PREAMBLE | COMPLIANCE
The protection of personal data and respect for the privacy of our customers and users are of great importance to us.
This privacy policy (the “Policy”) is intended to inform our customers, as well as the end users (“you”) of the VIRTUAL HALL® application (the “Application”), in accordance with the Swiss Federal Act on Data Protection (“FADP”) and, where applicable for relevant users, the European Union’s General Data Protection Regulation (“GDPR”).
It details the personal data that may be processed in connection with the use of the Application, why they are processed, how we use or access them, and your rights regarding them.
Important note on data collection: In line with our technical team’s guidance, Virtual Hall® is designed to minimize the direct collection of personally identifiable data. We only collect and directly process the data strictly necessary for the technical operation of the Application and for the optional services explicitly described below (such as the newsletter if you subscribe to it separately). User account management, purchases, and basic statistics related to your account on the platform are managed by Meta Platforms Ireland Limited (or the applicable platform provider), in accordance with their own privacy policy.
Where consent is referred to as the legal basis for processing, this means that we request your explicit agreement before collecting or processing the data concerned (for example, via a checkbox when subscribing to the newsletter on our website, or a setting in the Application for an optional feature). If you do not give your consent, or if you withdraw it later, the data concerned will not be processed (or will no longer be).
Where performance of the contract is referred to as the legal basis, this means that the processing is indispensable to provide the service you requested (use the VIRTUAL HALL® Application) and that the processing is based on the contract binding us, such as the Terms of Use of the VIRTUAL HALL® Application.
Where legitimate interest is referred to as the legal basis, this means that we process data to ensure technical operation, the security of our services, or to analyze usage in a global and anonymized manner to improve our services, while ensuring that such processing respects your rights and freedoms. You may object to some of these processing activities (see Section 6).
Below you will find more information on:
Who we are and how to contact us (including our representative in the EU) (Section 1).
The products and services concerned (Section 2).
The categories of personal data processed, their sources, purposes and legal bases (Section 3).
The recipients of your data (platform, processors) (Section 4).
The retention period (Section 5).
Your rights (access, rectification, erasure, objection, etc.) and how to exercise them (Section 6).
Changes to this Policy (Section 7).
Data security (Section 8).
The validity of the Policy (Section 9).
- CONTACT
1.1. Data Controller (Switzerland)
The parties responsible for this Policy and for any processing of personal data in relation to our products and services are jointly:
Initiative/registered trademark: Fondation de l’Orchestre de la Suisse Romande à Genève (FOSR)
Designer and operating licensee: CYBEL’ART SA / IDE: CHE-110.130.923
Address: Grand’Rue 29, 1110 Morges (VD), Switzerland
Technology: Powered by Real Illusions XR Engine
We can be contacted at the following details:
By phone: +41(21) 802 50 86 or +41(22) 807 00 00
By email: contact@virtual-hall.com or desk@cybelart.dev
1.2. Representative in the European Union (in accordance with Art. 27 GDPR)
For users located in the European Union, our designated representative for data protection matters is:
Name: Philippe Font at Real Illusions (France)
Email: desk@cybelart.dev | rgpd@realilusions.io
You may contact our representative for any questions regarding the processing of your personal data under the GDPR.
- SCOPE
This Policy applies to the following products and services:
2.1. The VIRTUAL HALL® Application
The VIRTUAL HALL® Application is an immersive application available on the Meta Horizon Store (Meta Quest) and potentially other future platforms.
2.2. Email and newsletter services (Optional)
Communication relating to products and services, informational newsletters and promotional offers (including those from partners), only subject to your voluntary registration and explicit consent via our website or another means separate from the Application
- CATEGORIES AND PURPOSES OF DATA PROCESSED
3.1. Data we do NOT process directly
We wish to highlight the categories of data that we do NOT collect or do NOT process directly via the Application:
3.1.1. Virtual Hall®-specific user account data: We do not create or manage separate user accounts for the Application.
Access and identification are handled via your Meta account (or other applicable platform). We therefore do not directly collect your name or your email address via the Application for account management purposes.
3.1.2. Payment data: Transactions related to the purchase of the Application or additional content are processed directly by Meta (or the relevant distribution platform) via your account on that platform. We do not have access to your payment information.
3.1.3. Categories of sensitive (“special”) data: We do not actively process sensitive data (ethnic origin, political opinions, religious beliefs, health, sexual orientation, genetic/biometric data for the purpose of uniquely identifying a person, criminal convictions). If you voluntarily and unsolicitedly communicate such data to us (for example, via a revealing email address in the context of a support request), they would only be processed strictly to respond to your request.
3.1.4. Audio data (voice input): We do NOT collect voice data via your headset or device’s microphone as of today.
3.1.5. Social data (multiplayer interactions): The Application currently does not include multiplayer features. We therefore do NOT collect data related to direct interactions between users within the Application (e.g., friends list, chat history).
3.1.6. Content of media files viewed: The Application allows access to video, audio and image files. These files may be temporarily stored (cached) on your device to optimize performance and reduce bandwidth usage. We do not collect, analyze, or share the content of these files.
3.2. Categories of personal data processed, purposes, legal bases and sources
The personal data we may process are limited to the following categories:
3.2.1. Technical and connection information collected when using the VIRTUAL HALL® Application
Data category
Purpose(s) of processing
Legal basis (FADP / GDPR)
Source / Collection mechanism
Technical information (OS, SDK version, headset type, App version)
Ensure compatibility, optimize performance, diagnose technical issues, maintenance. Data not directly linked to your identity.
Legitimate interest (ensuring proper operation)
Automatically transmitted by your device or the platform (Meta SDK) during use.
