Effective date: September 2022
Edumersive (“us”, “we”, or “our”) operates the https://www.edumersive.nl website and our smartphone / VR headset application; Edumersive app (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
The service is the https://www.edumersive.nl website, Oculus VR, Pico VR, Google Playstore and iOS App store application operated by Edumersive
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit or a given answer on an interactive element in the application).
Cookies are small files stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Edumersive is a trademark of Cross-Reality-Expert, a company based in the Netherlands.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you on our website and apps. The Edumersive application collects user interaction data for your organisation, viewable by a designated persons within your organisation.
Types of Data Collected
Personal Data – website
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Cookies and Usage DataWe may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
Usage Data – website
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data – website
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Personal Data – application
While using our application, we may ask you to provide us with certain personally identifiable information like login details, that can be used to identify your account within the application. Login details may include, but is not limited to:
- Email address
- First name and last name
- Usage Data and interaction data
- The Service uses a hash algorithm to store the data safely. The personal data is encrypted and not visible to Edumersive or your organisation directly. User interaction data is visible to the user and designated persons within your organisation. To opt out, you must contact the designated person within your organisation.
Usage Data – application
We may also collect information on how the application is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), the experiences you start within the application, interaction therein and other diagnostic data.
Smartphone permissions – application
We use a couple of smartphone permission for the following goals:
File storage – Scenarios and their files are downloaded and checked on your device. Files are being checked and downloaded often with a visual notification to keep the app working properly.
Microphone – The microphone is used in the group training lobby for VOIP. Edumersive doesn’t save any audio locally or online.
Camera and photos – By default this will not be requested but It will be requested and used when the take pictures for user validation is enabled in an exam scenario. The designated persons of your organisations are able to create scenarios with the exam mode and photo option toggled on. If a user starts a scenario with those options turned on, a dialog will show up with the note that pictures will be taken during the scenario. The user can voluntarily decline but won’t be able to access that scenario if declined or denied the camera permissions.
WiFi state – WiFi is being used to check for a LAN / internet connection to connect to group sessions and download files.
Use of Data
Edumersive uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To provide analytics data for your own organisation
- To provide a personal account for the user
- To detect, prevent and address technical issues
- To provide the designated persons in your organisation with user photos of a exam scenario. This is user in order for them too see if the owner of the account is also undertaking the training (user validation).
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Edumersive may process your Personal Data because:
- We need to perform a contract with your organisation
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
Edumersive will also retain Usage Data for internal analysis purposes or if we are legally obligated to retain this data for longer periods.
As a user you can view the saved pictured and given answers during a scenario in the Analytics segment of the Service. By sending a email to email@example.com with the request to delete the user data. We will take steps to delete the data if you provide us with the correct user details.
Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. For example we use Microsoft data storage services and their servers are located around the world.
If you are located outside Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to Netherlands and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances Edumersive may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Edumersive may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Edumersive
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that 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 Data, we cannot guarantee its absolute security. We employ HTTPS, Hash algorithms and block malicious database injections to secure data. We cannot fully guarantee the security of the application itself, hosted on external sources like the Google Play store.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA) We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR) If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Edumersive aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org and ask for our Security Officer Mr. Timmers.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data through your organisation. If this somehow isn’t possible, please contact us.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. Contact us for this information. We will respond within a few work days with the information.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Edumersive relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. And it will take some time to reply and execute those requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Third parties also include our partners and resellers.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect or target personally identifiable information from anyone under the age of
18 If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.