects when you use those Services.
Magic Leap ID Account
You need a Magic Leap ID account to use many of our products and services, including to sign into a Device, our mobile or desktop applications and our developer portal. When you set up your account, we collect email address, name and birthdate. You can add other information to your profile such as nickname, phone number, location, profile picture and other bio information. You can also select your home country for Magic Leap World and store payment method information in your account for future purchases.
Additionally, if you connect your Magic Leap ID account with an account you have with a separate social media service, we will collect information provided by the social media service in accordance with their user permission process. For example, you may connect your Magic Leap ID account with your Google account via our Platform to import your contacts into your Device address book to help you see which of your friends may already be using our Platform.
The Magicverse is a new Magic Leap Platform that extends Magic Leap’s spatial mapping capabilities and allows for cross-platform experiences of digital content. Applications that have integrated with the Magicverse platform, whether created by Magic Leap or a third party, allow you to interact with spatial maps through those applications. On other platforms, you will be prompted to log in with your Magic Leap ID before the application is able to access spatial mapping functionality.
In connection with your use of this feature, Magic Leap will collect feature point information about your environment, your location, technical and sensor information from your mobile device, including information about your mobile device camera and information about how the mobile device is moving, which way it is facing, its speed, and similar orientation and movement data, and log files and usage data regarding the Magicverse platform, including IP address, time and date of access, which features you access, and other usage information. The images collected by the camera on your mobile device in connection with your use of Magicverse are designed to be processed locally on your mobile device to derive feature point information about your environment.
Mobile and Desktop Applications
This section describes additional information we collect via your mobile device or computer when you use our mobile or desktop applications, including our mobile and desktop companion applications and the downloadable desktop applications for developers that are made available via our developer portal.
Information you Provide: We collect any information you provide through our mobile and desktop applications, such as feedback or other text you submit.
Technical and Sensor Information: We collect technical and sensor information from your device, including the hardware model, operating system and version, unique device identifiers, and, in the case of mobile devices, mobile network information and information about how the mobile device is moving, which way it is facing, its speed, and similar orientation and movement data.
Log Files and Usage Information: We collect log files and usage data, including IP address, time and date of access, which features or screens you access, time spent in our application or a specific screen, interactions with other users and other usage information.
Additional Information with Your Permission: With your permission, Magic Leap may also collect additional information from features on your mobile device that you access from within Magic Leap’s mobile application, including your mobile device’s microphone, camera and photos. For example, Magic Leap’s mobile application may request your permission to take your photograph to determine the distance between your pupils and help fit you for your Device. Please refer to Your Choices for more information regarding your choices when it comes to this access.
Please see below for details on the additional information we collect via our websites.
General Information you Provide: There are various ways you can provide us other information through our websites, including by signing up for our emails and participating in online forums. The information you provide may include name, email address, and the content of postings.
App Developer Information: If you register to create or publish apps for our Device, you may provide us with additional information, including your contact information, bank account information or, if you register to publish paid apps as an individual, your Social Security number. We may rely on third-party systems to help validate identity and analyze suspected fraud, which may result in a registration being denied on an automated basis. Please contact us at email@example.com if you think these systems inappropriately denied your registration.
We collect additional information if you or your enterprise uses the enterprise services we make available for our Platform, including our Services, purchasing portal and customer service offerings. For example, representatives of prospective and current enterprise customers may submit information to us, including as part of requests for information or when applying to become an enterprise customer. This information may include name, job title, email, phone number, address, payment method information and other information about the relevant business or organization.
Please be aware that if your Device has been enrolled in Device Manager by your organization, then certain of your Device’s configurations may be preset by your organization’s administrator, including electing to save spatial maps to the cloud, to share additional analytics information and crash reports with Magic Leap, or to disable user control over these and other settings. Please contact your organization’s administrator for questions about how your Device has been configured.
We operate a few different stores where you can purchase products or download apps, including our web shop for Devices and accessories, and Magic Leap World -- our app store for the Device. Depending on the type of transaction, we may collect payment method information, billing and shipping address, sizing information, and details about your transaction, such as the time and date of the transaction, the item you purchased or downloaded and any purchase amount.
We also rely on third-party systems to help analyze suspected fraud, which may result in transactions being declined on an automated basis. Please contact us at firstname.lastname@example.org if you think these systems inappropriately suspected fraud.
You may also provide us with information when you interact with us in other settings, such as if you request customer support, complete a survey we send to you, or interact with us at an event. We may collect name, contact information, audio (from customer support calls) and other information you provide during these interactions.
How We Use Information
We use the information we collect to enable the features and functionality of your Device and provide Services to you, including to create spatial maps and to generate Device interactions used by us and third-party apps to facilitate your interactions with digital content displayed via the Device.
