Privacy Policy

Valid from: 19 November 2020

Welcome to Marble. We provide a real augmented reality platform designed to enable you to interact in a common space that seamlessly merges into the real world. For this we need information about you. The protection of your privacy is very important to us. Your data will only be used by us if we have a legal basis for this use. This Privacy Policy helps you understand what information we collect, how we use it, and what choices you have when you use our app, use our websites, or participate in live events and promotions (the “Services”).

Please note that in addition to the general information below, specific information about how certain our services use your information is provided at the end of this Privacy Policy in the “App Specific Information” section.

It is important that you also read our Terms of Use, which constitute the agreement between you and Marble.

  1. Who decides how your data will be used?

Marble AR, Inc. is responsible for making decisions about how we use your personal information.

If you have any questions or comments about this policy, you can:

– email us at

– contact our data protection officer at

  1. The data we collect about you and how we use it

This Privacy Policy applies to our use of information that may or may be used to identify you (“Personal Information”). It does not apply to data that cannot be used to identify you (“Anonymous Data”).

We must collect and use certain personal Information in order to provide you with the services and fulfill the commitments we make to you in our Terms of Use:

– When you register for our services, you voluntarily provide us with personal data by providing it to us, e.g. when you register an account. We collect and use this information to authenticate you when you register an account and use the Services to ensure that you are authorized and able to receive the Services and to provide you with the correct version of the Services. This information includes the username within the platform that you choose to use within our services and the internal account identifiers that we associate with your account.

– We collect and use your device location information when you use our services (and if you enable background tracking while not actively using the services), including how you move and events that occur during use. Our services include a location-based platform whose central feature is to enable a user experience that is linked to the real-world location, so we need to know where you are to operate that platform for you and plan the location of resources within the app (for example, SPOT within MARBLE). We determine your location by using a variety of technologies, including GPS, the WLAN through which you access the services, and mobile/cell triangulation.

– We also collect and use your actions within the platform and your usage progress and certain information about your mobile device (including device identifiers, device operating system, model, configuration, settings and information about any third-party applications or software installed on your device) to provide the services to you and to ensure that we provide a fair user experience for all users in accordance with our Terms of Use (including anti-fraud and anti-cheating measures and prohibited conduct prohibited by the Terms of Use).

– We also use the above information to show sponsored locations located near you as part of your user experience within the Platform.

– We also use the above information to provide you with technical support and customer service.

– You also give us personal data if you subscribe to our publications, register for a live event, take part in a competition, advertising event, raffle or survey or communicate with us via us. Depending on which of these services you use, this may include your name, address, telephone number, country of residence, date of birth (if necessary to verify suitability), and e-mail address. We use this information to provide these services to you and to provide you with related customer support.

In addition, we have and base the use of your Personal Information as follows on legitimate interests:

– Use your IP address, browser type, operating system, website you visited before accessing our services, pages of our services you visited or features you used and the time you spent visiting those pages or features, links in our services you click on, device and advertising identifiers and actions they take during use, your app settings and preferences, and your purchases within the app to understand who uses our services and how our services are used.

– Use of your contact information, namely your e-mail address, to communicate with you and to provide you with technical support and customer care.

– Use your internal account identifier to associate user content with your account (such as local POIs) where you choose to provide this Marble through the Services.

– Use your email address and device information to provide you with updates and news about the services either within the platform or via email. You can unsubscribe at any time via your device or app settings.

– To provide social features within our platform that enable you to interact with other users, including storing your communications with those users, finding and being found by your friends, and sharing your user experiences and successes with your friends.

– To provide new or additional features for our services.

– To organize and conduct live events based on our platform or identified by our platform. Please note that if you participate in live events, your actions and achievements within the platform, your username within the platform and your avatar, and other components of your user profile will be visible to other event participants and the public (e.g., in at the event).

– To take anti-fraud and anti-cheating measures and to ensure that you and other participants comply with our Terms of Use.

– To make legal or regulatory notices

We use your personal data for the following only with your consent:

– If you choose to enable background activity tracking on our services (for example, Marble notifications), we will collect your Personal Information while you are using the services and in the background if you have not opened the services on your device. This collection includes your device location). We use background activity tracking to provide you with certain features of our services, such as vouchers within the app and bonuses linked to your fitness activity level and notices of platform events near you. You can change your mind and disable background activity tracking in your device or app settings at any time.

– Send marketing materials via email or app notifications. You can unsubscribe from these emails and app messages in your device or app settings at any time.

We also rely on your consent when we use cookies or similar technologies. You can find more information on how we use cookies in our Cookie Policy. As far as cookies collect personal data, we process these only on the basis of your explicit consent, in anonymous form or under a pseudonym.

Extra information regarding Marble’s use of Apple’s TrueDepth API on iOS devices

Marble uses the device’s TrueDepth camera system only to temporarily switch the camera into “selfie mode”, which allows you to capture photos or videos with the front camera. Only these photos or videos will be stored, but never any face data. Face data will not leave the device, is never stored remotely, or given to third parties.

Extra information regarding Marble’s use of Google Authentication Services

If you sign-in to Marble using Sign In with Google, Marble will retrieve your e-mail address, your first and last names and your Google profile picture to associate them with your Marble account. They will automatically appear in Marble, so you don’t have to type them in manually. If you choose to link your Google account to an already existing Marble account, only your email address is retrieved.

