Last Revised: March 9, 2023
What this Policy Covers
This policy applies to information that Magic Leap collects across all of our augmented reality products and services, and when you otherwise interact with us. An overview of our products and services, including how to find even more detailed information for each generation of such products and services, is available below.
Within this policy, we cover the following topics:
- Our Products and Services
- Information We Collect
- How We Use Information
- How We Share Information
- Your Choices
- Your Rights
- Other Important Details
- Location-Specific Notices
- Contact Us
Please note that this policy only applies to Magic Leap. When you use third party products and services that are designed for use with our products, such as third party applications and solutions available for your Magic Leap device of any generation, what information is collected and how it is used by that third party is not controlled by Magic Leap. Be sure to review the privacy practices of these third parties prior to using their products or services with Magic Leap products to better understand how those third parties collect, use, or share your information.
Further, if you are using a Magic Leap product or service managed by an enterprise (e.g., your employer), then the enterprise, and not Magic Leap, determines what information it collects regarding your use of such Magic Leap products or services, as well as how any such information will be used or shared by such enterprise. Be sure to review the enterprise's policies to better understand how the enterprise handles your information.
Our Products and Services
Magic Leap 1 (including Magic Leap One: Creator Edition) is our first generation wearable computer that provides access to a connected augmented reality ecosystem. The Magic Leap 1 ecosystem includes the Magic Leap 1 device, LuminOS, our first-party applications, our application store (Magic Leap World), and a variety of connected services such as our Magic Leap ID, Magicverse and Device Manager offerings.
Magic Leap 2 is our next generation immersive AR headset designed for enterprise that runs an operating system software based on Android Open Source Project (AOSP) . Magic Leap 2 is a standalone spatial computer (along with available products and accessories) that enables a user to build and run immersive AR experiences. Magic Leap 2 devices may include certain technical features that enable you (or the enterprise managing the devices) to collect data from such Magic Leap 2 devices. You, or the managing enterprise, may elect to share certain data with Magic Leap for limited purposes (like to check for software updates, receive customer support services, or monitor license key compliance), however, Magic Leap 2 devices are not designed to offer a consumer-focused ecosystem like Magic Leap 1.
Each generation of our products and services also include software development kits (SDKs) and similar software tools to enable third party developers to create applications and solutions for our devices. We also operate websites to share documentation, learning resources and other materials to support our products, such as magicleap.com and our developer portals. Additional details regarding collection of data via generation-specific solutions, such as use of a Magic Leap ID account to log in to our first generation developer portal, are available via the Learn More articles for that specific generation.
Learn More: Magic Leap provides additional documentation specific to each generation of our products and services. Please visit our Privacy Hub and review the "Learn Mores" and additional policies specific to the generation of products and services relevant to you, including the choices you may have regarding Magic Leap's collection and use of your data.
Information We Collect
The information we collect may vary, depending on the generation of our products and services you use. When you create an account, purchase and use a device, visit our websites, download software, connect to our services, contact us, or otherwise interact with Magic Leap, we may collect the following categories of information:
- Account Information: Information you provide to create an account such as name, email address, and other biographical information.
- Contact Information: Information such as name, job title, email address, physical address, phone number, or other contact information, such as you may provide when purchasing a device or contacting customer support.
- Analytics Information and Crash Reports: Information such as how our products and services are used, and the performance of our products and services. This information may be collected on an ongoing basis with your permission or requested by Magic Leap, such as if you contact customer support.
- Payment and Transaction Information: Information such as billing address, method of payment (e.g., bank, credit, or debit details), information regarding your purchases of Magic Leap products and services, or financial information to enable us to pay you if you publish paid apps for Magic Leap 1 devices.
- Website and Mobile App Log and Usage Information: Information such as IP address, time and date of access, features used, website visits, browser type, derived location information, download history, web pages viewed and other usage information.
- Download and Usage Information: Information such as what products and services you download and use.
- Sensor Data: Information such as data used to create spatial maps, eye tracking data, and audio which is collected via device sensors (such as peripheral cameras, depth sensors, motion sensors, eye cameras, microphones and picture cameras). If you use a Magic Leap 2 device, Magic Leap does not collect this data, though the managing enterprise may receive eye imagery from the devices.
- Other Device Information: Certain device information, such as your device serial number, hardware and software versions, thermal and battery performance, settings information, Wi-Fi information and the location of your device. This information may be collected automatically on an ongoing basis or requested by Magic Leap, such as if you contact customer support.
- Other Information You Provide to Us: Information you or your enterprise submit to Magic Leap, such as customer feedback (whether in written, oral, or electronic form) or other information you provide when you interact with us, like participating in our online forums or training sessions.
Learn More: For more information about our collection of data and the choices available to you, please review the "Learn Mores" specific to the generation of products and services relevant to you.
How We Use Information
We use the information we collect to enable the features and functionality of the products you use and to provide services to you.
We also use the information we collect to:
- Personalize and improve our products and services, such as customize and improve your experience or provide advertisements or features that match your profile or interests;
- Develop new augmented reality and other products and services;
- 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 products and services;
- Detect, investigate and prevent fraudulent transactions, 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.
Learn More: For more information about our use of data and the choices available to you, please review the "Learn Mores" specific to the generation of products and services relevant to you.
Our products and services have several features that offer you choices around whether or how you use them. For more information about the choices available to you related to product features, data accessed by applications and solutions (including application permissions), please review the "Learn Mores"specific to the generation of products and services relevant to you.
