Privacy Policy

Effective November 2022


Table of Contents


What Information this Privacy Policy Covers

What Information We May Collect

How We  May Use the Information

How We May Share Corporate Contact Information

Our Use of Cookies and Other Tracking Mechanisms

Protecting Minors Personally Identifiable Information

California Consumer Privacy Statement (CCPA) 

How to Request That We Update or Delete Your PII

Changes To This Policy



This Privacy Policy describes how Transfr, Inc. (“Transfr”) may collect, use, and share information about organizations or individuals that engage Transfr through our Products or website. 


This Privacy Policy (“Policy”) describes how Transfr, Inc. (“Transfr,” “we,” “our,” or “us”) collects, uses, and discloses information we obtain when you visit our website, (the “Site”), download or interact with any of our virtual reality simulations on Transfr owned and/or customer owned virtual reality devices, or otherwise use our services that reference this Policy (collectively, the “Services”).


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.


Please feel free to contact us at [email protected] with any comments or questions. 


What Information this Privacy Policy Covers

This Privacy Policy covers information we may collect from either access to our website or use of our Product. Some of our Product’s functionality can be used without revealing any Personally Identifiable Information. Personally Identifiable Information can include information such as your name, 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 

Information We Collect Directly from You. The information we collect from you depends on how you use our Services:


We Collect Corporate information necessary to perform our services, including client and vendor  billing and contact information.


We Collect Information When You Communicate With Us. If you communicate with us, such as when you send us an email or otherwise contact us, we collect records and copies of your correspondence, including your name, email address, mailing address, and other contact information. We also collect any information you choose to provide or communicate to us while using the Services.


Information We Collect Automatically. We automatically collect information about your use of our Site and Services through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information.


When you visit our Site or use our Services, we may collect information such as your browser type and operating system, web pages you view, links you click, your IP address, and device identifier. We may also collect information about the length of time you spent visiting our Sites and/or using our Services, the referring URL, or the web pages that led you to our Site. For more information, please see the “Our Use of Cookies and Other Tracking Mechanisms” section below.


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 business partners, service providers or other third parties or 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 May Use The Corporate Contact Information We Collect

We use your Corporate Contact information, for the following purposes:

  • Transactional Purposes. For transactional purposes, such as to provide our Services to you. 
  • Customer Service and Support. 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.  
  • Customization. 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. 
  • Advertising and Marketing. For advertising and marketing purposes, 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. 
  • Information. For our information gathering purposes, such as to administer surveys and questionnaires, such as for market research or member satisfaction purposes. 
  • Administration. For administrative purposes, including to help us better understand how our customers access and use our Sites, including the pages viewed or other activity on our Sites; to maintain security and operability of our Sites (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Policy, our Terms of Use and other policies.  
  • Analytics. 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.  
  • Business Transfers. As part of a contemplated or actual acquisition, merger or investment, sale of shares or assets, or a bankruptcy or insolvency proceeding.
  • Legal Compliance. 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. 
  • Protection of Us and Others.  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. 


How We May Share Corporate Contact Information 

We may share your Corporate Contact information, including personal information, as follows:

  • Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants. 
  • In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. 
  • To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved. 
  • Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with other entities for marketing, advertising, research, or similar purposes. 


Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).  



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. There are two types of cookies: session and persistent cookies. 

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session while accessing our Site and Services. This allows us to display content and provide our Services to you while navigating our Site.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

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:


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


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 e-mails are viewed, and track whether our emails are forwarded.


Analytics. We use automated devices and applications, such as Google Analytics, 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. To learn more about Google’s privacy practices, please review the site “How Google uses data when you use our partners’ sites or apps,” located at You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at


Do-Not-Track. Some web browsers offer a “Do-Not-Track” setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).



Our Site and Services may contain links to unaffiliated websites. 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. 


Security of Your Information

We have implemented precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. 


Access To Your Information 

You may modify your information, including personal information, that you have submitted by contacting us via the information provided in the “Contact Us” section below.


Choices Regarding Our Use of Your Information

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.


Protecting Minors Personally Identifiable Information

We are committed to protecting the privacy of children who use our Sites and Services. This section includes disclosures required under the Children’s Online Privacy Protection Act of 1998 and its implementing regulations (collectively, “COPPA”). This section notifies parents of: 

  • The types of information we may collect from children under 13.
  • How we use the information we collect.
  • Our practices for disclosing that information.

This section only applies to children under the age of 13 (a “child” or “children”) and supplements the other provisions of this privacy policy. Only the other provisions of this Policy apply to teens and adults. 


Parental Changes and Controls. At any time, parents may review their children’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us to further collect or use their child’s information. Parents can review, change, or delete their child’s personal information by sending us an email at: [email protected]. If you send us a request, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.


California Consumer Privacy Statement (CCPA)

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 (“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 the
Submitting CCPA Requests section 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 the 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 website to assist us with analyzing user activity on our Sites 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.


Changes to this Policy

This Policy is current as of the Effective 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 W. 39th Street

Suite 802/3

New York, NY 10018


Email: [email protected]