Privacy Policy
Work At Height - Safety Training
A Virtual Reality Training Application by AutoVRse
Effective Date: Oct 15, 2026
Last Updated: Oct 15, 2026
Version: 1.0
Definitions and Interpretation
"Personal Information" means any information relating to an identified or identifiable natural person. It includes information that does not name you but that can be used to distinguish you from another person, such as a persistent identifier or an IP address.
"Services" means the virtual reality training application "Work At Height - Safety Training" (the "App"), together with related software, documentation, updates, and modifications. The web-based administrative interface used by AutoVRse personnel is not accessible to Users and is referred to in this Policy as the "internal dashboard".
"AutoVRse", "we", "us", or "our" means TDW Technologies Private Limited, a company incorporated in Bengaluru, India, operating under its trademarked name "AutoVRse".
"Account" means the account you create in the App using your Meta Horizon account, through which you access the full set of training modules. Use of the App as a guest does not create an Account.
"User", "you", or "your" means any person who accesses or uses the Services.
"Processing" means any operation performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, restriction, erasure, and destruction.
"Controller" means the person who, alone or jointly with others, determines the purposes and the means of the Processing of Personal Information. Where applicable law uses a different term for the same role, including "Data Fiduciary" under the Digital Personal Data Protection Act, 2023, or "business" under the California Consumer Privacy Act, that term has the same meaning as Controller in this Policy.
"Processor" means a person who Processes Personal Information on behalf of, and on the documented instructions of, a Controller. Where applicable law uses a different term for the same role, including "Data Processor" or "service provider", that term has the same meaning as Processor in this Policy.
"Data Subject" means the individual to whom Personal Information relates. Where applicable law uses a different term, including "Data Principal" under the Digital Personal Data Protection Act, 2023, or "consumer" under United States state privacy laws, that term has the same meaning.
1. Scope and Applicability
1.1. This Policy governs the collection, storage, use, Processing, and disclosure of Personal Information by AutoVRse in connection with the Services, specifically Work At Height - Safety Training. It does not apply to any other AutoVRse application unless that application is named in this Policy.
1.2. This Policy applies to all Users.
1.3. An Account is personal to you. AutoVRse is the Controller for all Personal Information described in Section 3. If a future version of the App allows an employer or other organization to provision accounts or to receive training records about identified individuals, we will update this Policy before that version is released and will set out the allocation of Controller and Processor roles at that time.
1.4. The App is intended for use by individuals 13 years of age or older.
2. Notice, Consent and Acceptance
2.1. This Policy is the notice we give you about how we handle Personal Information in connection with the Services. Section 3 sets out what we collect and why, Section 4 sets out who receives it, Section 5 sets out how long we keep it, and Section 7.6 sets out the legal basis on which we rely for each category.
2.2. Where we rely on consent, we ask for it separately and in context, for example in-headset before the App first accesses your microphone. You may withdraw that consent at any time using the contact details in Section 10, without affecting the lawfulness of Processing carried out before withdrawal.
2.3. Where you are in a jurisdiction in which consent is the primary ground for processing personal data, including India under the Digital Personal Data Protection Act, 2023, you consent to the collection, use, storage, Processing, and transfer of your Personal Information as described in Sections 3, 4, and 8 when you first use the Services. You may withdraw that consent at any time as set out in Section 6, and we will tell you what withdrawal means for your continued use of the App.
2.4. If you do not agree with this Policy, you must stop using the Services.
3. Information We Collect and How We Use It
3.1. Categories of Personal Information
3.1.1. Guest identifier. You can use the App as a guest, without an Account. Guest access is limited to one training module. When you use the App as a guest it generates a random identifier, which remains associated with your installation of the App across sessions.
3.1.2. Account information. If you create an Account, we receive your Meta Horizon user identifier and your Meta Horizon username from Meta, and we store them. We use them to create and maintain your Account, to confirm on each launch that you are entitled to use the App, to associate your training records with your Account, and to identify you when you contact us for support.