Product Features: We offer a variety of privacy settings and choices through our device setup and settings (depending, in part, on whether you are using a Magic Leap 1 or Magic Leap 2 device). Choices you make around providing optional information may limit your ability to use certain features or functionality.
Enterprise: Customers using our enterprise products and services for their employees may also have the ability to make certain decisions on your behalf. Please review your employer's policies or contact your enterprise administrator directly with questions regarding specific settings and choices that you are unable to modify.
Data Accessed by Applications and Solutions: As detailed above, some of the information from your device is shared automatically to help applications and solutions operate on our devices, while other access is only granted with your permission. The access that you grant through permissions can be adjusted in device settings at any time, though certain apps or features (whether offered by Magic Leap or a third party application provider) may not function without certain permissions.
Promotional Emails: You may opt out of receiving promotional emails from us by following the instructions in such marketing emails. If you have a Magic Leap ID account, you can also unsubscribe from our marketing emails within your account settings. 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. 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. If you opt out of receiving promotional emails from Magic Leap, Magic Leap will also cease using your email address for the purpose of tailored audience ads.
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.
Depending on where you reside, you may have other rights available to you in addition to those described above. For more information, please review the Location-Specific Notices section below.
Exercising Your Rights
Individuals who wish to submit a privacy related request can either do so on their own, or through a third party, such as an authorized agent. Prior to taking action on any privacy-related request, Magic Leap takes steps to limit fraudulent activity by requiring information be provided that matches information we currently maintain about the subject of the request. Failure to provide us with the information requested may result in our denial of the request. We respond to all legitimate requests within legally mandated timeframes.
- California Residents: If you would like to exercise your rights under the CCPA, please click here. If you have any issues with our webform, you may also submit a request by emailing us at email@example.com. For more information on the rights available to California residents, please refer to the applicable subsection of the Location-Specific Notices section below.
- EEA, UK, or Swiss Residents: If you would like to exercise your rights under the GDPR, UK GDPR, or the Swiss Federal Act on Data Protection, please click here. If you have any issues with our webform, you may also submit a request by emailing us at firstname.lastname@example.org. For more information on the rights available to EEA, UK, and Swiss residents, please refer to the applicable subsection of the Location-Specific Notices section below.
- Residents of Other Jurisdictions: If you would like to exercise your rights as described herein or any other rights which may otherwise be available to you under the laws of the jurisdiction in which you reside, please submit your request by emailing us at email@example.com
Other Important Details
Changes to this Policy: 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 use Magic Leap's products and services 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.
The following sections describe additional notices and rights that may apply to you based upon where you reside:
This section provides details about rights afforded to California consumers under the California Consumer Privacy Act or "CCPA," and its underlying regulations. We also provide 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.
Categories of Personal Information We Collect: In the last 12 months, we have 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 certain of our products and 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 does not fall 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).
Categories of Sources From Which We Collect Personal Information: The above information has been collected from the following sources:
- information you provide directly to us;
- information we collect automatically as you use certain of our products and 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.
Purposes for Collection: We collect personal information for the business and commercial purposes described in the How we Use Information section above.
Categories of Third Parties With Whom We Share Your Personal Information: We share this information with the categories of third parties described in the How We Share Information section above.
Sale of Your Personal Information: We do not sell the personal information we collect (and will not sell it in the future without changing this policy and providing the ability to opt out of such sale).
This section provides details about rights afforded to Virginia consumers under the Virginia Consumer Data Protection Act or "VCDPA".
Please see Your Rights above for a description of rights available to you, which include rights provided under the VCDPA.
Appeals: In addition to the rights available to you as described in the Your Rights section above, if you reside in Virginia, you have the right to appeal any refusal by Magic Leap to take action on a request to exercise the rights afforded to you under the VCDPA within a reasonable period of time. You may exercise your right to appeal by submitting your request to appeal to Magic Leap via email at firstname.lastname@example.org. We will inform you in writing of any action taken or not taken in response to your appeal, along with a written explanation of the reasons for our decisions. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.
In accordance with Connecticut law, we publish this privacy protection policy in connection with the Social Security numbers we may collect from Connecticut residents that register as Magic Leap 1 app publishers.
As part of this 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.
European Economic Area ("EEA"), United Kingdom ("UK"), and Switzerland
Magic Leap, Inc. is the data 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 products and 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 products and services, detect and prevent fraud, and analyze how you use our products and services and how our products and services perform.
- 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 products and services to you pursuant to our applicable user agreements (visit the Magic Leap Legal Hub for copies, depending on which product and services you use). We will take steps to implement appropriate safeguards to help provide an adequate level of protection for this data.
Complaints: In addition to the rights available to you as described in the Your Rights section above, if you reside in the EEA, UK or Switzerland, you have the right to file a complaint regarding our data protection practices with your local supervisory authority. If you reside in the EEA, please see this directory for contact details. If you reside in the UK, you can contact the Information Commissioner's Office. For Swiss residents, please refer to the Office of the Federal Data Protection and Information Commissioner.
If you are in the EU, you may contact our representative at: email@example.com or at: Magic Leap Belgium BV, Attn: Privacy, Stephanie Square Centre Avenue, Louise 65, Box 11, Brussels 1050 Belgium.
If you are in the UK, you may contact our representative at: firstname.lastname@example.org or at: Magic Leap UK, Attn: Privacy, Westpoint 4 Redheughs Rigg, South Gayle, Edinburgh Lothian Region, EH12 9DQ United Kingdom.