We also use the information we collect to:
Personalize and improve our Platform, such as customize and improve your experience or provide advertisements or features that match your profile or interests;
Develop new products and services for our Platform;
Send you technical notices, updates, security alerts, and other administrative messages and to respond to your comments and questions;
Process transactions, fulfill orders and send related information, including confirmations, receipts, invoices, and recall notices;
Monitor and analyze trends, usage and activities in connection with our Platform;
Detect, investigate and prevent fraudulent transactions, Platform abuse, and other illegal activities, verify identity, comply with legal obligations, and protect the rights and property of Magic Leap and others;
Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards; and
Send you direct marketing, such as information about products, services, offers, promotions, news or events offered by Magic Leap and others we think will be of interest to you.
How We Share Information
Before we describe our sharing practices, we want to make one thing clear: except in connection with a sale of our business, as described below, we will not sell your data to other companies. When we share your data, we will either do so based on a choice you’ve made or to operate our business or provide certain products and services to you or your enterprise – you can find more about each of these below.
With other users: There are a variety of ways in which you can choose to share information with other members of the Magic Leap community. For instance, in Social, you can search for, connect and communicate with other community members. You can also elect to contribute to Shared World to improve the collective spatial maps that are stored in Magic Leap’s cloud ecosystem and made available to all users who contribute to the collective map of that space.
With other apps you use: While some information from your Device is shared automatically with apps that you choose to install on your Device, you may also choose to share other information with the providers of those apps. We require app publishers to provide notice of their privacy practices to our users via Magic Leap World, so we encourage you to review those privacy policies for information about how they will use and share the information they collect. For information about what data apps for our Device may be able to access, Learn more about app permissions.
With other social platforms: You may share content from our Platform to your social media accounts, such as YouTube or Twitter. You should review the policies of your social media accounts to learn about how they collect and use the information you share to those services.
With your enterprise: If you are an authorized user of one of our enterprise customers and are using a Device enrolled in our Device Manager program, then the administrators of your program will have the ability to view certain information about your Device, which may include apps you download, install, start and stop, and the ability to manage your Device, including remotely updating profiles and resetting Devices. Please contact your company administrator(s) for more details on how your Device Manager program has been configured.
Other sharing: In addition to the above, we may also share information about you as follows:
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, public authority request or legal process, including to meet national security or law enforcement requirements.
If we believe your actions are inconsistent with our user agreements or policies to enforce or fulfill such agreements or policies.
To protect the rights, property and safety of Magic Leap or others.
In connection with, or during negotiations of, any merger, sale of assets, financing or acquisition of all or a portion of our business.
Between and among Magic Leap and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership.
Otherwise with your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you, with others.
We offer a variety of privacy settings and choices through our Device setup and settings. Below is a summary of some of the key options, but please review your Device settings for more information about the choices available to you.
Device Features: Our Device has several features that offer you choices around whether or how you use them, including choices around spatial mapping use and storage, whether to enable Iris ID authentication, and how you’d like to interact with your Device. Please refer to the Device Features section above for more information.
Location Information: If you wish to disable our collection of precise location information from your Device, you should disable Wi-Fi on the Device. However, while Wi-Fi is disabled, your Device will not be able to connect to our Services or the Internet.
Additional Analytics Information and Crash Reports: If you wish to alter your choices regarding whether Magic Leap will receive additional analytics information and crash reports from your Device, you can do so through Device settings at any time.
Other Data Accessed by Apps: Some of the information from your Device is shared automatically to help apps operate on our Platform, including spatial maps, the position of your eyes, head and hands, and Internet access. Other access is only granted with your permission, including access to the microphone or picture camera. The access that you grant through permissions can be adjusted in Device settings at any time, though certain apps or features may not function without certain permissions.
Apps for our Device Choices
We also offer choices in connection with some of the apps Magic Leap publishes for the Device. For example, Helio offers certain privacy features, such as the ability to clear your browsing history and cookies. Additionally, Social provides some privacy settings, including the ability to set which elements of your profile are visible to other users, to determine how discoverable you are to the Social community, and to set which users can contact you through Social.
You may update or remove most of the information you provide as part of your Magic Leap ID account by logging in and accessing your profile page. You may also request to delete your Magic Leap ID account, which is designed to disable your profile and remove your name, photo and profile information. In either case, we retain certain information we have collected about you for our legitimate business purposes or as required by law, such as transaction history. Also, please note that without a Magic Leap ID account, you will not be able to access a Device and most of our Services.
Mobile Application Choices
As described above, our mobile application may request access to certain features or content on your mobile device, including your microphone, camera or photos or the ability to send notifications. Please review your mobile device settings for options to disable any permissions you have granted to our mobile application.
Promotional Emails: Please review the settings in your Magic Leap ID account to unsubscribe from our marketing emails. You may also opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or your purchases.