3.1.3. Purchases and entitlement. The App is sold through the Meta Horizon Store. Meta processes your payment.
3.1.4. IP address. Our servers receive your IP address in order to respond to requests from the App, but we do not record it. Where our service providers receive your IP address in the course of providing their services, that is described in Section 4.
3.1.5. Training activity records. We record which training modules you used, whether tasks within a module were completed, the time spent in each module, error events, and session duration. If you have an Account, these records are stored against your Account and are linked to the identifiers described in 3.1.2. If you use the App as a guest, they are stored against the guest identifier described in 3.1.1 and are not linked to you. We use these records to confirm task completion, to investigate and fix errors you encounter and problems you report to us, and to improve the App and develop new features. We do not use them to make automated decisions about you that produce legal or similarly significant effects, and we do not use them for advertising or profiling.
3.1.6. Voice and microphone audio. The App accesses your microphone only after you have granted the microphone permission, and only in the following two situations.
- Multiplayer voice chat. Your audio is transmitted live to the other Users in your session through Photon Voice. We do not record or store it.
- In-experience AI trainer. Your voice and any text you enter are sent to ConvAI so that the AI trainer can understand and respond to you. ConvAI processes this data and retains it as described in Section 4.2.
You can prevent all Processing under this paragraph by declining the microphone permission or by not using voice features. The remainder of the App will continue to function.
3.1.7. Movement data. To render your avatar and to detect whether a training task has been performed, the App receives abstracted hand and body position data from your headset and controllers while you are in a session. Raw camera images of your hands, face, or eyes are processed on your device and are never shared with us. This data is used in real time only. It is not written to our servers, and it is discarded when your session ends. We do not use it to identify you, and we do not use it for advertising or profiling.
3.1.8. Cookies and similar technologies. The App does not use cookies or any similar tracking technology.
3.2. Purposes of Processing
We Process the Personal Information described in 3.1 in order to deliver the training simulation, to create and maintain your Account, to keep multiplayer sessions separate, to verify that you are entitled to use the App, to confirm task completion, to answer your support requests and troubleshoot the problems you report, to operate and secure the Services and diagnose faults, and to improve the App and develop new features. We do not Process it for advertising, for profiling, or for automated decision-making that produces legal or similarly significant effects.
4. Disclosure and Third-Party Service Providers
We engage the following third parties. Each of them receives Personal Information even where we do not retain that information ourselves.
4.1. Multiplayer and voice services: Photon
| Purpose | Real-time multiplayer functionality and live voice chat |
| Data received | Voice audio, IP address, player identifier, connection data |
| Use | Session matchmaking and live voice communication |
| Privacy policy | https://dashboard.photonengine.com/account/privacyandcookiepolicy |
4.2. AI conversational services: ConvAI
| Purpose | In-experience AI trainer: real-time speech and text understanding and response generation |
| Data received | Voice audio, text input, device and usage information, IP-derived location |
| Retention | ConvAI retains this data for as long as AutoVRse's account with ConvAI remains active. |
| Privacy policy | https://convai.com/privacy-policy |
4.3. Meta Platform Services
| Purpose | Verification that you are entitled to use the App, as required of Meta Horizon Store developers |
| Data exchanged | We receive your Meta Horizon user identifier and your Meta Horizon username from Meta, together with confirmation that you are entitled to use the App. Meta processes payment. |
| Use | Account creation and maintenance, entitlement verification, support, and association of your training records with your Account |
| Retention | Stored by us for the period set out in Section 5 |
| Privacy policy | Meta's handling of your information is governed by Meta's own privacy policy |
4.4. Hosting and infrastructure: Amazon Web Services
The Services are hosted on Amazon Web Services, with data stored in the Asia Pacific (Mumbai) region. Amazon Web Services Processes Personal Information only on our instructions under a data processing agreement and does not use it for its own purposes.
4.5. Other disclosures
We may disclose Personal Information to law enforcement or governmental bodies where we are required to do so by law, to our professional advisers under obligations of confidentiality, and to a counterparty in connection with a merger, acquisition, or sale of assets.
