Date of last revision: Monday, July 22, 2019
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 services we provide via our Device. When we mention “Device,” we mean our hardware devices, which include Lightwear, Lightpack and Control. More information regarding the components of our Device can be found here.
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.
Our Data Practices
Information We Collect
The information we collect falls into the three main buckets, each as described below:
Provided by You
This part is straightforward. When you provide us with information, we will collect it. For example, this happens when you sign up for our emails, create a Magic Leap ID account, update your profile, complete a purchase through the Platform, participate in online forums or interact with other users, submit text through our apps or Device (including through our voice-to-text dictation service), fill out a form, or request customer support. The types of information we collect include your name, phone number, birthdate, email address, profile picture, nickname, billing or shipping address, payment method information, text fields (and audio used to convert to text), your contacts, photos or other content you upload to our Services, prescription range information, and any other information you choose to provide. Additionally, if you register to create or publish apps for our Device, we may collect additional information you provide, such as your business contact information, bank account information or, if you register to publish apps as an individual, your Social Security number.
Collected Through Our Device and Services
Information collected through our Device and Services comes from a few sources, including our Device sensors, Services we provide for the Device, and our mobile application and website.
Our Device captures data through a variety of sensors.
For example, the Device has depth sensors and peripheral cameras that help to gather information about your surrounding environment. This data 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.
The Device also has microphones, motion sensors, and other cameras (both inward and outward facing) that record audio, measure your movements, enable use of certain features, determine what you are looking at, and enable you to take pictures and video with your picture camera. The audio we collect includes voice data collected when you record video, make video calls, or use voice-to-text dictation, and also other sounds from the world around you that do not include voice data. These other sounds help us to improve the spatial maps of your surroundings (sort of like sonar) and create realistic sound effects around you.
Of all the raw data collected by the various sensors on the Device, 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 Your Choices section below for more information. All other raw sensor data is meant to remain on your Device.
Services We Provide for the Device
When you use the Services we provide for your Device, the following data is collected automatically:
Wi-Fi Access Point Information: We collect information about the Wi-Fi routers detected by your Device, which includes MAC address, signal strength and similar connection data.
Device 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.
Services Log Information: We collect log files when your Device connects to our Services, including those we provide via our Device and the apps we publish. This information includes access times, Services used, hardware and software versions, Device identifiers, and IP address.
App Download and Usage Information: We collect information about the apps you download and install from Magic Leap World, as well as the apps you start, stop, pause and resume.
Device Performance Information: We collect certain thermal and battery performance information from all Devices connected to our Services.
Magic Leap App Analytics: We collect information about your use and the performance of apps that Magic Leap publishes for our Device, including which features or screens you access, time spent in an app or a specific screen, interactions with other users and other usage information.
Additional Information with Your Permission: While Magic Leap collects certain information from its Services and your Device, as described above, additional analytics information regarding use of your Device is only collected with your permission. This additional information includes certain sensor data and usage data, including data about performance of our operating system software and information about the ways you interact with your Device. We also only collect crash reports, which may contain contents of the screens at the time of the crash, with your permission. More information on the additional information collected with your permission is provided during the setup process for Magic Leap One. Please refer to Your Choices to review the choices available to you with respect to this additional information.
Our Mobile Application and Websites
Information about Your Mobile Device: We collect technical information about the mobile device you use to access Magic Leap’s mobile application, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Mobile Device Sensor Information: We collect data from the sensors on your mobile device when you use Magic Leap’s mobile application, which generate data about how the mobile device is moving, which way it is facing, its speed, and similar orientation and movement data.
Log Files: Our websites and mobile application collect log files similar to the types of log files that all of our Services collect, which may include IP address, time and date of access, web browser type, and website you last visited before arriving at our website.
Analytics and Usage Information: We use various technologies to collect analytics and usage information via our websites and mobile application, including cookies and web beacons. For more information about cookies and other tracking technologies, and how to disable some of them, please see Your Choices.
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 Magic Leap One. Please refer to Your Choices for more information regarding your choices when it comes to this access.
