Privacy Policy
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 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 Disclose 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 Magic Leap products (such as software that runs on our devices) or use a Magic Leap product or service managed by an enterprise, what information is collected by such third party or enterprise and how it is used is not controlled by Magic Leap. When used in this policy, the term “enterprise” refers to any organization responsible for managing your use of the Magic Leap products or services. Be sure to review the privacy practices of these enterprises to better understand how those third parties collect, use, or share your information.
Our Products and Services
Magic Leap 2 is our 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 disclose certain data to 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.
Our products and services may also include software development kits (SDKs) and/or 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 portal.
Learn More: For more information about Magic Leap’s products and services, including regarding our collection of data and the choices available to you, please review the Magic Leap “Learn Mores” found in our Privacy Hub.
Information We Collect
The information we collect may vary, depending on the 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 (whether directly or indirectly through a third party), 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 or company 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, contacting customer support or visiting our booth at an event.
- 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, information regarding your purchases of Magic Leap products and services, or other financial information.
- Website 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 collected via device sensors (such as peripheral cameras, depth sensors, motion sensors, microphones and picture cameras). This information is not collected automatically by Magic Leap, however, you or an enterprise may share this information with us for customer support and product improvement purposes.
- 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 an 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 Magic Leap “Learn Mores” found in our Privacy Hub.
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;
- 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 Magic Leap “Learn Mores” found in our Privacy Hub.
How We Disclose Information
Before we describe our disclosure 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 disclose 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 an 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 disclose information to other members of the Magic Leap community. For instance, our websites may include forums or communication tools.
With third-party service providers: We may engage third parties to deliver a product or service on our behalf (or enhance specific features within our offerings), or to perform certain tasks, at our direction.
With applications and solutions you use on a Magic Leap device: When you install and/or use applications on our devices, certain information may be automatically accessible to the application provider to enable certain features and functionality. You may also have the option to provide additional information through a variety of on-device permissions. Review the privacy policy of any application or solutions provider you engage to understand how your information may be used.
With an enterprise: When you use a Magic Leap device managed by an enterprise, such enterprise may collect certain information about you and your usage of the device. Please review the enterprise’s policies or contact the enterprise administrator directly to learn more about the information available to the enterprise.
With social platforms: Depending on the products or services you use, you may have the option to share content from Magic Leap products or services to a variety of social media platforms, such as YouTube. You should review the policies of the social media platforms you use, to learn about how they collect and use the information you disclose to those services. For example, please see Google’s privacy policy for details on how they use this information. If you no longer want Magic Leap’s products or services to be able to access data from or post to your YouTube account, you may revoke access using Google’s security settings page.
Other sharing: In addition to the above, we may also disclose 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 disclose aggregated or de-identified information, which cannot reasonably be used to identify you, with others.
Learn More: For more information about how we disclose information, and the choices available to you, please review the Magic Leap “Learn Mores” found in our Privacy Hub.
Your Choices
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 and data accessed by applications and solutions (including application permissions), please review the Magic Leap “Learn Mores” found in our Privacy Hub.
Product Features: We offer a variety of privacy settings and choices through our device setup and settings. Choices you make around providing optional information may limit your ability to use certain features or functionality.
Enterprise: Enterprise customers using our products and services for their employees or customers may also have the ability to make certain decisions on your behalf, if you use devices they manage. Please review the enterprise’s policies or contact the 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 accessible 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.
For more information about cookies and other tracking technologies, and options to disable them, please see our Cookie Policy. Please note that we do not currently respond to “do not track” signals or other mechanisms that might enable you to opt out of tracking on our websites.
Promotional Emails: You may opt out of receiving promotional emails from us by following the instructions in such marketing emails or by emailing privacy@magicleap.com. If you opt out, we may still send you non-promotional emails, such as those about your account or your purchases.
Your Rights
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.
- 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.
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.
- United States Residents: If you would like to exercise your rights afforded to residents of certain US states, please click here. If you have any issues with our webform, you may also submit a request by emailing us at privacy@magicleap.com. For more information on the rights available to US 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 privacy@magicleap.com. 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 privacy@magicleap.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.
Advertising and Analytics Services Provided by Others: We engage others to provide analytics services via our websites, and to serve advertisements on our behalf on other websites and online services. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of our websites and other websites and online services, including your IP address, web browser, pages viewed, time spent on pages or in apps, links clicked and conversion information. For example, we use Google Analytics. See Google’s privacy policy for more information about how Google collects and uses data about you when you use our websites. For more information about cookies, including how you may be able to opt out of interest-based ads, please see our Cookie Policy.
Location-Specific Notices
The following sections describe additional notices and rights that may apply to you based upon where you reside:
This section provides additional disclosures for and details about rights afforded to residents of certain US states, including, without limitation, California consumers under the California Consumer Privacy Act or “CCPA,”, as well as the California Privacy Rights Act or “CPRA”, Colorado residents under the Colorado Privacy Act or “CPA”, Connecticut residents under the Connecticut Data Privacy Act or “CTDPA”, Oregon residents under the Oregon Consumer Privacy Act or “OCPA”, and Virginia residents under the Virginia Consumer Data Protection Act or “VCDPA.”
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 To Whom We May Disclose Your Personal Information: We may disclose your personal information to the categories of third parties described in the How We Disclose Information section above.
Your Rights: Please see Your Rights above for a description of rights Magic Leap makes available to all individuals. In addition, the following rights may be available to you, depending on the state in which you reside:
- Sale of Your Personal Information: We do not sell the personal information we collect, within the meaning of any state laws. We will not sell personal information in the future without changing this policy and providing any residents of California or other applicable states the right to opt out of such sales.
- Sharing of Your Personal Information/Targeted Advertising: We do not disclose your personal information to third parties for cross-contextual behavioral advertising (i.e. “sharing” within the meaning of the CCPA) or otherwise use personal information we collect from you for purposes of targeted advertising (within the meaning of other state laws). We will not “share” or otherwise use your personal information for targeted advertising in the future without changing this policy and providing any residents of California or other applicable states the ability to opt out of such sharing or use.
- Appeals: 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 privacy@magicleap.com. 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.
Advertising/Analytics: Please note that we may use cookies and related technologies set by other companies for other types of advertising and analytics, as further described in the Advertising and Analytics Services Provided by Others section above. However, based in part on how we’ve configured their technologies, these companies have committed to only use the data they receive via our products and services for the limited business purpose of providing services to us.
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.
Contact Us
This privacy policy applies to Magic Leap, Inc. If you have any questions about this policy, you may contact our Senior Privacy & Product Counsel, Scott Paskal, at: privacy@magicleap.com or at: Magic Leap, Inc., Attn: Privacy, 7500 W Sunrise Blvd, Plantation, FL 33322.
If you are in the EU, you may contact us at: euprivacy@magicleap.com or at: Corda Campus, Attn: Magic Leap Belgium BV, Privacy, Kempische Steenweg 301/1, Room 001, B-3500 Hasselt.
If you are in the UK, you may contact our representative at: ukprivacy@magicleap.com or at: Magic Leap UK, Attn: Privacy, Suite 2, First Floor, Templeback, 10 Temple Back, Bristol BS1 6FL, United Kingdom.
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