4.6. What we do not do
We do not sell Personal Information and we do not share it for cross-context behavioral advertising or targeted advertising. We do not use Personal Information for advertising or targeting.
5. Security and Retention
5.1. We implement encryption in transit and at rest, access controls, security assessments, and incident response procedures. Compliance with data protection law is addressed in Section 7.
5.2. We retain Personal Information for no longer than is necessary for the purposes set out in this Policy, or for such longer period as we are required to retain it by law. The periods that apply are as follows.
| Category | Retention period |
|---|---|
| Guest identifier | Retained for as long as the App remains installed and until 36 months after your last guest session, after which the associated records are deleted |
| IP address | Not retained |
| Multiplayer voice audio | Not recorded or stored by us. Transmitted live only. |
| Movement data | Not stored. Discarded at the end of the session. |
| Voice and text sent to the AI trainer | Retained by ConvAI as stated in Section 4.2 |
| Account information (Meta Horizon username and user identifier) | Until 36 months after your last session |
| Training activity records | Until 36 months after your last session |
5.3. In the event of a security incident affecting Personal Information, we will notify the relevant supervisory authorities and affected Users without undue delay and in accordance with applicable law.
6. Your Rights
6.1. Subject to 6.3, you have the right to request access to the Personal Information we hold about you, to have it corrected, to have it deleted, to object to or restrict its Processing, to receive a copy of it in a structured, commonly used, machine-readable format, and to withdraw any consent you have given. You also have the right to lodge a complaint with a supervisory authority. A list of authorities in the European Economic Area is available at edpb.europa.eu. In the United Kingdom, the authority is the Information Commissioner's Office at ico.org.uk. In India, it is the Data Protection Board of India.
6.2. To exercise any of these rights, email privacy.vrt@autovrse.in. There is no fee and you do not need to give a reason. We will acknowledge your request within 10 days and respond within 30 days. If we need longer, we will tell you why within that period.
6.3. Verifying your request. If you have an Account, we can locate your records from your Meta Horizon username or user identifier, and we will ask you to confirm one of them so that we can be satisfied the request is yours. If you have used the App only as a guest, we hold no information that identifies you and we will in most cases be unable to locate any record relating to you. Where that is the case, we will tell you so and explain why. This does not affect any rights you have in respect of the service providers named in Section 4, and on request we will tell you how to contact them. Uninstalling the App on its own does not delete your Account or the records associated with it.
6.4. Deletion. You can delete your Account at any time from inside the App, under Settings. We will fulfil a deletion request in full except where we are required to retain specific information, in which case we will delete everything else and tell you what was retained, why, and for how long. The limited cases in which we retain information are records we are required to keep under Indian tax and corporate law, and information needed to establish, exercise, or defend a legal claim. Voice and text data held by ConvAI is deleted in accordance with Section 4.2 and, on request, we will instruct ConvAI to delete data associated with your sessions.
6.5. Grievance redressal. If you are not satisfied with how we have handled your Personal Information, or with our response to a request under this Section, you may raise a grievance with our Privacy Officer, Angad Raghavan, at privacy.vrt@autovrse.in, or by post at the address in Section 10. Please describe the issue and, if it concerns a particular session, tell us the approximate date, time, and modules used, so that we can investigate. We will acknowledge your grievance within 10 days of receipt and respond substantively within 30 days.
6.6. Nomination. If you are in India, you may nominate another individual to exercise your rights under this Policy and under the Digital Personal Data Protection Act, 2023 on your behalf in the event of your death, or of incapacity that prevents you from exercising them yourself. To make, change, or revoke a nomination, email privacy.vrt@autovrse.in with the nominee's full name and contact details. We may ask you and the nominee to verify your identities before we record or act on a nomination, and we will act on a nomination only on receipt of satisfactory evidence of death or incapacity.
