1. Introduction
We are MATSUKO s.r.o., a company having its registered office at Tomášiková 17, 040 01 Košice - Sever district, Slovakia, incorporated under company ID number 35 886 498 (the “Company” or “we” or “MATSUKO”) and we have developed holographic communication application named MATSUKO available on our website www.matsuko.com (“Application”).
Please read this Privacy Policy (the “Policy”) carefully before you start to use the Application. This Policy is applied when the data processing refers to data subjects in the European Union, also by the Regulation (EU) 2016/679 of the European Parliament and the Council, General Data Protection Regulation (GDPR) and is also governed by the laws of the State of California, in particular, by the California Consumer Privacy Act.
Our goal is to protect privacy, confidential information and personal data entrusted to us. We are committed to ensure appropriate security and use of personal data.
This policy gives you information about the way we treat your personal data (sometimes referred to as "personally identifiable information" or "PII") and explains how we collect, use, process, disclose and secure information and personal data obtained from users including information we collect when you visit our websites or our services. It also tells you about your rights and choices with respect to your information, and how you can contact us in case you have any questions or concerns.
2. Information about collection and use
Who is the data controller of your personal data?
The data controller is generally a person who, alone or together with others, determines the purposes and decides how personal data will be processed. MATSUKO is the data controller of personal data. In other words, we determine the purposes and means of the processing of that personal data.
How do we collect personal data?
We obtain your personal data directly from you. Mostly from filled-in forms, mutual communication or agreements. We can also obtain personal data from third parties we cooperate with, which are entitled to access and process your personal data, and from publicly accessible sources or social or other online platforms.
List of processing activities
Collection of customers for the Early Access Program.
– The purpose of the processing is to collect, analyse and store personal data about potential customer within early access program via link to a web form on the company web page www.matsuko.com. Processing of the data is within internal tools and early access program customers are categorized into groups and prioritized based on owned VR/AR/MR device, mobile phone and experience with XR.
– We are processing personal data - Early access customer information (name, company, position, e-mail, time zone), Early access customer hardware (type of phone, XR glasses, ...) - of Early access program potential customers.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data using a selection of 3rd party software tools such as online Web form tools, Analytic tools, CRM tools, Service desk tools, and in cooperation with approved External developers, Shareholders, State regulators.
Holographic presence of a user.
– The purpose of the processing is to collect, transmit and show user’s voice, video feed of front facing camera in combination with depth point cloud of a specific person via MATSUKO application.
– We are processing personal data, including the certain biometric and audio data provided by the microphone, front facing cameras and ARKit and TrueDepth, to transmit Holograms through our Application to other participants within your call. All data are encrypted in transit, never stored on our servers and are not used for marketing or advertising purposes.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data through MATSUKO front-end application, MATSUKO back-end application, hosted servers, CRM tools, Service desk tool, and in cooperation with approved External developers; Shareholders, State regulators.
Training data collected by scanning different people.
— The purpose of the processing is to collect, store and use the video footage of different people via smartphones and specific devices with pre-installed MATSUKO application. We are using these data to improve our rendering services and train neural network in the application by different types of people, their faces and moves. All data are fully anonymized or deleted after importing into the MATSUKO back-end application.
– We are processing personal data - Video footage of a person doing a sequence of head movements, faces and speaking - of Selected and specific users of MATSUKO demo application.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data through MATSUKO front-end application, MATSUKO back-end application, hosted servers, CRM tools, Service desk tools, and in cooperation with approved External developers; Shareholders, State regulators.
Collection of testimonials.
— The purpose of the processing is to collect, analyse and share user testing feedback/testimonials that are collected during product presentation at various conferences, presentation and marketing activities via 3rd party technology tools. Communication of collected testimonials to advertise is done via website, social media and printed materials.
– We are processing personal data - Visitor and user information (name, company, position, photo, video, age group), Visitor hardware used for testing (type of phone, XR glasses...) - of Visitors and users during user testing.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 3 years. We are sharing and transferring data through suitable 3rd party software tools, Social networks (Facebook, Instagram, Twitter, YouTube, and others), and in cooperation with approved website management agencies (Web developer), Marketing Agencies, Shareholders, State regulators.
Direct marketing.
— The purpose of the processing is to collect and use contact information for distribution and providing information as a part of direct marketing, e.g. newsletters, product updates, marketing newsletters within approved and specialized communication tools and platforms.
— We are processing personal data of clients and those who are interested in the service such as full name, e-mail address, phone number, address.
— Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 3 years. We are sharing and transferring data through selected CRM tools and Marketing tools and in cooperation with approved Professional consultants and advisers, Shareholders, State regulators.
All types of cookies on the webpage www.matsuko.com.
