Privacy Policy

Last Updated: September 22, 2023


Table of Contents



What Information this Policy Covers

The Information We May Collect and How We Collect It

How We Use Your Information

How We Share Your Information

Choices About How We Use and Disclose Your Information

Your State Privacy Rights

Data Retention

Data Security

Children’s Online Privacy Protection Act of 1998

California Consumer Privacy Act and California Privacy Rights Act

The Family Educational Rights Privacy Act

Changes to this Policy

Contact Us





Transfr Inc. (“Transfr”,we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). 


This Policy describes the types of information we may collect from you or that you may provide when you visit this website, (the “Site”), download or interact with any of our virtual reality simulations on Transfr owned and/or customer owned virtual reality devices or our mobile application,“” (the “app”), or otherwise use our services that reference this Policy (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.


Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy.



What Information this Policy Covers


This Policy applies to information we collect:


  • On this Site.
  • In email, text, and other electronic messages between you and this Site.
  • Through use of our Services.


It does not apply to information collected by any third-parties, including through any application, content or websites that may link to or be accessible from or through the Site. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. 


Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site or Services. By accessing or using this Site and/or our Services, you agree to this Policy. This Policy may change from time to time (see “Changes To This Policy”). Your continued use of this Site and/or our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.


Some of our Services can be used without revealing any personal information. Personal information can include information such as your name, telephone number, mailing address, email address and IP address, among other things.  If Transfr is asked to collect personal information by clients we will work to limit the amount of information collected, the way it is archived, and how it is deleted whether by your request or under a managed defensible deletion initiative.



The Information We May Collect and How We Collect It


We collect several types of information from and about users of our Site and Services, including:


  • Identifiers. Information by which you may be personally identified, such as name, alias or username, postal address, email address, and IP address (“personal information“);
  • Descriptors. Information that is about you but individually does not identify you, such as geographic location; and/or
  • Internet or Network Activity. Information about your internet connection, the equipment you use to access our Site, and usage details. 
  • Commercial Data. Information pertaining to billing and payments from our clients and vendors. 


We collect this information:


  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, metadata, and information collected through cookies and other tracking technologies.
  • From third parties, for example, our customers and business partners.



Information You Provide to Us


The information we collect on or through our Site may include:

  • Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our Services, sending a message to us through the Site, requesting a demo or further services.  We may also ask you for information when you report a problem with our Site.
  • Records and copies of your correspondence (including email and mailing addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Site and of the fulfillment of your orders and/or requests. You may be required to provide financial information before placing an order through our Site.



Information We Collect Automatically


As you navigate through and interact with our Site and Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:


  • Details of your visits to our Site, including traffic data, location data, time logs, and other communication data and the resources that you access and use on the Site.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.


We currently do not collect information about your online activities over time and/or across third-party websites or other online services (behavioral tracking). 


The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:


  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Site according to user interests.
  • Speed up your login by recognizing you when you return to our Site.


The technologies we use for this automatic data collection may include:


  • Cookies (or browser cookies). Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.


  • Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.


  • Analytics. We use automated devices and applications to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve the performance of our Site and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. 



Information We Collect from Third Parties


When you use the Services, we may collect information, including personal information, about you from third-party sources, such as our customers, business partners, or other entities. Information we collect may be combined with other information we have collected about you in order to complete requests you have made or facilitate transactions you have initiated via the Services, or for other purposes, such as fraud prevention, authentication, and marketing or promotional purposes.



How We Use Your Information


We use your information that we collect about you or that you provide to us, including any personal information for the following purposes:


  • To present our Site, Services and their respective contents to you.
  • To provide you with information, products, or services that you request from us.
  • To provide you with notices about your account and/or subscription, including billing, expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Site or any Services we offer or provide through it.
  • For customer service and support purposes, such as to communicate with you about your use of our Services, changes to our services, and to respond to your inquiries.  
  • To maintain security and operability of our Sites (including for debugging purposes).
  • To administer surveys and questionnaires, such as for market research or member satisfaction purposes. 
  • For research and analytics purposes, including to better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we may evaluate which features of our Sites are most (or least) used by users.  
  • For advertising and marketing purposes, with your consent, including where permitted by applicable law, to send you email marketing, news, or newsletters about our products and services that we think may be of interest to you. You may change your preferences for receiving marketing content by contacting [email protected], or for email communications, by following the opt-out instructions contained in the email.
  • As part of a contemplated or actual acquisition, merger or investment, sale of shares or assets, or a bankruptcy or insolvency proceeding.
  • To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services. 
  • To comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings. 
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Policy. 
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.



