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Privacy Policy

Updated at 2021-09-10.

XRProj (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by XRProj. This Privacy Policy applies to Our Application, XRProj, covering all its systems and subsystems or its associated “Service”. By accessing, installing or using the mentioned Application and its respective Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure information as described in this Privacy Policy and our Terms of Service. Nevertheless, We provide you with the means to contact us regarding inquiries or any complaints of yours.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly defined as:

  • Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to FormulaXR, residing in the Technology Park of São José dos Campos, Estrada Doutor Altino Bondensan, Nº 500 Business Center 1, Room 205, ZIP 12247-016, that is responsible for your information under this Privacy Policy.
  • Country: where XRProj or the owners/founders of XRProj are based, in this case is Brazil.
  • Customer: refers to the company, organization or person that downloads, installs and uses the XRProj application and its respective Service to either: create digital content, manage advanced manufacturing training or engage in online immersive communication.
  • Device: any internet connected device such as a phone, tablet, computer or any other platform that can be used to run the XRProj Application in order to enable its Service.
  • IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
  • Personnel: refers to those individuals who are employed by XRProj or are under contract to perform a service on behalf of one of the parties.
  • Personal Data: any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
  • Application: refers to the Our system, XRProj, an executable software that can be installed on Windows Desktops, iOS IPads and Android Devices; also described as an authoring platform to create digital content, manage immersive conferences and develop Digital Twin systems.
  • Service: refers to the service provided by the XRProj Application.
  • Third-party service: refers to services, software engines or applications developed and maintained by individuals or companies - other than and not affiliated to FormulaXR - that directly affect, increment, or help to develop/deliver our Application/Service and its functionalities.
  • Engine: engine is a program that performs a core or essential function for other programs.
  • API: application programming interface - a set of definitions, commands and protocols to build and integrate application software. Website: XRProj's site, which can be accessed via this URL - www.xrproj.com
  • You: a person or entity that intends to or uses XRProj Applications and its Services.
  • User(s): a person or entity that uses the XRProj application or Service.
  • User Generated Content: a digital asset or content created by the User utilizing the XRProj Application.
  • OS: refers to the operating system of each device used to run Our Application.
  • Networking System: A network consists of two or more computers that are linked via cable or internet in order to share resources (such as printers and CDs), exchange files, or allow electronic communications.
  • AES 256 end-to-end encryption: AES-256 is a cryptography with a 256 bits length key - the largest bit size - practically unbreakable by brute force based on current computing power, making it the strongest encryption standard. End-end-encryption is a system of communication where only the communicating users have the capacity to decrypt and read the messages.

Personal Information

We only collect personal information you voluntarily provide to us and with the sole purpose to register and license the software, engage support or to send informational messages about new releases/features, fixed bugs or relevant data regarding the Service provided by Us. We do not share or sell Your personal information to third parties or use it for marketing/advertising campaigns. The information collected might be:

  • Name/Username;
  • Last name;
  • E-mail;
  • Phone;
  • City;
  • Company name.

We use appropriate security measures and only use Third Party services/technology to store and protect your registered user information and personal data from unauthorized access, disclosure, and modification. However, You must take into account that the Internet and e-mail transmissions are not 100% secure or error free communication means.

Information automatically collected

We do not develop algorithms or systems whose purpose is to capture User/Device information or to engage in advertising schemas, but the XRProj Application is built utilizing a graphics development environment known as Unity3d, developed and maintained by Unity Technologies, thus, Our Application utilizes the referred Third Party’s Engine and, most important, its embedded Analytics API that automatically collects strictly technical data or usage information - This information does not reveal your specific identity (like your name or contact information). The collected information may include:

  • Your IP address;
  • Device characteristics;
  • Operating system;
  • Language preferences;
  • Device name;
  • Country/location;
  • Information about when you use our Application and;
  • Other technical information.

