Privacy Policy of Virtuademy
Last Updated: July 9, 2026
Version: 2.0
1. Introduction
Welcome to Virtuademy, the immersive virtual academy dedicated to schools, education, and corporate training. The platform, entirely developed by AnotheReality Srl (“we”, “us”, “our”), allows students, teachers, and professionals to interact in three-dimensional spaces (the “Metaverse”) via virtual reality headsets (such as Meta Quest), mobile devices, and desktop computers.
Considering the impact and distinct characteristics of XR (Extended Reality) technologies on user experience, this Privacy Policy has been drafted to provide maximum transparency in compliance with Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”). This document details how we collect, process, share, and protect personal data, telemetry data, and digital interactions of our users.
2. Data Controller and Contact Information
The Data Controller responsible for determining the purposes and means of processing personal data is:
- Company Name: AnotheReality Srl
- Registered Office: Via Atto Vannucci 13, 20135 Milan, Italy
- VAT Number / Fiscal Code: IT09726020960
- Dedicated Privacy Email: privacy@anothereality.io
3. Type of Personal Data Collected and Collection Methods
To operate Virtuademy as a fully simulated educational environment (capable of hosting virtual chemistry labs, historical explorations, or industrial machinery simulators), we collect various categories of data:
| Data Category | Specific Description | Source and Collection Method
|
|---|---|---|
| Account and Identification Data | First name, last name, email address, access credentials, role (e.g., Teacher, Student, Technical Expert), school or company of affiliation. | Provided directly by the user or their institution during onboarding. |
| Indirect Biometric and Telemetry Data (VR/AR Sensors) | Spatial positioning of the headset and controllers (kinematics), hand tracking, and gaze/audio directionality data (strictly processed to animate the avatar in 3D space and manage spatial audio). | Processed automatically and in real time by the hardware sensors (e.g., Meta Quest) locally and transmitted temporarily to the servers. |
| User-Generated Content (UGC) and Educational Assets | Multimedia materials, video documentaries, slides for virtual screens, drawings on shared whiteboards, 3D annotations, and custom environment configurations. | Uploaded voluntarily by the teacher, presenter, or student during sessions. |
| Audio/Video and Text Communications | Audio streams (voice) to facilitate conversation during lessons and text messaging in the session chat. | Captured by the device microphone and input methods during presence in the virtual room. |
| System and Navigation Data | IP address, device type (e.g., Standalone headset or PC-VR), connection logs, and crash reports. | Collected automatically by cloud infrastructure services. |
4. Purposes of Processing and Legal Bases
The collected data is processed lawfully, fairly, and transparently for the following purposes:
- Provision of Educational Services and Synchronization: Translating real-world movements into avatar actions, transmitting voice data to enable interactive collaboration (e.g., conducting virtual experiments or practicing machinery installations), and managing session room access.
- Maintenance, Security, and Performance Analysis: Monitoring platform stability and networking quality (lag/latency) to provide seamless experiences; preventing abuse, fraud, unauthorized access to private rooms, and safeguarding platform integrity.
- Customer Support and Training (Webinars): Managing technical support requests (e.g., tickets) from teachers or trainers and managing invitations to webinars dedicated to using the tool and creating educational material.
- Development of New Features (Research and Development): Analyzing usage metrics in a purely aggregated and statistical form to understand which virtual rooms or modules are most engaging, with the goal of improving immersive pedagogy.
5. Data Sharing and the Virtual Social Environment
The core nature of a “metaverse” platform implies a collaborative dimension. Consequently, your avatar, your movements translated into the virtual world, and the content you project are visible in real time to all users present in the same instance or virtual classroom.
For the technical architecture, we utilize external Data Processors for infrastructure services (e.g., multiplayer server hosting, cloud databases), operating on servers located within the European Economic Area (EEA) and bound by specific Data Processing Agreements (DPAs) ensuring high security standards (e.g., encryption of network streams). If any data is exceptionally transferred outside the EU/EEA, we will guarantee compliance with Chapter V of the GDPR, such as utilizing Standard Contractual Clauses (SCCs).
6. Data Retention
Data is retained strictly for the duration necessary to fulfill the purposes for which it was collected. For example:
- Profile Data: Retained for as long as the Virtuademy account (or the institution’s license) remains active.
- Telemetry and VR Position Data: Used in real time for multiplayer synchronization; it is not permanently stored or linked to the user’s real identity after the session ends.
- Documents and Assets: Maintained within the institution’s virtual space until deleted by an administrator (e.g., the teacher).
7. Data Subject Rights
Users may at any time exercise their rights under Articles 15 to 22 of the GDPR, including:
- Access and Transparency: Confirm whether personal data is being processed and obtain a copy.
- Rectification and Erasure (“Right to be Forgotten”): Request updates to or complete deletion of personal data.
- Restriction and Objection: Object to processing or request restriction of processing on legitimate grounds.
- Data Portability: Receive personal data in a structured, commonly used format to transfer it to another controller.
To exercise these rights or for any inquiries, users can contact us at privacy@anothereality.io. Users also have the right to lodge a complaint with their national Data Protection Authority (such as the Italian Garante per la Protezione dei Dati Personali).