— The purpose of the processing is to transmit or facilitate the transmission of the message over the network or, if absolutely necessary for the operator as an information society service provider, to provide the information society service explicitly requested by the website user. Analytical cookies allow the operator to recognize and count the number of users and obtain information about how the website is used (e.g. which pages the user opens most often and whether the user receives error messages from some sites). This helps the operator to improve the way its website page works, for example, so that the user can easily find what he is looking for.
– We are processing personal data - Log data (your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details), Device data (device type, operating system, unique device identifiers, device settings, and geo-location data - of website visitors/users.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - consent of the person concerned with retention period adjusted for a specific cookie. We are sharing and transferring data in cooperation with professional consultants and advisers who are bound by a legal and/or contractual obligation of confidentiality; website management company; social media companies that use 3rd party cookies and entities to which the controller provides personal data by law.
What are the purposes and legal basis for processing of personal data?
We will process your personal data lawfully, fairly and in a transparent manner. We collect and process information about you only where we have a legal basis to do so/for doing so.
This legal basis depends on services you use and how you use them, meaning we collect and use your information only where:
— it's necessary for the performance of an agreement to which you are a party or to take steps at your request before entering into such an agreement (for example, when we provide you with a service you request from us);
— it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
— you give us a consent to do so for a specific purpose; or
— we need to process your data in compliance with a legal obligation.
All legal grounds are defined in the above-mentioned list of personal data collection and processing.
When you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has been already conducted).
How long do we process personal data?
We keep personal data only for a limited time. While we retain PPI, we will protect them within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
MATSUKO will keep your personal data for a predefined time period. Once this period has expired, we will delete your data by predefined procedures. All retention periods are defined in the above mentioned list of personal data collection and processing.
How do we secure processed personal data?
In an effort to maximize the security of your personal data, we are taking the appropriate technical, physical, legal and organizational measures in accordance with applicable laws on privacy and data security. MATSUKO has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction.
However, neither method of transmission over the internet nor method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. We encourage you to use precautions such as two-factor authentication, to prevent the use of publicly available networks and use security tools, like antivirus etc.
If you have any reason to believe that your communications with us are no longer secure (for instance, if you feel that the security of any personal data you have entrusted to us has been compromised), please notify us immediately via email address privacy@matusko.com.
Transfers to third parties
We will not, in any circumstances, share your personal information with other individuals or organizations without your permission, including public organizations, corporations or individuals, except when applicable by law.
We may disclose personal data to third party service providers (data processors) for the purpose of enabling them to provide their services. All transfers are defined in the above mentioned list of personal data collection and processing. We will provide you with the full list of processors upon your request.
3. What are your rights?
We make sure the processing of all personal data is done properly and safely. You can exercise the rights guaranteed to you in this section, or by the GDPR by contacting us via email address privacy@matsuko.com.
Every user is entitled to the following:
The right to access - You have the right to request MATSUKO for copies of your personal data. We may charge you for this service.
The right to rectification - You have the right to request that MATSUKO corrects any information you believe is inaccurate. You also have the right to request MATSUKO to complete information you believe is incomplete.
The right to restrict processing - You have the right to request that MATSUKO erases your personal data, under certain conditions.
The right to object to processing - You have the right to object to MATSUKO’s processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that MATSUKO transfers data that were collected to another organization, or directly to you, under certain conditions.
4. Privacy policy of other website
MATSUKO may contain links or connections to third party websites or services that are not owned or controlled by us. When you access third party websites or use third party services, you accept that there are risks in doing so, and that we are not responsible for such risks. We encourage you to be aware in case you click on other links and we encourage you to read the terms and conditions and privacy policy of each third party website or service that you visit, or utilize. We have no control over, and assume no responsibility for the content, accuracy, privacy policies, or practices, or opinions expressed in any third party websites or by any third party.
5. Changes to our privacy policy
At our discretion, we may change our Policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this Policy will be regarded as acceptance of our practices around privacy and personal data.
If we make a significant change to this Policy, for example changing a lawful base upon which we process your personal data, we will ask you to re-consent to the amended Policy.
This privacy policy was last updated on 05th May 2022.
6. Policy questions and enforcement
In case of any questions or when exercising your rights under relevant data protection legislation please contact us via email address privacy@matusko.com or standard post service within our address: Tomášiková 17, 040 01 Košice - Sever district, Slovakia.
In any event, you always have the right to lodge a complaint with the Slovak regulator in charge of protecting personal information: https://dataprotection.gov.sk/uoou/ or via address:
Úrad na ochranu osobných údajov SR
Hraničná 12,
820 07 Bratislava
Slovak republic
We are MATSUKO s.r.o., a company having its registered office at Tomášiková 17, 040 01 Košice - Sever district, Slovakia, incorporated under company ID number 35 886 498 (the “Company” or “we” or “MATSUKO”) and we have developed holographic communication application named MATSUKO available on our website www.matsuko.com (“Application”).