The above information is primarily needed to improve the functionalities, stability and the operation of Our Service, and for our internal analytics, reporting and customer support workflow. The information may be uploaded to the Company's servers and/or to Unity Technologies server or it may be simply stored on Your device. By accessing, installing or using Our Application and its respective Service, You agree and understand that Our Application utilizes the Third Party service/platform mentioned above and that You have read and consent with their Data Privacy terms published here:

  • https://docs.unity3d.com/Manual/UnityAnalyticsDataPrivacy.html

Access and Permissions

With Your permission and prior consent to this Privacy Policy, and with the exclusive purpose to provide the Application Service and its features to its full extent, the Application may temporarily utilize or enable:

  • The Device camera to take pictures or record videos.
  • The proper Device/OS commands needed to create and access internal folders or storage systems with the sole purpose to save or retrieve User Generated Content or access digital assets that will be used by You to create digital content.

We never share, utilize or visualize User Generated Content nor any captured/stored data obtained by the above means unless otherwise authorized by You and with the sole purpose of providing technical support or any other request initiated by Your intent.

Remote Collaboration and Networking System

To enable the Application's collaborative experience and remote communication features, Your Application shares its state, streaming data (voice & video) and device/user information with other remote Application instances and its respective Users; the data/information is only exchanged between Applications utilized by Users that You authorize, via personal invitation or by sharing Your registered serial number or login account. Application state data is considered pure abstract mathematical information, with no valuable meaning unless applied to a specific digital context that, for security and intellectual property protection, is never shared by the Networking System; voice & video streaming is exchanged via AES 256 end-to-end encryption. Our Application’s Networking System relies on specialized Third Party Services that utilizes proper privacy and security measures. For more information about the Third Party Services, their technology and privacy policy please visit its respective websites:

  • Streaming data is managed by Agora (https://www.agora.io);
  • Application State and device/user information is shared and synchronized via Photon Engine (https://www.photonengine.com).

User Generated Content Exchange

The User Generated Content is only exchanged between Applications/Users previously authorized by You via personal invitation or through a shared licence account.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of XRProj or any of its Corporate Affiliates (as defined herein), or that portion of XRProj or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the Third Party agrees to adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including personal information) about You to Our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with FormulaXR, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of Brazil without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US framework. The laws of Brazil, excluding its conflicts of law rules, shall govern this Agreement and your use of the Application. Your use of the Application may also be subject to other local, state, national, or international laws. By using XRProj or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not download, install or use our Application or Services. Continued use of the Application, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

Kids' Privacy

We collect information from kids under the age of 13 just to better our services. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data without your permission, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, please delete Your account with, don't use and uninstall Our Application.

Information about General Data Protection Regulation (GDPR)

We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why this data is collected, and how we maintain this data under protection from being replicated or used in the wrong way.

What is GDPR?

GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and enhances the control the EU residents have over their personal data. The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.

What is personal data?

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity. The Data Protection Principles include requirements such as:

  • Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect. Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.
  • Personal data should be held no longer than necessary to fulfil its purpose.
  • People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR important?

GDPR adds some new requirements regarding how companies should protect individuals' personal data that they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts it's simply the right thing to do. At XRProj we strongly believe that your data privacy is very important and we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Individual Data Subject's Rights - Data Access, Portability and Deletion

We are committed to helping our customers meet the data subject rights requirements of GDPR. XRProj processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days. We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update, retrieve and remove personal data. We got you! We've been set up as self service from the start and have always given you access to your data and your customers data. Our customer support team is here for you to answer any questions you might have about working with the API.

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you. - Right to Equal Service. We will not discriminate against you if you exercise your privacy rights. - Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected. - Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. We do not sell the Personal Information of our users. For more information about these rights, please contact us.

California Online Privacy Protection Act (CalOPPA)

CalOPPA requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above. CalOPPA users have the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
  • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
  • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
  • Right to request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. We do not sell the Personal Information of our users. For more information about these rights, please contact us.

Contact Us

Don't hesitate to contact us if you have any questions.