Privacy Policy

1.    INTRODUCTION

Our goal at Kaleidoscope XR Inc. (“Kaleidoscope XR”, “we”, or “our”) is to explain how we gather and use your personal information. We want you to trust us with your information. 

This privacy policy (“Privacy Policy”) lays out what personal information we collect and why. We hope it helps you understand what we do with your data so you can feel comfortable sharing it with us.

Protecting privacy matters to us. Our clients trust us with sensitive information about their employees and students. We take that responsibility seriously.

Unlike some companies, we don't collect personal information just to sell it. We gather data so we can provide our services to our clients and users. We only use information as directed by our clients, and we never sell or rent data to third parties.

 

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2.    WHAT IS PERSONAL INFORMATION?

“Personal Information” broadly means any information about an identifiable individual. Personal information does not include business contact information, including your name, title, position, organization, telephone, email address, telephone number, or public social media account names.

 

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3.    WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to Personal Information collected (1) at websites, customer portals, and other sites we own or control (collectively, “Websites”), including https://kaleidoscopexr.ca, and (2) our extended reality software platform and other software owned and operated by us (collectively, “Software Services“), you consent to the collection and use by us of Personal Information as described in this Privacy Policy.

It also applies to our client marketing and engagement activities, such as contacting the relevant staff or clients by email, mail, or telephone.

This Privacy Policy does not apply to information we collect in the aggregate. Aggregated information does not identify you as an individual.

This Privacy Policy does not apply if you are given access to our Services or invited to use our Services by an organization (e.g., an employer, college, university, training academy, or a care organization) that uses our products or services (“Organization”). We are providing the Services to you on the organization’s behalf. Here, we are considered a processor, and your Organization’s privacy policy governs using Personal Information. Contact your Organization to find out its practices regarding your Personal Information.

Our Privacy Policy also affects no contracts between us and your Organization (or any other client or third party), nor does it affect any contract between you and your Organization.

The types of Personal Information we collect and how we use it will depend on your relationship with us.

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4.    CHANGES TO THIS PRIVACY POLICY

Sometimes, we will need to update this Privacy Policy to reflect changes to our products and services, how we operate, or meet new legal and regulatory requirements. We reserve the right to change our Privacy Policy at any time by posting a new or updated version of the Privacy Policy on the Websites. You are bound by any changes to the Privacy Policy when you use an Website or Software Service after such changes have been posted.

 

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5.    WE NEED YOUR PERMISSION TO COLLECT AND PROCESS YOUR PERSONAL INFORMATION

By providing any Personal Information to us or sharing Personal Information with others (including sensitive information) using a Software Service or Website, you expressly consent to the collection, retention, processing and use of that Personal Information by us in line with this Privacy Policy and any applicable user agreement (including an end user license agreement or service agreement) that lets us store and process Personal Information about you.

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6.    COLLECTION AND USE OF PERSONAL INFORMATION OF WEBSITE USERS

Scope of This Section

This section only applies to using Personal Information related to our Websites (e.g., kaleidoscopexr.ca). Please visit the section of the Privacy Policy under the heading Collection and Use of Personal Information of end users of an Organization for information on how we use the Personal Information of our clients’ end users.

Kaleidoscope XR has various websites for different services and geographies accessible to anyone. You can visit the Websites without logging in or identifying yourself. On some Websites, you may need to log in to benefit from the service or to use all the functionalities and be able to communicate with us, such as with our Software Services or support portals.

Information We Collect Directly From You

Some Websites, such as our Software Services portals, require you to sign up for an account. When you do, we ask you for the information we need to set up your account, such as your name and email address.

Information We Collect Indirectly From You

We collect information about the pages you visit and how you access and use the Websites using cookies or third-party analytics tools. This information includes the device(s) you use to access the Websites, including unique device identifiers, IP addresses, operating systems, browsers, and cookies. Depending on your device settings, we may also collect information about your location.

How We Use This Information

We use this information to provide and improve the Website services:

• Analytics and marketing. We analyze usage information for sales and marketing purposes and for trends about our visitors and their demographics and how they use the Websites. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and the Websites, improving the Websites, and communicating with you (including for marketing purposes). Learn more about how we use Personal Information for client engagement and marketing.

• Personalization. For some Websites, we also use your information to personalize the pages, which is necessary to provide more contextually relevant information as you browse the Websites.

• Communication. If you use Websites with logins, we use the contact details you provided to communicate with you and to let you communicate with us and other Software Services users. Typically, we use information in this way because it must provide the Software Services and because it is in our legitimate interests to ensure our services are being offered in a way that meets our standards.

