TrainR Technologies Group B.V. – Unified Privacy Policy (Web & Apps)

Effective Date: October 27, 2025

This Privacy Policy describes the privacy practices of TrainR Technologies Group B.V., located at Stationsplein 10, 9401 LB Assen, The Netherlands (Chamber of Commerce number: 84586818) (“TrainR,” “we,” “us,” or “our”) regarding the collection, use, and protection of personal data across our websites, apps, XR fitness experiences, and other digital services (collectively, the “Service”).

By using our websites, applications, or related online services, you acknowledge and agree to the terms of this Privacy Policy.

1. Scope

This policy applies to all digital products and services operated by TrainR Technologies Group B.V., including but not limited to:
Websites such as www.trainr-group.com and / or www.verseus-games.com
Mobile and XR applications available on platforms such as Meta Quest and others
Any online or cloud-based services operated or maintained by TrainR

2. Data Collected

We collect and process information to operate and improve our Services. The types of data we may collect include:

2.1 Platform Data (e.g., Meta Quest)

When you use our applications on platforms such as Meta Quest, we may access limited platform data through official APIs, including:

• User ID  – to enable account-specific features and purchases.

• User Profile – such as display name, avatar image, and social ID, used to display identity in multiplayer or social features.

• Friends List and Invites – used to enable social play and invitations.

• In-App Purchases – used solely to validate and deliver purchased content.

Purpose:
This data is used exclusively to enable gameplay functionality, social interactions, and content delivery.

Storage:
TrainR does not permanently store your platform User ID or profile data on our servers unless required for specific account services.

Deletion:
If we store personal data, users may request deletion at any time by contacting us at support@trainr-group.com

2.2 Technical and Usage Data

We may collect non-identifiable data such as:

• Device type, operating system, region, and performance metrics.
• General activity data for analytics and service improvement.

This information is anonymized and cannot identify individual users.

2.3 Fitness and Motion Data

Aggregated, non-personal fitness data (e.g., total hours trained or activity summaries) may be collected to understand engagement and improve training effectiveness. This data is not tied to identifiable individuals.

2.4 Voice Interaction Data

When voice or AI interaction is enabled, your microphone input is processed in real time to enable speech recognition and AI responses.
We do not store voice recordings.
All processing is temporary and used solely for gameplay or AI interaction functionality.

2.5 Website Data and Cookies

Our websites may use cookies and similar tracking technologies for:

• Authentication and account access
• Performance and personalization
• Analytics and security

You can manage or disable cookies in your browser settings at any time.

3. Use of Data

We use collected data to:

• Operate, maintain, and improve the Service
• Personalize user experience
• Conduct analytics and research
• Provide customer support and respond to inquiries
• Ensure legal and technical compliance

We do not sell, rent, or trade your personal data.

4. Data Sharing

We do not share personal data with third parties except when necessary for:

• Service Providers: Hosting, analytics, or customer support providers that help us operate the Service under strict confidentiality agreements.
• Legal Requirements: When required to comply with laws, court orders, or lawful government requests.
• Business Transactions: In case of a merger or acquisition, subject to the same privacy protections.

We do not share or retain voice or biometric data.

5. Children’s Privacy

Our Services are not intended for children under 13.
We do not knowingly collect or process data from users under 13. If we discover such data, we will delete it immediately in compliance with applicable laws (including COPPA and GDPR-K).

6. Data Retention

We retain data only for as long as necessary to fulfill the purposes described in this policy or as required by law.
Once data is no longer needed, it will be securely deleted or anonymized.

7. Data Security

We take reasonable administrative, technical, and physical measures to safeguard information against unauthorized access, loss, misuse, or alteration.
However, no transmission or storage method can guarantee 100% security.

8. International Data Transfers

Data may be transferred and processed in other countries where TrainR or its partners operate.
We ensure that such transfers comply with applicable data protection regulations, including GDPR, and use appropriate safeguards such as Standard Contractual Clauses where necessary.

9. User Rights (GDPR)

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

• Request access to your data
• Request correction or deletion
• Restrict or object to data processing
• Withdraw consent where applicable

To exercise any of these rights, please contact us at support@trainr-group.com

10. Legal Basis for Processing

Our processing of personal data is based on one or more of the following legal grounds:

• Your consent
• The necessity to perform a contract with you
• Compliance with legal obligations
• Legitimate interests pursued by TrainR Technologies Group B.V.

11. Social Media and Third-Party Conten

Our websites and services may include links or embedded content (e.g., videos or posts) from third parties.
These external services are governed by their own privacy policies. We are not responsible for their data practices.

12. Updates to this Policy

We may update this Privacy Policy periodically to reflect changes in our operations or legal requirements.
The “Effective Date” at the top of this page will indicate the most recent revision.
Continued use of our Services after updates constitutes acceptance of the revised policy.

13. Contact

For any questions, data access, or deletion requests, please contact:
TrainR Technologies Group B.V.
Lauwers 9, 9105 BL Assen, The Netherlands
Email: info@trainr-group.com
Website: www.trainr-group.com