This Privacy Policy, together with our Terms of Service, governs your use of the online services, software, applications, content and website (collectively, the “Services”) made available to you by BigRing Virtual Technologies, Inc. (“BRVT”, “we” or “us”), a Colorado corporation. We are committed to protecting your privacy and complying with applicable data protection and privacy laws. This document is designed to help you understand what information we collect in connection with our products and services and how we work with that information.

By using our Services, or by submitting personal data to BRVT, you consent to the processing of your personal data in the manner described in this Policy. If you do not agree with this Policy, please do not use the website, application or any product of BigRing Virtual Technologies.

1. Who We Are

BigRingVR is operated by BigRing Virtual Technologies, Inc. ("BRVT"), a Colorado corporation. BRVT is the data controller responsible for your personal information. If you have any questions about this policy or how we handle your data, you can contact us at bigringvr@bigringvr.com.

2. What Data We Collect

a. Technical information. Generally, you may visit our website without identifying yourself. However, certain technical information may be collected as part of your use of our Services. This includes, but is not limited to, your IP address, the website you linked from, access times, the pages you visit, the links you use, the content you viewed, information about your devices, and other technical information your browser provides or that is otherwise collected in connection with certain products and services.

b. Your training information. We may collect or infer health-related information such as heart rate or other biometric information, including power, cadence, height and weight, and other performance indicators.

c. Information you provide. BRVT only collects personal information about you if you voluntarily choose to share it with us. When you register for our Services we ask you to create an account with your name and email address. When an account is created we do not share this information with anybody. We may ask for additional information such as your age, gender, country or province, weight, FTP (Functional Threshold Power) and language preferences, but you are not obligated to share it. You have the option to connect your account to services such as Strava, TrainingPeaks and intervals.icu to track your training and rides if you wish to do so.

d. Payment information. To process your payments we use a PCI-certified third-party payment service, Braintree (a PayPal service). When you make a payment, we collect the information needed to process it, which may include your name, address, email address and payment amount. Your card details are transmitted over an encrypted connection directly to the payment provider and processed in accordance with its own privacy policy. We do not store your full credit card numbers.

3. Public Information

If you are given the option to identify any of your information as public and you choose to do so, you are authorizing us to share that information publicly. In addition, there may be public areas of the Services — such as message boards, online forums and leaderboards — in which you are able to post information or appear. By choosing to use these areas, you understand and agree that anyone may access the information in them. By default, your ride activities are visible to other users on the leaderboard; you can set individual activities to private in your account settings or in the app.

If you choose to upload your rides (with the statistics attached to them) to Strava or any similar network, that upload is governed by the permissions on your profile with that provider and becomes subject to that provider's terms and privacy policy.

4. The Purposes for Which We Collect Your Data

BRVT collects your personal data mainly for the purposes described below:

• to fulfill your requests and make sure your order is processed correctly;
• to enforce the contract between you and BRVT;
• to ensure the functionality and security of our products and services;
• to identify you and to prevent and investigate fraud and other misuse;
• to develop better products and services, and to personalize our offering so that the service is more relevant to you; and
• to communicate with you about our products and services, or for customer-satisfaction surveys (with your consent where required).

5. Legal Bases for Processing

Where the General Data Protection Regulation (GDPR) applies, we process your personal information on the following legal bases:

• Performance of a contract — to create your account and provide the BigRingVR service you sign up for.
• Consent — for optional communications such as marketing emails, which you can withdraw at any time.
• Legal obligation — to keep financial and transaction records required by tax and accounting law.
• Legitimate interests — to secure our service, prevent fraud and abuse, and improve our products, where these interests are not overridden by your rights and freedoms.

6. Sharing Your Data

We do not sell, lease, rent or otherwise disclose your personal data to third parties for their own marketing purposes, and we do not share it for cross-context behavioral advertising. We disclose personal data only in the following circumstances:

• where you have given us your consent;
• where we are required to do so by law, such as in response to a court order or subpoena;
• where we find that you are in breach of our Terms of Service or any of our policies or usage guidelines;
• where, in our opinion, it is necessary to protect the rights, property or safety of our employees, the users of our Services, or the public;
• where, in our opinion, it is necessary to prevent, investigate, detect or prosecute criminal offenses or attacks on the technical integrity of our Services;
• where it is necessary to fulfill your product or service order;
• where we use third-party service providers who help us with vital business functions such as component development, data management, storage or payment processing — in which case we disclose only the information necessary for them to perform those services, and only where they are bound to maintain its confidentiality; and
• where our business is acquired by or merged with another entity, in which case the necessary information will be shared with the new owner of these Services.

