Privacy Policy

Last updated: March 30, 2026

V111A, Inc. (“Villa,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Villa application and visit villamoves.com (collectively, the “Service”).

1. Information We Collect

1.1 We collect the following categories of information:

1.2 Account Information. When you create an account, we collect your name, email address, and profile information you provide during registration.

1.3 Movement & Gesture Data. The Service processes movement and gesture information locally on your device to power workout functionality. During normal use, this data is not transmitted to our servers. See Section 3 for details.

1.4 Usage Data (Unity Analytics). We use Unity Analytics within the application to collect anonymized data including:

• Movement performance metrics;
• Session duration and frequency;
• Feature usage patterns; and
• Crash reports and technical diagnostics.

1.5 Device & Technical Information. We collect technical details about your device, operating system, browser type, and camera access permissions.

1.6 Website Analytics (Google Analytics). We use Google Analytics on villamoves.com to collect anonymized browsing data, including:

• Pages visited and time on site;
• Referral sources;
• General geographic location; and
• Browser and device type.

Google Analytics uses cookies to collect this information. You can opt out by installing the Google Analytics Opt-out Browser Add-on.

2. How We Use Your Information

2.1 We use the information we collect for the following purposes:

• Delivering and personalizing your fitness experience;
• Generating adaptive workouts from movement analysis;
• Monitoring your progress and providing performance insights;
• Improving our products, services, and user experience;
• Communicating with you about updates, features, and support; and
• Ensuring the security and integrity of the Service.

2.2 Internal Access to Player Data. V111A, Inc. personnel may access individual player data (such as gameplay performance, session history, and movement metrics) for the purposes of customer support, debugging, and product improvement. This access is limited to authorized personnel and is subject to internal access controls.

2.3 Prohibited Uses. We will not:

• Sell, rent, or lease your personal data or gameplay data to any third party;
• Use your data to serve advertisements or for third-party marketing purposes;
• Share individually identifiable player data with advertisers or data brokers; or
• Use your data for any purpose unrelated to the operation, improvement, or support of the Service.

2.4 Audio Data. The Service operates as a passive, real-time signal processing tool that responds to audio already being rendered by your device’s operating system, without recording, storing, reproducing, or identifying the underlying content. We do not collect, store, or have access to any audio played on your device.

3. Camera & Movement Processing

3.1 General Users. For general users of the Service, all movement analysis occurs entirely on your device. We do not transmit, store, or have access to your camera feed or raw movement data on our servers.

3.2 Beta Program Exception. If you separately and explicitly consent to participate in our Beta Testing program under a separate Beta Participation and Data Release Agreement, you authorize the recording and uploading of:

• Video footage of you and your environment;
• Biometric and skeletal tracking data; and
• Gameplay renders synchronized with your input.

3.3 Distinction. Beta data collection requires a separate consent flow and a separate signed agreement. General users who have not signed the Beta Agreement are never subject to video recording, biometric data upload, or server-side storage of camera data. The statements in Section 3.1 apply fully and exclusively to non-Beta users.

4. Information Sharing

4.1 We do not sell your personal information.

4.2 We may share your information with the following categories of recipients:

• Service Providers: Third parties who assist us in operating the Service, subject to confidentiality obligations;
• Legal Compliance: When required by law, subpoena, or court order; and
• Business Transfers: In connection with a merger, acquisition, or sale of assets, in which case your information may be transferred as part of that transaction.

5. Cookies & Tracking Technologies

5.1 Our website and application use the following tracking technologies:

5.2 Google Analytics (Website). We use Google Analytics to understand how visitors interact with villamoves.com. Google Analytics collects information such as visit frequency, pages viewed, and prior site usage. It collects only the IP address assigned to you on the date you visit, rather than your name or other identifying information. You can opt out by disabling cookies or installing the Google Analytics Opt-out Add-on.

5.3 Unity Analytics (Application). Within the Villa application, we use Unity Analytics to collect anonymized performance and usage data. This helps us understand how the application performs across different devices and how users interact with features.

5.4 Essential Cookies. We use strictly necessary cookies to maintain your session and remember your preferences. These cookies are required for the Service to function and cannot be disabled.

6. Data Security

6.1 We implement industry-standard encryption protocols and security measures to protect your information.

6.2 No method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention and Destruction Schedule

This section constitutes V111A, Inc.’s publicly available data retention and destruction schedule, as required by applicable biometric privacy laws, including the Illinois Biometric Information Privacy Act (740 ILCS 14/15(a)).

7.1 General User Data. We retain account information, usage data, and preferences for as long as your account is active or as needed to provide the Service. If you request account deletion, we will delete your personal data within thirty (30) days, except where retention is required by law.

7.2 On-Device Biometric Data (General Users). Movement and skeletal tracking data processed locally on your device during normal use of the Service is not transmitted to or stored on our servers. This data exists only in your device’s temporary memory during active sessions and is not retained by V111A, Inc.

7.3 Beta Program Biometric and Video Data. If you participate in the Beta Testing program under a separate Beta Participation and Data Release Agreement, the following retention schedule applies:

• Raw video footage: Retained for a maximum of eighteen (18) months from the date of collection, or until the specific ML model version it was used to train is finalized, whichever comes first;
• Skeletal tracking and biometric data: Retained for a maximum of three (3) years from the date of collection; and
• Anonymized or aggregated data: May be retained indefinitely, provided it has been irreversibly de-identified and cannot be used to identify any individual.

7.4 Destruction of Biometric Data. V111A, Inc. will permanently destroy biometric identifiers and biometric information when the initial purpose for collecting or obtaining such data has been satisfied, or within the retention periods specified in Section 7.3, whichever occurs first. Specifically:

• Destruction will be completed within ninety (90) days of the applicable retention period expiring;
• Destruction will be performed using industry-standard secure data destruction methods (overwriting, cryptographic erasure, or physical destruction of storage media);
• V111A, Inc. will maintain an internal log of all biometric data destruction activities; and
• Destruction is not required where retention is mandated by applicable federal, state, or local law.

7.5 Early Deletion Requests. Beta participants may request early deletion of their raw biometric data and video footage at any time by contacting privacy@villamoves.com. V111A, Inc. will comply within ninety (90) days, except where the data has already been irreversibly anonymized or where retention is required by law.

7.6 Website Analytics Data. Data collected by Google Analytics is retained in accordance with Google’s data retention policies. You may opt out of Google Analytics data collection at any time by installing the Google Analytics Opt-out Browser Add-on.

7.7 Application Analytics Data. Anonymized data collected by Unity Analytics is retained for as long as necessary to fulfill the purposes described in Section 2, after which it is deleted or further anonymized.

8. Your Rights

8.1 Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate information;
• Request deletion of your personal information;
• Opt out of marketing communications;
• Request a portable copy of your data; and
• Withdraw consent where processing is based on consent.

8.2 To exercise any of these rights, please contact us at privacy@villamoves.com. We will respond to your request within thirty (30) days.

9. Age Requirements

9.1 The Service is intended for users who are at least eighteen (18) years old.

9.2 We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from someone under 18, we will take steps to delete that information as quickly as possible.

10. Changes to This Policy

10.1 We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date.

10.2 Your continued use of the Service after any changes constitutes your acceptance of the updated Privacy Policy.

11. Contact

11.1 For privacy-related inquiries, data deletion requests, or biometric data inquiries:

Email: privacy@villamoves.com

11.2 For general legal inquiries:

Email: legal@villamoves.com

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