How We Share Your Information


We may disclose aggregated information about our users, as well as de-identified or anonymized information without restriction.


We may disclose personal information that we collect or you provide as described in this Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business, including lenders, auditors, consultants or outside counsel. 
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Transfr’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Transfr about users of our Site or Services is among the assets transferred.
  • To fulfill the purpose for which you provide it. 
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.


We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Transfr, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.



Choices About How We Use and Disclose Your Information


We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Disabling Cookies. Most website browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function. For more information on how you can customize your browser’s cookie setting, please visit the link to your web browser below:


  • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g. communications regarding the updates to our Services, Terms of Use or this Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

  • Mobile Devices. We may collect location-based information if you use our app.  You may opt-out of this collection by changing the settings on your mobile device.

We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see “Your State Privacy Rights” 


Your State Privacy Rights


State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. 


To learn more about California residents’ privacy rights, see California Consumer Privacy Act & California Privacy Rights Act (CCPA & CPRA)”


Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.


To exercise any of these rights please send an email to [email protected]


Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.


Data Retention

We will only keep your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements.


Data Security


We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site ro Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Services.



Children’s Online Privacy Protection Act of 1998 (COPPA)


We are committed to protecting the privacy of children who use our Services. This section includes disclosures required under the Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA“). COPPA requires us to inform parents and legal guardians (as used in this section, “parents“) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children” or “child” as appropriate). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.


This section notifies parents of:

  • The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through the Site or Services. 


This section only applies to children under the age of 13 and supplements the other provisions of this Policy. Only the other provisions of this Policy apply to teens and adults. 


Information We Collect from Children


Children use many of the Services without providing us with personal information. However, access to some content requires us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they use the Services.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.


Information We Collect Directly


We currently do not collect any information directly from children. All personal information required for a child to use the Services is collected directly from the child’s educational institution or agencies. See, “The Family Educational Rights and Privacy Act”. 


Information We Collect From Third Parties


To enable a child to use the Services, the child’s educational institution or agency provides us with the following information: first and last name, and a username. We also require the child to create a password. We may request additional information from the child’s educational institution or agency, but this information is optional. We specify whether information is required or optional when we request it.


Automatic Information Collection


We use technology to automatically collect information from our users, including children, when they access and navigate through the Services and use certain features. The information we collect through these technologies may include:

  • Information that identifies a device’s approximate location.
  • Associated metadata from information directly shared with us.

We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Information We Collect Automatically” and “Choices Regarding Our Use Of Your Information” sections of our Policy.

How We Use Your Child’s Information


We use the personal information we collect from third parties to:

  • Register your child with the Services; and
  • Create a dashboard for your child and/or his or her school administrator to view activity, progress and performance within the Services.

We use the information we collect automatically through technology and other non-personal information we collect to improve our Service and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Monitor and improve the functionality of our Services.

We use geolocation information we collect to:  

  • Detect and prevent fraud and instances of unauthorized parties accessing our Services.
  • Identify and authenticate your child’s access to our Services.

Our Practices for Disclosing Children’s Information


Transfr does not sell or rent children’s personal information.  Any sharing or transfer of children’s personal information is done pursuant to a legitimate business purpose as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children’s personal information:

  • De-identified to third parties we use to support the internal operations of our Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.

  • If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Transfer, our customers or others, including to:

    • protect the safety of a child;
    • protect the safety and security of the Services; or
    • enable us to take precautions against liability.

  • To law enforcement agencies or for an investigation related to public safety.