Please read this Privacy Policy (the “Policy”) carefully before you start to use the Application. This Policy is applied when the data processing refers to data subjects in the European Union, also by the Regulation (EU) 2016/679 of the European Parliament and the Council, General Data Protection Regulation (GDPR) and is also governed by the laws of the State of California, in particular, by the California Consumer Privacy Act.
Our goal is to protect privacy, confidential information and personal data entrusted to us. We are committed to ensure appropriate security and use of personal data.
This policy gives you information about the way we treat your personal data (sometimes referred to as "personally identifiable information" or "PII") and explains how we collect, use, process, disclose and secure information and personal data obtained from users including information we collect when you visit our websites or our services. It also tells you about your rights and choices with respect to your information, and how you can contact us in case you have any questions or concerns.
2. Information about collection and use
Who is the data controller of your personal data?
The data controller is generally a person who, alone or together with others, determines the purposes and decides how personal data will be processed. MATSUKO is the data controller of personal data. In other words, we determine the purposes and means of the processing of that personal data.
How do we collect personal data?
We obtain your personal data directly from you. Mostly from filled-in forms, mutual communication or agreements. We can also obtain personal data from third parties we cooperate with, which are entitled to access and process your personal data, and from publicly accessible sources or social or other online platforms.
List of processing activities
Collection of customers for the Early Access Program.
– The purpose of the processing is to collect, analyse and store personal data about potential customer within early access program via link to a web form on the company web page www.matsuko.com. Processing of the data is within internal tools and early access program customers are categorized into groups and prioritized based on owned VR/AR/MR device, mobile phone and experience with XR.
– We are processing personal data - Early access customer information (name, company, position, e-mail, time zone), Early access customer hardware (type of phone, XR glasses, ...) - of Early access program potential customers.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data using a selection of 3rd party software tools such as online Web form tools, Analytic tools, CRM tools, Service desk tools, and in cooperation with approved External developers, Shareholders, State regulators.
Holographic presence of a user.
– The purpose of the processing is to collect, transmit and show user’s voice, video feed of front facing camera in combination with depth point cloud of a specific person via MATSUKO application.
– We are processing personal data, including the certain biometric and audio data provided by the microphone, front facing cameras and ARKit and TrueDepth, to transmit Holograms through our Application to other participants within your call. All data are encrypted in transit, never stored on our servers and are not used for marketing or advertising purposes.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data through MATSUKO front-end application, MATSUKO back-end application, hosted servers, CRM tools, Service desk tool, and in cooperation with approved External developers; Shareholders, State regulators.
Training data collected by scanning different people.
— The purpose of the processing is to collect, store and use the video footage of different people via smartphones and specific devices with pre-installed MATSUKO application. We are using these data to improve our rendering services and train neural network in the application by different types of people, their faces and moves. All data are fully anonymized or deleted after importing into the MATSUKO back-end application.
– We are processing personal data - Video footage of a person doing a sequence of head movements, faces and speaking - of Selected and specific users of MATSUKO demo application.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 1 year. We are sharing and transferring data through MATSUKO front-end application, MATSUKO back-end application, hosted servers, CRM tools, Service desk tools, and in cooperation with approved External developers; Shareholders, State regulators.
Collection of testimonials.
— The purpose of the processing is to collect, analyse and share user testing feedback/testimonials that are collected during product presentation at various conferences, presentation and marketing activities via 3rd party technology tools. Communication of collected testimonials to advertise is done via website, social media and printed materials.
– We are processing personal data - Visitor and user information (name, company, position, photo, video, age group), Visitor hardware used for testing (type of phone, XR glasses...) - of Visitors and users during user testing.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 3 years. We are sharing and transferring data through suitable 3rd party software tools, Social networks (Facebook, Instagram, Twitter, YouTube, and others), and in cooperation with approved website management agencies (Web developer), Marketing Agencies, Shareholders, State regulators.
Direct marketing.
— The purpose of the processing is to collect and use contact information for distribution and providing information as a part of direct marketing, e.g. newsletters, product updates, marketing newsletters within approved and specialized communication tools and platforms.
— We are processing personal data of clients and those who are interested in the service such as full name, e-mail address, phone number, address.
— Processing is based on Art. 6 par. 1 letter a) of GDPR - Consent of the person concerned with retention period 3 years. We are sharing and transferring data through selected CRM tools and Marketing tools and in cooperation with approved Professional consultants and advisers, Shareholders, State regulators.
All types of cookies on the webpage www.matsuko.com.
