Privacy Policy

1. Introduction

Fundamental XR ("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 visit our website, use our services, or use our virtual reality (VR) applications, including those distributed through the Meta Horizon Store for Meta Quest devices ("VR Apps").

Fundamental XR is the data controller for personal information collected through our website and, unless stated otherwise below, our XR Apps. Where our XR Apps are provided to you by your employer, hospital, university, or other organisation ("Organisation"), that Organisation may be the controller of some of your data, and we process it on their behalf. In that case, please also refer to your Organisation's privacy notice.

2. Information We Collect

Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Contact us through our website forms
• Subscribe to our newsletter
• Request a demo or consultation
• Participate in surveys or feedback

Automatically Collected Information

We automatically collect certain information when you visit our website, including:

• IP address and location data
• Browser type and version
• Device information
• Pages visited and time spent
• Referring website

Information Collected Through Our VR Apps

See Section 3 for full details of the information we collect when you use our VR Apps.

3. XR Apps and the Meta Horizon Store

3.1 Information we receive from Meta

When you install and use our XR Apps through the Meta Horizon Store, Meta may share limited information with us through its platform, such as:

• Your Meta app-scoped user ID and display name or username
• Confirmation that you are entitled to use the app (purchase or licence verification)

We use this information only to operate the app, verify your entitlement, and provide app features. We handle this information in accordance with Meta's platform terms and developer data use policies. We do not receive your Meta account password or payment card details; purchases are processed by Meta under Meta's own privacy policy.

3.2 Account and profile information

If you create or sign in to a Fundamental XR account within a XR App, we collect:

• Name, email address, and login credentials
• Organisation, role, specialty, or training level [if applicable]
• Account preferences and settings

3.3 Usage and performance information

When you use our XR Apps, we collect:

• Session information, such as start and end times, duration, and modules or scenarios completed
• Training and performance data, such as task completion, accuracy, timings, scores, errors, and assessment results
• In-app interactions, such as menu selections and features used

3.4 Device and technical information

• Headset model, operating system and software version, and app version
• Device identifiers generated by the app
• Frame rate, performance metrics, crash reports, and error logs
• IP address and approximate location (country or region), derived from your connection

3.5 Movement and sensor data

XR Apps rely on sensors in your headset and controllers to function. Depending on the app and the features you use, we may process:

• Head, controller, and hand position and movement (tracking data)
• Hand-tracking data, if the app supports hand tracking
• Eye-tracking data, only if you enable it on a supported device
• Voice and microphone input, if the app includes voice features
• Room-scale and environment data, such as play-area boundaries or scene data, used to place content in your space

Most of this data is processed in real time on your device to render the experience and is not stored by us. Where we do store or transmit movement or sensor data (for example, to calculate performance metrics or allow an instructor to review a session), we will tell you in the app, and we use it only for that purpose. We do not use movement, eye, face, or voice data to identify you, infer sensitive characteristics about you, or for advertising. Access to eye tracking, face tracking, microphone, and passthrough camera features is controlled through your device's permission settings, and you can turn these off at any time.

We do not access or store images from your headset's cameras.

3.6 Analytics

We use Cognitive3D to understand how our XR Apps are used and to improve them. These providers act on our behalf and may process session, usage, device, and movement data as described above.

3.7 How we use XR App information

We use this information to:

• Provide, operate, and maintain the XR Apps
• Verify your licence or purchase
• Track your training progress and generate performance reports
• Share results with your Organisation or instructor, where your access is provided through them
• Diagnose technical issues and improve performance, safety, and comfort
• Develop and improve our products and training content
• Comply with legal obligations

3.8 Sharing XR App information

In addition to the circumstances in Section 5, XR App information may be shared with:

• Your Organisation, if it provided your access, including training progress and performance results
• Meta, to the extent required to operate the app on Meta's platform (for example, entitlement checks)
• Service providers who host our data, provide analytics, or support our apps, under contracts that require them to protect your data

4. How We Use Your Information

We use the information we collect to:

• Provide and maintain our services
• Respond to your inquiries and requests
• Send you marketing communications (with your consent)
• Improve our website and services
• Analyze usage patterns and trends
• Comply with legal obligations

Legal bases for processing

Under UK and EU data protection law, we rely on the following legal bases: performance of a contract (to provide our website services and VR Apps to you or your Organisation); legitimate interests (to improve, secure, and analyse our services, where these interests are not overridden by your rights); consent (for marketing communications and optional features such as [eye tracking or voice features], which you may withdraw at any time); and legal obligation (where we must comply with the law).

5. Information Sharing

We do not sell, trade, or otherwise transfer your personal information to third parties except:

• With your explicit consent
• To trusted service providers who assist us in operating our website and VR Apps
• To your Organisation, where it provides your access to our services
• When required by law or to protect our rights
• In connection with a business transfer or merger

6. International Transfers

Some of our service providers, including Meta, may process your information outside the UK and European Economic Area. Where this happens, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses, or an adequacy decision.

7. Data Retention

We keep personal information only for as long as necessary for the purposes described in this policy. Account and training records are retained for the duration of your account or your Organisation's contract, plus 12 months, unless your Organisation requires a different period. Analytics and technical data are retained for 12 months. Real-time sensor data processed only on your device is not retained by us. When information is no longer needed, we delete or anonymise it.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction, including encryption of data in transit [and at rest] and access controls.

9. Children's Privacy

Our VR Apps are intended for users aged 18 and over / professional and educational use. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us and we will delete it.

10. Your Rights

Under applicable data protection laws, you have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your information
• Object to processing of your information
• Request data portability
• Withdraw consent at any time

Deleting your XR App data

You can request deletion of your XR App account and associated data by emailing privacy@fundamentalxr.com with the subject line "Data Deletion Request" and the email address or Meta username associated with your account. We will confirm your request and complete deletion within 30 days, except where we must keep certain information for legal reasons. Uninstalling the app from your headset does not by itself delete data we hold. If your access is provided through an Organisation, we may need to coordinate your request with them.

You also have the right to lodge a complaint with the Information Commissioner's Office (ico.org.uk) or your local data protection authority.

11. Cookies

We use cookies and similar tracking technologies to enhance your browsing experience. You can control cookie settings through your browser preferences. Our XR Apps do not use browser cookies but may use similar local storage on your device to save settings and progress.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a new "Last updated" date and, where changes are significant, notify you through our website or XR Apps.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: privacy@fundamentalxr.com
Address: Fundamental XR, 60 Grays Inn Road, London, WC1X 8LU, GB