We keep website usage information for as long as necessary for the purposes mentioned above. This period will vary depending on the services and websites you use and how you interact with us. Account information is kept until you delete the account and for a limited period afterward. If you provide information in forms, the information is kept only as long as required. For example, we may need to keep a record of the correspondence with you if you have made a complaint for as long as it is necessary to protect us from any legal claim. Similarly, if you unsubscribe from receiving marketing communications from us, we will keep a record to ensure you do not receive such communications again.

Who We Share This Information With

• Third-party tools. When we use third-party tools (for example, to understand how the Websites are used and to show relevant ads and campaigns on other websites), these third parties will have access to some of your Personal Information. This includes analytics tools such as Google Analytics and advertising tools such as Google Ads, LinkedIn Ads, or Meta for Business.

• Partners. We share Personal Information related to the staff of our existing or prospective clients with specific partners who may use this information for marketing. We never share any Personal Information we use on behalf of our clients unless instructed by our clients.

• Vendors. We also share information with our vendors, service providers, and other necessary third parties for legal or business purposes.

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7.    COLLECTION AND USE OF PERSONAL INFORMATION OF END USERS OF AN ORGANIZATION

Scope of This Section

Your Organization decides how your Personal Information is used. We provide most of our products and services to end-users of an Organization as a so-called 'data processor' on behalf of our clients. This means that the primary responsibility for data privacy compliance lies with your Organization as the ‘data controller.’ It also means that your Organization’s privacy policy applies to using your Personal Information (instead of ours). Your Organization determines what information we collect through our products and services and how it is used, and we process your information according to your Organization’s instructions and our contracts with your Organization.

The following section is for informational purposes and describes how your information is used when we provide products and services to you on behalf of a client. How your information is used depends on your Organization, so you should read your Organization’s Privacy Policy.

Information We Collect Directly From You & Information Your Organization Provides To Us

To access some Software Services, you may be asked to create an account, requiring you or your Organization to provide us with information, including your name, email address, and other Personal Information. Certain Software Services enable you to provide more information voluntarily. Providing information beyond what is required at registration is up to you, but providing this information may enable you to get more or easier use from the Software Services.

We may collect Personal Information about you if your Organization has contracted with us for professional services or end-user support or if you are an approved support contact under our contract with your Organization. This information may include your name, email address or other Personal Information. Information collected in connection with our provision of professional services to your Organization is collected for providing such services efficiently and effectively. Information collected through our support service is intended to help resolve issues quickly and ensure you can be notified of the progress of any issues you describe.

Information We Collect Indirectly From You

We collect information on how you use our products and services. Depending on which product or service you use, this may include these data categories:

• Location and events data. For some of our products and services, we will collect information about classes and events you have visited and attended on behalf of your Organization and the time and date of such visits. Additionally, we may collect precise geolocation data when you use the Software Services.

• Chat and audio recordings. Some of our products allow for virtual training sessions to be recorded. There is an indicator if the session is being recorded.

• Device and usage.

o   We collect computer or mobile device and usage information when you access and use the Website, including information that your browser sends when you use the Website. This data may include your unique device identifier, Internet Protocol address, browser type and configuration, the date and time of using the product or service, how long you used the Software Service and cookie data.

o   We collect device and usage information when you use Software Services, including information that the virtual reality headset, the Software Service, or the virtual reality headset device management software sends when using it. This data may include your unique device identifier, Internet Protocol address, your configuration, the date and time of your use of the Software Services, how long you used the Software Services, biometric response data and other usage information based on how you use the Software Services or virtual reality headsets. We use this information to provide the Software Services to you.

Information We Get from Others

• Vendors and integrations. We may receive information from our vendors and other third parties. For example, we may receive Personal Information from third-party services that integrate or complement our products to ensure a seamless experience. Some of our Software Services (e.g., CaregiverVR) use or integrate with ABXR Labs, Inc.’s extended reality headset management software and will exchange information with your Organization’s ABXR Labs, Inc. account.

How We Use This Information

• on Your Organization's behalf. We use your information on behalf of and under the instruction of your Organization, the data controller. We use the information under our contract with your Organization to operate, maintain, and provide the features and functionality of the products and services. Your Organization determines how your information is used.

• Product enhancement and research. Where the contract with your Organization gives us permission, we may also use:

(i)             Your Personal Information to evaluate and improve our products and services and develop new ones.

(ii)            De-identified information for other purposes, such as carrying out research and analyzing trends,

When we use information for these purposes, we will implement appropriate safeguards. This may include removing or hashing direct identifiers (e.g., your name, email address, and device ID) from the data set before conducting research and analysis.

Who Do We Share This Information With?

We share your information under our contract with your Organization. This includes sharing data within and outside of Kaleidoscope XR.

• Within Kaleidoscope XR. Your information will be accessed only by those who need to know or access your information to provide the products and services to your Organization and improve them. For example, our technical teams and client support teams may have access to your information when we set up the product for your Organization or when software or database changes are required for support and maintenance purposes.