If Transfr is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Transfr’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Accessing and Correcting Your Child’s Personal Information


At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

You can review, change, or delete your child’s personal information by:

  • Sending us an email at [email protected].  To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children


The following are all operators that may collect or maintain personal information from children through the Services:

Operator Name

Postal Address

Email Address

Yun Jin Rho

339 West 39th Street, Suite 802, New York, New York 10018

[email protected]

No third-party operators may collect or maintain personal information from children through the Services.


California Consumer Privacy Act and California Privacy Rights Act (CCPA & CPRA)


In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”). If you are a California resident, you may have additional rights under the CCPA, as explained in this section. This section does not address or apply to our handling of personal information that is exempt under the CCPA.

Right to Request Disclosure. You have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:

  • The categories of personal information we collect about you; 
  • What personal information we collect, use, or disclose about you; 
  • The categories of sources of the personal information we collect about you;
  • Our business or commercial purpose for collecting the personal information;
  • For each category of personal information, the categories of third parties with whom it was disclosed; and
  • The specific pieces of personal information we collect about you.

For more information on how to request information about our collection, use, and disclosure of your personal information, please see “Submitting CCPA Requests”, below.

Right to Request Deletion. You have the right to request the deletion of your personal information that we collected. For more information on how to request deletion, please see “Submitting CCPA Requests”, below. Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.

You do not need to create an account with us to exercise your deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.

Right to Opt-Out of Sales. You have the right to opt-out of “sales” of your personal information. The CCPA broadly defines “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. Although we do not disclose your personal information with third parties in exchange for monetary compensation, we may make your information available in the following circumstances, which could be deemed to be “sales” under the CCPA: we may permit online analytics providers to place a cookie, tag, or other tracking tool on our Site to assist us with analyzing user activity on our Site and Services. 

Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your CCPA rights.

Submitting CCPA Requests


Requests to Know or Delete. To exercise your rights to know or delete described above, you may use one of the following methods:


Authorized Agent. Only you, or an individual legally authorized to act on your behalf, may make a request to know, delete, or opt-out related to your personal information. You may designate someone as an authorized agent to submit requests on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify you have authorized your authorized agent to act on your behalf.


Verification. You may only submit a request to know twice within a 12-month period. Your request to know or delete must: 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or that the requestor is your authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To verify your identity, we will require you to provide appropriate identifying documentation. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you. In general, we will verify your request and your identity by matching the information you provided with the information we have in our records.

The Family Educational Rights and Privacy Act (FERPA)

The Family Educational Rights and Privacy Act (FERPA) is a United States Federal law requiring educational institutions and agencies to adhere to certain practices to protect personally identifiable information of students found in educational records and, to make this information available to parents of those students, or, for students who are 18+ or enrolled in a graduate program, directly to the students themselves.  We have prepared this Section to support our customers in the education-sector, with managing their FERPA compliance.  

Transfr only collects Directory Information from educational institutions and agencies. Directory Information is defined under FERPA as personally identifiable information maintained by the educational institution or agency and used to identify a student for administrative purposes.  Examples of Directory Information include student names, addresses, and phone numbers.  Under FERPA, these records are generally only required to be kept private by the educational institution or agency upon the parent or student’s request, as applicable. 

Transfer takes the following steps to protect personal information covered by FERPA:

(i) we require educational institutions or agencies from whom we receive student personal information, to confirm compliance with FERPA, including 34 CFR §99.37, in our Terms of Use.

(ii) we use the information only for the purposes for which it was provided to us (except in instances we are able to de-identify or anonymize student personal information)

(iii) we promptly respond to requests we receive from educational institutions or agencies with whom we are working, to delete any student personal information from our systems, and 

(iv) we abide by the same practices to safeguard student personal information that we’ve implemented to protect other forms of personal information we collect, as outlined in this Policy.

Changes to this Policy


This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. 


Contact Us


If you have questions about this Policy, the privacy aspects of our Site or Services, or would like to make a complaint, please contact us at:


Transfr Inc. 

333 West 39th Street

Suite 802

New York, NY 10018


Email: [email protected]