Advertising: You can also opt out of receiving “custom audience” ads from us in Facebook and from receiving similar types of tailored audience ads in other third-party platforms that you may be using (such as Instagram or Twitter) by accessing the ad setting features on such platforms or by contacting us at email@example.com. As part of these audience ad programs, we upload a list of email addresses to a third-party platform so that we can display interest-based ads within that platform to specific groups of users.
Subject to certain limitations and exceptions allowed by law, Magic Leap honors the exercise of the following rights for its users regardless of their location:
- Access: You have the right to request access to the personal data we process about you along with information about how we process your personal data and the categories of personal data we process.
- Correction: You have the right to request that we correct inaccurate or incomplete personal data we process about you.
- Deletion: You have the right to request that we delete personal data about you.
- Restriction: You have the right to request that we restrict processing of your personal data, such as by limiting to storing but not further processing.
- Data Portability: For personal data you provided to us, you have the right to request that we provide that data in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another controller.
- Objections: You have the right to object to our processing, such as if you object to our processing based on legitimate interests or our direct marketing.
- Revocation of Consent: When our processing is based on your consent, you have the right to revoke that consent.
- No Sales: You have the right to opt out of any sales of data - however at this time we do not sell data.
- Free from Discrimination: You have the right to not be discriminated against for exercising any of your rights.
- Complaints: You have the right to file a complaint regarding our data protection practices with your local supervisory authority. If you are in the EEA, please see this directory for contact details. For Swiss residents, please refer to the Office of the Federal Data Protection and Information Commissioner.
If you would like to exercise any of the above rights, please contact us at firstname.lastname@example.org or through Customer Care. We will verify your request by asking you to provide information that matches information we have on file about you or by having you log into your account to submit the request. You can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
Other Important Details
Notice of Changes: We may change this policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review the policy whenever you access the Platform or otherwise interact with us to stay informed about our information practices and the choices available to you.
Retention: We store the information we collect about you for as long as is necessary for the purpose for which such information was collected or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Security: We use measures designed to protect the information we collect about you against unauthorized access, use and disclosure.
Privacy Protection Policy for CT Residents: In accordance with Connecticut law, we are publishing this privacy protection policy in connection with the Social Security numbers we may collect from Connecticut residents that register as app publishers. As part of our privacy protection policy, we implement measures designed to: (1) protect the confidentiality of the Social Security numbers we collect from Connecticut residents, (2) prohibit unlawful disclosure of those numbers, and (3) limit internal access to those numbers.
California Privacy Notice
This section provides details about rights afforded to California consumers under the California Consumer Privacy Act or “CCPA,” and supplemental information that we are required to disclose pursuant to the CCPA.
Please see Your Rights above for a description of rights available to you, which include rights provided under the CCPA.
In the last 12 months, we collected the following categories of personal information: identifiers (such as name, contact information and device identifiers); commercial information (such as products purchased); internet or other network activity information (such as data about how and when you use our Services); demographic information (such as birthdate which reveals age); geolocation data; audio, electronic, visual, thermal or similar information (such as customer support call audio and camera images and video); professional or employment-related information (such as from business contacts of our enterprise customers); and other information that doesn’t fit neatly into any category of data described under the CCPA (such as payment method information and other content you upload or submit that may contain personal information). This information has been collected from the following sources: information you provide directly to us, information we collect automatically as you use our Services, and information we receive from other parties. For more details about the personal information we collect, please see the Information We Collect section above.
We collect personal information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share Information section above.
Individuals in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland
If you are in the EEA, UK or Switzerland, this section contains additional information for you. Magic Leap, Inc. is the controller of your personal information. We process information about you under the following legal bases:
- Contract: We use information about you to fulfill our contractual obligations to you, such as to provide our Services, deliver Devices you purchase, provide customer service, or fulfill other transactions like processing exchanges and returns.
- Legitimate Interest: We also use information about you when we have a legitimate interest in doing so, such as to help secure and improve our Platform, detect and prevent fraud, and analyze how you use our Platform and how our Platform performs.
- Legal Obligation: We may be required to use information about you to comply with our legal obligations, such as to communicate with you about product safety issues or provide other legally required notices.
- Consent: We may ask for consent to use information about you for specific purposes. If we do, know that you can withdraw your consent at any time. Even if we are not relying on consent to use information about you, we may still provide you with choices or ask your permission before conducting a specific processing activity.
International Transfers: We are headquartered and receive and process information about you in the United States, which may not provide equivalent levels of data protection as your home jurisdiction. This processing is necessary to provide the Services to you pursuant to our applicable user agreements (including the Account Terms and Conditions, Developer Agreement, and Terms of Sale. We will take steps to implement appropriate safeguards to help provide an adequate level of protection for this data.
Or, if you are in the EU, you may contact our representative at: email@example.com or at: Magic Leap Belgium BV, Attn: Privacy, Kempische Steenweg 303, bus 17 3500 Hasselt, Belgium.