• With your Organization. Much of the Personal Information we collect and use about you is shared with your Organization that uses our products and services and with other Organization users. What information is shared depends on your organization's product functionality, settings, and instructions. Please read your Organization’s privacy policy to learn more.

• Outside Kaleidoscope XR. We use vendors to help us provide our products and services to you on behalf of your Organization. For example, ArborXR Labs, Inc. and our hosting providers help us provide and run our products and services. Our products and services may also integrate with third-party products of your Organization and exchange Personal Information to enable a seamless and secure integration. When we use third-party tools (for example, to understand how our products and services are used), these third parties will have access to some of your Personal Information. We use Google Analytics and other analytics tools to help us measure traffic and usage trends to help us analyze and improve the performance of the Websites.

Your Organization may ask us to share this information with more parties, or it may share your information further. Please read your Organization’s privacy policy.

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8.    VENDORS & OTHER TYPES OF DISCLOSURES

This section explains how we protect your information when we engage vendors, how we share information with our partners, and in which other scenarios we may share your information with third parties.

Vendors

We use vendors to help us provide our products and services to our clients and you or to perform work on our behalf. If this requires access to Personal Information, we are responsible for the data privacy practices of the vendors. Our vendors must abide by our strict data privacy and security requirements and instructions. They may not use Personal Information they access or receive from us for any other purposes than as needed to carry out their work for us.

Other Types of Disclosures

We will also share your information where required in the circumstances below.

• Changes to our business structure. Where permitted by applicable law and by the contracts with our clients, we may disclose your information in these limited cases:

(i)             corporate transactions such as mergers, acquisitions, sale of assets, or financing;

(ii)            bankruptcy, dissolution, or reorganization, or in similar transactions or proceedings; or

(iii)           steps related to the previous bullet points (for example, due diligence)

We will always aim to continue applying our commitments in this Privacy Policy in such a case. If this is impossible, we will tell our clients, and we will not provide Personal Information about end users of our clients without the required contract of our clients to a successor entity:

• Comply with law. We may need to disclose your information to follow legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. We will always aim to limit the information we provide. If such disclosures relate to Personal Information we hold on behalf of our clients, we will defer such requests to our clients where permissible.

• Enforce our rights, prevent fraud, and ensure our safety. We may need to disclose your information to protect and defend the rights, property, or safety of us, our clients, or third parties, including enforcing contracts or policies or investigating and preventing fraud.

• De-identified information. We may disclose aggregate or de-identified information no longer associated with an identifiable individual for research or to enhance and promote our products and services. For example, we may share aggregated or de-identified information with our partners or others for business or research purposes, like partnering with a research firm or academics to explore how our products are being used and how this data can enhance our functionalities and help our clients and other institutions. We will implement appropriate safeguards before sharing information, including removing or hashing direct identifiers (e.g., your name, email address, and device ID).

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9.    CLIENT ENGAGEMENT & MARKETING

Client Engagement

• Managing the client relationship. We are collecting and storing limited Personal Information about the relevant contacts of our clients for invoicing, notification of product updates and maintenance, and similar purposes.

Marketing

• Promotion of products and services. We conduct marketing to promote our products and services. This marketing is aimed at the staff of our current and potential clients and partners. That said, we do not restrict activities and events to those audiences when such activities and events help instructors and other end users of systems, such as demonstrations or webinars that explain how our products can be used effectively.

• Events and webinars. When we conduct or sponsor events and webinars, we will collect information about attendees, such as their session and contact details, to provide them with relevant product information and other Kaleidoscope XR-related information.

• Sharing with vendors. We may use vendors to help us organize and conduct campaigns, events, and other parts of marketing. We will share with them only the necessary Personal Information and ensure they follow our strict requirements for vendors.

• Marketing preferences and opt-out. Our marketing emails will include a link so you can change your preferences and opt out of receiving marketing communications from us. You can do this by clicking the "Unsubscribe" link in the email footer.

• Online and interest-based advertising on the Websites. Sometimes, we use third-party advertising tools to collect information about your visits to the Websites to serve you targeted advertisements based on your browsing history and interests on other websites and online services or devices you may use. We only use these tools on the Websites (e.g., kaleidoscopexr.ca). When we provide our services on behalf of a client, our products and services and our Software Services do not use interest-based advertising tools unless instructed by our clients.

We may share a common account identifier related to your use of the Websites (such as an email address or user ID) with our third-party advertising partners to help identify and contact you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests and to provide advertising-related services such as reporting, attribution, analytics, and market research.

You can accept, opt-out, and set your preferences for cookies for online advertising by using the cookie options in our cookie banner on the Websites. These tools only prevent you from receiving interest-based ads on that specific browser or device. Even so, you may still receive interest-based ads on your other devices. You must perform the opt-out on each browser or device you use. Some of these opt-outs may be effective only if your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you must opt-out again.