7. Data Security

BRVT takes reasonable technical and organizational measures to protect your personal data and to minimize the risks associated with processing it. These measures include the use of encryption, firewalls, secure server facilities, and appropriate access-rights management processes. Data is encrypted in transit using industry-standard TLS (Secure Sockets Layer / Transport Layer Security). We may also take back-up copies and use other means to prevent accidental damage or destruction of your personal data. However, no website, internet transmission, computer system or wireless connection is completely secure, and we cannot guarantee the absolute security of any information you transmit to us.

8. Where Your Data Is Stored and International Transfers

Our web servers and database are hosted in the European Union. Your account, profile and activity data are stored and processed there, so for users in the EEA and UK your core personal data is not transferred outside the EEA for storage.

A small number of services operate differently:

• Payments are processed by Braintree, a PayPal service, which may process payment information in the United States. Such transfers are covered by appropriate safeguards (for example, Standard Contractual Clauses and the provider's own compliance program). We do not store full card numbers.
• Content delivery. Video and image files are delivered to your device through content delivery networks. These networks serve files to you but do not receive your account, profile or activity data.
• Third-party fitness services. If you choose to connect Strava, TrainingPeaks or intervals.icu, your activities are uploaded directly from the BigRingVR application on your own device to that service, under your own account and that service's privacy policy. We do not upload or transfer your data to those services on your behalf.

9. Cookies

A “cookie” is a small text file containing a string of characters that is sent to your device and stored when you visit a site. It is common practice to use cookies to provide useful features to users. Our cookies do not contain personally identifying information; they work by assigning your device a unique number that has no meaning outside of our organization. We use cookies to:

• remember your login status;
• provide features such as personalization and saving your member ID; and
• understand how you use our site and improve your experience.

Most web browsers automatically accept cookies, but you can change your browser settings to refuse them or to indicate when a cookie is being sent. Not accepting cookies may make certain features of our service unavailable to you.

10. Data Retention

We retain your personal information only for as long as necessary to provide our service to you. When you delete your account, we remove your profile, ride history and settings within a reasonable time (normally within 30 days of your request).

For legal and accounting reasons we retain a limited set of financial records — such as invoices, payment and transaction identifiers, amounts and dates — even after your account is deleted. We keep these to comply with tax and accounting law (typically for up to 7 years) and to resolve any billing disputes or chargebacks. These records are kept to the minimum needed for those purposes and are deleted or anonymized once they are no longer required.

You can request deletion of your account at any time on our Delete Account page.

11. Your Rights

You can access much of your information by logging into your account, where you can also rectify, restrict or delete much of it. Depending on where you live, you have some or all of the following rights over your personal information:

• Access — request a copy of the data we hold about you.
• Rectification — ask us to correct inaccurate or incomplete data.
• Erasure — request deletion of your account and data (see our Delete Account page).
• Restriction — ask us to limit how we process your data.
• Portability — receive your data in a commonly used, machine-readable format.
• Objection — object to processing based on our legitimate interests.
• Withdraw consent — where we rely on your consent, withdraw it at any time.

To request deletion, use our Delete Account page. For any other request, contact us at bigringvr@bigringvr.com; we will generally respond within a few business days. Please note that we may retain certain information as required by law or for legitimate business purposes. If you are in the EEA or UK and believe we have not handled your personal data properly, you also have the right to lodge a complaint with your local data protection supervisory authority.

12. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you the right to know what personal information we collect and how we use it, to request access to or deletion of your personal information, to correct inaccurate information, and not to be discriminated against for exercising these rights. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. To exercise your rights, use our Delete Account page or contact us at bigringvr@bigringvr.com.

13. Children's Privacy

BigRingVR is intended for adults and is not directed to children. BRVT does not knowingly collect personal information from children under 13 (or under 16 in the EEA and UK), and the Services may not be used by children under the age of 13 without a parent's express written consent. If you believe a child has provided us with personal information, please contact us at bigringvr@bigringvr.com and we will delete it.

14. Disclaimer

Please note that while we take reasonable steps to protect your information, no website, internet transmission, computer system or wireless connection is completely secure. We cannot ensure or warrant the security of any information exchanged between you and BRVT. Transmitting personal information is done at your own risk. Other sites accessible through our Services have their own policies and data-collection, use and disclosure practices; please consult each site's policies if you have any concerns. BRVT is not responsible for the policies or practices of third parties.

15. Changes to This Privacy Policy

BRVT reserves the right to modify this Privacy Policy at any time. All changes will be posted on this page in a timely manner, and where appropriate we may notify you by other means. By continuing to use the Services after changes are posted, you agree to the updated Policy.

16. Contact

Questions about this Privacy Policy? Contact us at bigringvr@bigringvr.com.

Last updated: September 2026