  1. With whom we share data

We do not share any Personal Information we have collected from you or about you with others except as described below:

Data shared with our service providers. We have contracted third parties to work with us to administer and provide the services. They process your personal data on our behalf. These third parties have access to your Personal Information only for the purpose of providing the services we have commissioned, in accordance with this Privacy Policy, and we ensure that each third party is contractually bound not to disclose or use your Personal Information for any other purpose. The third party service providers we use will assist us with the following:

– Run, operate and maintain our mobile games through third-party platforms and software tools;

– Moderation and crash analytics;

– Conduct email and mobile marketing campaigns;

– Perform game and marketing analytics;

– Manage live events, contests, sweepstakes and promotional events, including user registration, registration and attendance management, eligibility verification and pricing;

– providing technical support and customer care;

– Processing of payments for live event ticket sales or other purchases.

Data shared with other users. If you use the Services, and in particular if you use our App, if you use social features of this Platform, or participate in live events, we will share certain Personal Information with other users. This Personal Information includes your user profile (such as your username), your actions within the Platform and usage progress, the location of resources within the Platform in the real world with which you interact while using the Platform, and your public messages within the App. Please read the app-specific information at the end of this Privacy Policy for more details.

Data shared with third parties. We share anonymous data with third parties for industry and market analysis. If you have given us your explicit consent, we may share personal information with third party publishers for direct marketing purposes. We do not share Personal Information with other third parties for their direct marketing purposes.

Data passed on in connection with business transactions. Data that we collect from our users, including personal data, is part of our business assets. If our company is acquired by a third party as a result of a transaction such as a merger, acquisition or asset deal, or if our assets are acquired by a third party in the event of our cessation of business or insolvency, all or part of our assets, including your Personal Data, will be transferred or transferred to a third party acquirer in connection with the transaction.

  1. How your personal data is transmitted

Marble operates its services worldwide. Your Personal Information will most likely be transferred and stored in a country outside your home country, including the United States, for the purposes described in this Privacy Policy. Data protection laws in these countries may not be the same as those in your home country.

When we transfer your Personal Information from the EEA to other countries, including the United States, we ensure that your Personal Information is afforded a similar level of protection as within the EEA by ensuring that at least one of the following guarantees is implemented:

– The country to which your Personal Data is transferred is a country which, in the opinion of the European Commission, provides an adequate level of protection for Personal Data, such as the EEA.

– Where we work with service providers in the United States, they are part of the EU-U.S. Privacy Shields, under which they are required to provide the same level of protection for your Personal Information as they do within the EEA.

  1. How we secure your personal data

We have taken reasonable security measures to protect your Personal Information from accidental loss, unlawful use or access, adaptation or disclosure. We also restrict access to your personally identifiable information to employees, contractors and other third parties who need to know that information for business purposes. You will only process your Personal Data in accordance with our instructions and it will be subject to a duty of confidentiality. We have established procedures to deal with a suspected breach of Personal Data Protection and we will notify you and the appropriate regulatory authority of a breach if we are required to do so by law.

  1. How long will we store your personal data?

We will retain your Personal Information for as long as we need it to provide the Services to you and for the purposes set out in this Privacy Policy. This also applies to anyone with whom we share your data and who provides services on our behalf.

When we no longer need your Personal Information and when we no longer need to store it to comply with our legal or regulatory obligations, we will delete your information from our systems or make it anonymous so that it can no longer be associated with you. When we delete Personal Information, we will take commercially reasonable and technically feasible steps to delete that Personal Information irretrievably or irretrievably.

  1. Your rights and opportunities

You have certain rights with regard to your personal data. To exercise these rights, please contact us at

You can:

– Request information about the personal data that we have about you.

– Delete or correct your personal data. The easiest way to update your account information is through your in-app settings. You can also submit a customer support request to us at .

– You object to the processing of your personal data. Some of the personal data we store is necessary for the provision of the services and for fulfilling the promises made to you in the Terms of Use.

– Require us to cease using your Personal Information, including for marketing and promotional purposes (but remember that sometimes we need to use your Personal Information in order for you to use the Services).

– Have your Personal Information transferred to another company (where technically possible).

– Complain to a regulatory authority. We would be pleased if you would give us the opportunity to deal with your concerns directly, so we would prefer if you contact us first. However, if you are based in the EEA and believe that we have not complied with data protection laws, you can complain to your local regulatory authority.

Under certain circumstances, the laws provide for exceptions to these rights. If you are unable to exercise any of these rights because of such an exception, we will explain why.

We provide you with opportunities to collect, use and share Personal Information and will respect the choices you make. Please note that if you choose not to provide the Personal Information we request, you may not have access to all the features of the Services.

Our goal is to provide the data within 30 days or to fully respond to your request within this time.

  1. Changes to this privacy policy

Personal information that we collect is covered by the Privacy Policy that was in effect when that information was collected. We may change this Privacy Policy from time to time. We will give you reasonable notice of any material changes.

  1. Third parties

By using our services, you have access to links to websites and services owned or operated by third parties (each a “Third Party Provider”). Information that you provide in or through a third party service is provided directly to the owner or operator of the service and is subject to the Privacy Policy of the owner or operator. We are not responsible for the content, privacy, security measures and policies of any third party services. To protect your privacy, we encourage you to carefully review the privacy policies of all third parties you access.

Data shared with other users. When you perform certain actions in the Marble Prototype app, your username (or the username of your authorized child) will be publicly shared across the platform, including with other users, in connection with the arena location in the “Marble Spot”.