• Google Analytics and Advertising on the Websites. We may also use certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie), third-party cookies (such as the DoubleClick advertising cookie), or other third-party cookies to inform, optimize, and display ads based on your past visits to the Websites. You can accept, opt-out and set your preferences for cookies used for online advertising by using the cookie options in the cookie banner on the Websites. For information on how Google Analytics collects and processes data and how you can control information sent to Google, review Google's site "How Google uses data when you use our partners' sites or apps." You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at google.com/ads/preferences.

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10. COOKIES

What are Cookies, and How Do They Work?

Cookies are small text files placed on your device to ensure the Websites work efficiently and seamlessly and perform certain functions. They are unique to your account or your browser. A website sends information to the browser with cookies, creating a text file. Every time you return to the same website, the browser retrieves and sends this file to the website's server. Cookies cannot access, read, or change any other data on your computer.

Cookies let website operators store your preferences and settings, authenticate and log you in, provide a personalized experience, keep websites secure, and analyze how websites and online services perform.

How We Use Cookies

We do not use cookies or similar technologies on the Websites. We will let you know if this changes.

How to Control Cookies & Opt-Out

You have several tools to control and opt out of cookies and similar technologies. On our Websites, if we ever use cookies, you will be able to accept, decline, or set your preferences for cookies used for online advertising by using the cookie options in a cookie banner.

You can also use browser controls to block and delete cookies and controls provided by some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. In some browsers, you can set your cookie preferences for each site, which means you can disable cookies but allow them for websites you trust. Doing so, however, could result in some services not functioning correctly.

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11. SECURITY

We take your privacy seriously and seek to maintain the privacy and security of the Personal Information you provide. We have a dedicated information security program and work hard to continuously enhance our technical and operational security measures. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.

Our measures consider the sensitivity of the information we collect, use, and store and the current state of technology. Our security measures include data encryption at rest and in transit, firewalls, data use, access limitations for our staff and vendors and physical access controls to our facilities.

We have a dedicated information security program and work hard to continuously enhance our technical and operational security measures. We have adopted procedures designed to limit the dissemination of your Personal Information to only designated staff as reasonably necessary to carry out the stated purposes we have communicated to you.

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12. EXTERNAL LINKS

Websites may present links to other websites. Know that operators of linked websites may also collect your Personal Information and information generated through cookies when you link to their websites. Legal Adjacency is not responsible for how those third parties collect, use, or disclose your Personal Information, so review their privacy policies before providing them with your Personal Information.

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13. LOCATION AND TRANSMISSION OF INFORMATION

Kaleidoscope XR is headquartered in Calgary, Alberta, Canada. When you provide information, that information may live on our or our service providers’ systems. You understand and agree that Personal Information collected through Software Services and Websites may be stored and processed by us or vendors in Canada, the United States, or other countries, including countries other than your country of residence; the laws of the jurisdiction in which the information is stored and processed will apply to its storage and processing. 

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14. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may keep specific data as necessary to prevent fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to this Privacy Policy.

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15. YOUR RIGHTS

In many jurisdictions, you have rights under applicable data protection laws to control how your Personal Information is used. Depending on where you live, you may have the right to request access to, rectification, or erasure of Personal Information we hold about you. You also may have the right to object to or restrict certain types of use of your Personal Information and request to receive a machine-readable copy of the Personal Information you have provided to us.

In many of our products, you can access your information and change and delete some of the information yourself by logging into your account.

 If you cannot access, correct, or delete the required information yourself, please follow these steps:

• If you are a user of our products and services we provide on behalf of your Organization, contact your Organization to exercise your rights. They need to manage your request even if it relates to information we store on behalf of your Organization. We will support your Organization with your request.

• In all other cases, please email us at ca or contact us using the contact information below to exercise these rights.

Please remember that many of these rights are not absolute. Sometimes, we (or your Organization) are not legally required to follow your request because of relevant legal exemptions.

You may also lodge a complaint with the local data protection authority in many jurisdictions. But please get in touch with us first so we can address your concern.

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16. CHALLENGING COMPLIANCE WITH THIS PRIVACY POLICY

Kaleidoscope XR will respond to individual complaints or questions about our compliance with this policy and privacy laws. We will investigate and try to resolve all complaints. If you have questions about your privacy and our role in protecting it, please get in touch with our Privacy Officer.

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17. CONTACT US

If you would like to access, correct, update, or delete any Personal Information we have about you, register a complaint, or simply want more information, don't hesitate to get in touch with our Privacy Officer at:

Kaleidoscope XR Inc.

192 Haddon Rd. SW

Calgary, Alberta, Canada

T2V 2Y6

Email: info@kaleidoscopexr.ca

 

And that’s our Privacy Policy. Thanks for reading!