7. Compliance with Applicable Laws
7.1. India. The Digital Personal Data Protection Act, 2023 and the rules made under it.
7.2. European Economic Area and United Kingdom. The EU General Data Protection Regulation and the UK General Data Protection Regulation, for Users in those territories.
7.3. United States
This paragraph applies to Users resident in California, Virginia, Colorado, Connecticut, Texas, and other states with comparable privacy laws.
(a) Categories collected. In the preceding twelve months we have collected the following categories: identifiers, being the guest identifier, the Meta Horizon username, and the Meta Horizon user identifier; commercial information, being the record that you are entitled to use the App; internet and device activity, being the training activity records described in Section 3; audio, being the voice input you provide to multiplayer chat and to the in-experience AI trainer; and, where you contact us for support, your email address and the contents of your message. We collect these from you, from your device, and from Meta. We have not collected postal addresses, telephone numbers, government identifiers, financial account or payment card information, precise geolocation, biometric information, or any category that applicable law treats as sensitive personal information.
(b) Purposes and disclosures. We use these categories for the purposes set out in Section 3.2 and disclose them to the service providers named in Section 4. We do not disclose them for any other purpose.
(c) No sale or sharing. We have not sold Personal Information, and have not shared it for cross-context behavioral advertising or targeted advertising, in the preceding twelve months, and we do not do so now. We do not Process Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects.
(d) Retention. We retain each category for the period set out in Section 5.
(e) Your rights. You may request to know what we have collected about you, to access it, to correct it, to delete it, and to obtain a portable copy. Submit requests to privacy.vrt@autovrse.in.
(f) How we handle requests. We will confirm receipt within 10 business days and respond within the 30-day period set out in 6.2. We verify your request as described in 6.3. Where we cannot verify a request or locate responsive information, we will say so in our response and explain why. An authorized agent may submit a request on your behalf if you provide written permission, and we may contact you to confirm it.
(g) Appeals. If we decline a request, you may appeal by emailing privacy.vrt@autovrse.in with "Appeal" in the subject line within 30 days of our decision. We will respond within 45 days with our decision and the reasons for it. If we deny your appeal, you may contact the Attorney General of your state.
(h) Non-discrimination. We will not deny you the Services, charge you a different price, or provide you a different level of service because you exercised any of these rights.
7.4. Middle East. UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and the Saudi Personal Data Protection Law, where applicable to Users in those jurisdictions.
7.5. Other regional privacy laws as applicable to a User's location.
7.6. Legal bases
Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases.
- Account information, entitlement records, and support correspondence: necessary for the performance of your contract with us.
- Training activity records, where used to confirm task completion, to answer your support requests, and to investigate and fix problems you report: necessary for the performance of your contract with us.
- Training activity records, where used to improve the App and develop new features: our legitimate interests, to which you may object as described in Section 6.
- Guest identifier, and training activity records recorded in guest sessions: our legitimate interests in operating and securing the Services and diagnosing faults.
- Voice and microphone audio: your consent, requested in-headset before the App first uses your microphone, and withdrawable at any time.
- Movement data: our legitimate interest in rendering your avatar and detecting task completion. This data is not stored.
- Disclosures to law enforcement or governmental bodies: compliance with a legal obligation.
8. Changes to This Policy
We may update this Policy. We will communicate material changes by in-app notification.
9. Governing Law and Jurisdiction
This Policy is governed by the laws of India, and disputes arising out of it are subject to the exclusive jurisdiction of the courts of Bengaluru, Karnataka, India. Nothing in this Section limits any right you have to bring proceedings in the courts of your country of residence, or any protection available to you under the mandatory law of that country.
10. How to Contact Us
Privacy Officer
Angad Raghavan
AutoVRse (TDW Technologies Private Limited)
3rd Floor, Rear Wing, Subham Complex, 1st A Main Road, Sarakki Industrial Area, JP Nagar 3rd Phase, Bengaluru 560078, Karnataka, India
Email: privacy.vrt@autovrse.in
This Policy is available in English. If you require it in another language listed in the Eighth Schedule to the Constitution of India, please contact us at the address above.