— The purpose of the processing is to transmit or facilitate the transmission of the message over the network or, if absolutely necessary for the operator as an information society service provider, to provide the information society service explicitly requested by the website user. Analytical cookies allow the operator to recognize and count the number of users and obtain information about how the website is used (e.g. which pages the user opens most often and whether the user receives error messages from some sites). This helps the operator to improve the way its website page works, for example, so that the user can easily find what he is looking for.
– We are processing personal data - Log data (your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details), Device data (device type, operating system, unique device identifiers, device settings, and geo-location data - of website visitors/users.
– Processing is based on Art. 6 par. 1 letter a) of GDPR - consent of the person concerned with retention period adjusted for a specific cookie. We are sharing and transferring data in cooperation with professional consultants and advisers who are bound by a legal and/or contractual obligation of confidentiality; website management company; social media companies that use 3rd party cookies and entities to which the controller provides personal data by law.
What are the purposes and legal basis for processing of personal data?
We will process your personal data lawfully, fairly and in a transparent manner. We collect and process information about you only where we have a legal basis to do so/for doing so.
This legal basis depends on services you use and how you use them, meaning we collect and use your information only where:
— it's necessary for the performance of an agreement to which you are a party or to take steps at your request before entering into such an agreement (for example, when we provide you with a service you request from us);
— it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
— you give us a consent to do so for a specific purpose; or
— we need to process your data in compliance with a legal obligation.
All legal grounds are defined in the above-mentioned list of personal data collection and processing.
When you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has been already conducted).
How long do we process personal data?
We keep personal data only for a limited time. While we retain PPI, we will protect them within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
MATSUKO will keep your personal data for a predefined time period. Once this period has expired, we will delete your data by predefined procedures. All retention periods are defined in the above mentioned list of personal data collection and processing.
How do we secure processed personal data?
In an effort to maximize the security of your personal data, we are taking the appropriate technical, physical, legal and organizational measures in accordance with applicable laws on privacy and data security. MATSUKO has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction.
However, neither method of transmission over the internet nor method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. We encourage you to use precautions such as two-factor authentication, to prevent the use of publicly available networks and use security tools, like antivirus etc.
If you have any reason to believe that your communications with us are no longer secure (for instance, if you feel that the security of any personal data you have entrusted to us has been compromised), please notify us immediately via email address privacy@matusko.com.
Transfers to third parties
We will not, in any circumstances, share your personal information with other individuals or organizations without your permission, including public organizations, corporations or individuals, except when applicable by law.
We may disclose personal data to third party service providers (data processors) for the purpose of enabling them to provide their services. All transfers are defined in the above mentioned list of personal data collection and processing. We will provide you with the full list of processors upon your request.
3. What are your rights?
We make sure the processing of all personal data is done properly and safely. You can exercise the rights guaranteed to you in this section, or by the GDPR by contacting us via email address privacy@matsuko.com.
Every user is entitled to the following:
The right to access - You have the right to request MATSUKO for copies of your personal data. We may charge you for this service.
The right to rectification - You have the right to request that MATSUKO corrects any information you believe is inaccurate. You also have the right to request MATSUKO to complete information you believe is incomplete.
The right to restrict processing - You have the right to request that MATSUKO erases your personal data, under certain conditions.
The right to object to processing - You have the right to object to MATSUKO’s processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that MATSUKO transfers data that were collected to another organization, or directly to you, under certain conditions.
4. Privacy policy of other website
MATSUKO may contain links or connections to third party websites or services that are not owned or controlled by us. When you access third party websites or use third party services, you accept that there are risks in doing so, and that we are not responsible for such risks. We encourage you to be aware in case you click on other links and we encourage you to read the terms and conditions and privacy policy of each third party website or service that you visit, or utilize. We have no control over, and assume no responsibility for the content, accuracy, privacy policies, or practices, or opinions expressed in any third party websites or by any third party.
5. Changes to our privacy policy
At our discretion, we may change our Policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this Policy will be regarded as acceptance of our practices around privacy and personal data.
If we make a significant change to this Policy, for example changing a lawful base upon which we process your personal data, we will ask you to re-consent to the amended Policy.
This privacy policy was last updated on 05th May 2022.
6. Policy questions and enforcement
In case of any questions or when exercising your rights under relevant data protection legislation please contact us via email address privacy@matusko.com or standard post service within our address: Tomášiková 17, 040 01 Košice - Sever district, Slovakia.
In any event, you always have the right to lodge a complaint with the Slovak regulator in charge of protecting personal information: https://dataprotection.gov.sk/uoou/ or via address:
Úrad na ochranu osobných údajov SR
Hraničná 12,
820 07 Bratislava
Slovak republic