Received from Others
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 to your Google account via our Platform to import your contacts into your Device address book to see which of your friends may already be using our Platform.
We also rely on third-party systems to help analyze suspected fraud, which may result in purchases being declined and/or registration being denied on an automated basis. Please contact us at firstname.lastname@example.org if you think these systems inappropriately suspected fraud.
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:
Spatial Mapping: Spatial maps are essentially digital models of the physical areas surrounding a Device. Spatial maps do not include images of individuals or text, and instead just help to reproduce the physical contours of the surrounding area. These maps allow us and other app providers to display digital objects in the space surrounding your Device in a realistic manner.
Device Interactions: We use the data collected via the Device sensors to determine the pose of your head and your hand, understand where you are looking, recognize your gestures and derive other similar input data. This data helps us and the third-party apps you use 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 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 in a few other ways that are necessary to operate our business – you can find more about each of these below.
There are three key ways in which you can enable us to share information with others:
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 enable Shared World to contribute to 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. Please refer to Your Choices for more details.
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. Please refer to Your Choices for more details regarding the information shared with other 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. You may also choose whether to share crash reports with the providers of the apps you install on your Device. Please refer to Your Choices for more information regarding the choices available to you with respect to crash reports on our Platform.
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 and procedures of your social media accounts to learn about how they collect and use the information you share to those services.
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; and
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. For example, we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
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.
Cloud Processing for Spatial Maps: When you first set up your Device, you can choose whether or not to enable cloud processing for spatial mapping If you use cloud processing for your spatial maps, you will be able to store more maps, update your maps more quickly, and enable shared experiences with other users. If you do not enable cloud processing for spatial mapping for privacy or other reasons, your spatial maps are designed to stay on your Device. You can change this choice through Device settings at any time.
Shared World: You may also be presented with the option of whether or not to enable Shared World. If you enable Shared World, each spatial map created from your device about a particular space will be saved to a collective map of that space that is stored in Magic Leap’s cloud ecosystem. You need to enable cloud processing for spatial maps to use Shared World, but you can use cloud processing without Shared World if you prefer. You can change your selection through Device settings at any time. Should you later choose to change your settings to disable Shared World, the maps you have contributed to the collective spatial maps will not be deleted. This is because the contributed maps become part of the combined Shared World experience, and are not directly associated with a particular Device or Magic Leap ID account. If there are spaces you do not want to be part of the collective spatial maps, we encourage you to change your settings before entering that space.
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.
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. As noted in the section above on sharing, you may also choose to share crash reports with the providers of the apps you install. These choices may also be adjusted through the settings on your Device.
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. More details on data that applications can access and our app permission framework are provided during the setup process for Magic Leap One. 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.
Magic Leap App Choices
We also offer choices in connection with some of the apps Magic Leap publishes for our 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, determining how discoverable you are to the Social community, and the ability to determine 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.
Website and Mobile Application Choices
Information on Your Mobile Device with Your Permission: We collect information about features on your mobile device that you use to access Magic Leap’s mobile application in accordance with the permission process set by your mobile device, including access to the microphone, camera and your photos.
Mobile Device Settings: The settings in your mobile device should allow you to stop sharing access to certain information or features with us via our mobile application. For example, you should be able to deactivate our access to information collected from your microphone or camera, images in your photo gallery, or our ability to send you push notification messages.
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 and Correction: 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 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.
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.
Other Important Details
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.
Children: Our Platform is not intended for children under 13 years of age. If you live in the EEA or Switzerland you must be at least 16 years old to use our Platform. If you are a parent and believe we have collected personal information from a child under 16 in the EEA or Switzerland, or 13 everywhere else, please contact us at firstname.lastname@example.org.
Individuals in the European Economic Area (“EEA”) or Switzerland
If you are in the EEA 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 fulfil 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 securing and improving our Platform, detecting and preventing fraud, and analyzing 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, Creator Agreement , and Terms of Sale). We will take steps to implement appropriate safeguards to help provide an adequate level of protection for this data.