IP address
Ensure the operation and security of the service (connection to content servers, abuse detection), error diagnostics. Deletion after max. 30 days.
Legitimate interest (security, functionality)
Automatically transmitted when connecting to content servers (e.g., Vimeo).
Aggregated and anonymized usage data
Overall and anonymized statistical analysis of the use of features (e.g., general popularity of content) to improve ergonomics and content. These data do not allow you to be identified.
Legitimate interest (service improvement)
Potentially via analytics tools provided by the platform (Meta) or anonymized third-party tools (e.g., Google Analytics, if used).
3.2.2. Virtual Reality (VR) interaction data processed in real time
Data category
Purpose(s) of processing
Legal basis (FADP / GDPR)
Source / Collection mechanism / Storage
Data necessary for basic operation
(processed locally/in real time)
Controller inputs (buttons, joysticks, triggers)
Interpret your commands to enable navigation, selection, movement, and basic interaction. Indispensable to use the Application.
Performance of the contract
Processed in real time by the Application and the platform SDK via the controllers. Not stored by Virtual Hall.
Headset and controller position and orientation
Track your movements to display the first-person view and the position of virtual hands, enabling interaction and immersion. Indispensable for the VR experience.
Performance of the contract
Processed in real time by the Application and the platform SDK via the sensors. Not stored by Virtual Hall.
Data subject to consent
(optional feature)
Hand tracking data (Hand Tracking)
Optional feature, disabled by default. If enabled by you, collects hand position/gesture data for more natural interaction. Improves immersion but is not indispensable for basic operation.
Consent
Collected and processed in real time via the headset sensors only if the feature is enabled by you in settings. Can be disabled at any time. Not stored by Virtual Hall.
3.2.3. Information collected via email and newsletter services (if voluntarily subscribed)
Data category
Purpose(s) of processing
Legal basis (FADP / GDPR)
Source / Collection mechanism / Consent
Email address
Only for Newsletters / Promotional offers: Sending news, information about new content, special offers (including from partners), if you have explicitly consented.
Consent
Address voluntarily provided by you via a dedicated signup form (e.g., on www.virtual-hall.com) with a checkbox. You can withdraw your consent at any time via the unsubscribe link in each email or by contacting us.
- DATA RECIPIENTS (PLATFORM, PROCESSORS)
We do not sell or rent your personal data. We share your personally identifiable data with third parties only in limited and controlled cases:
4.1. Distribution Platform (Meta)
The use of the Application via the Meta Horizon Store implies that Meta Platforms Ireland Limited processes certain of your data as the platform provider (management of your Meta account, payments, provision of the runtime environment, potentially collection of usage statistics). Such processing is subject to Meta’s privacy policy, which we invite you to consult.
4.2. Transmission to external service providers (processors)
We use service providers for specific technical operations. We only transmit to them the data strictly necessary for their task and require them, by contract (data processing addendum), to keep your data confidential, to use it only on our behalf and according to our instructions, in accordance with the FADP and the GDPR (Art. 28).
We prioritize providers based in Switzerland or in the European Economic Area (EEA). If a data transfer outside these areas is necessary (for example, to the United States for video hosting), it will only take place if appropriate safeguards are in place (for example, Standard Contractual Clauses approved by the European Commission and validated by the FDPIC, relevant adequacy decision).
4.3. List of main providers and purposes
Category of provider
Name of provider
Main purpose
Main processing location
Hosting and delivery of video/audio content
Cybel’Art at Vimeo Inc.
Secure storage and delivery of video and audio content accessible via the Application.
USA (subject to appropriate safeguards – Standard Contractual Clauses)
Distribution platform & related services
Meta Platforms Ireland Limited
Provision of the platform (Meta Horizon Store), management of linked accounts, payment processing, possible provision of aggregated statistics.
Ireland (EEA) / USA (subject to appropriate safeguards)
Audience analysis (anonymized)
Google LLC (Google Analytics) (if used)
Aggregated and anonymized audience measurement for service improvement.
USA (subject to appropriate safeguards)
Email sending service
Cybel’Art Brevo account (if newsletter service maintained)
Management and sending of newsletters (if voluntarily subscribed).
EEA or USA (subject to appropriate safeguards)
XR Engine Infrastructure
Real Illusions (OVH servers)
Provision of the underlying technology and technical support.
France (EEA)
Accounting (Internal)
CYBEL’ART SA (via Swiss chartered accountant)
Internal processing for the financial management of CYBEL’ART SA (does not directly concern the end users’ data of the Application).
Switzerland
4.4. Legal obligations
We may be required to disclose your data if required by law (for example, to a judicial or administrative authority) or if we believe in good faith that this is necessary to comply with legal proceedings, respond to claims, or protect our rights, property, or safety, as well as those of our users or the public.
- RETENTION PERIOD
5.1. General principle
We retain the personal data that we process directly only for as long as necessary to achieve the purposes for which they were collected, including to meet any legal or reporting requirements applicable to those specific data.
5.2. Specific durations
Account data: We do not retain separate user account data. Account management is handled via your Meta account (or other applicable platform) according to their retention policy.
Technical logs: Technical logs (e.g., IP address for security when connecting to content servers) are retained for a limited period not exceeding 30 days, unless a legal requirement or compelling security need justifies longer retention.
Interaction data: Real-time interaction data (movements, commands, hand tracking if enabled) are not stored by Virtual Hall®.
Analytics data: Aggregated and anonymized usage data are retained as long as they are useful for improving the service, but without allowing personal identification.
Newsletter-related data (if applicable): Your email address is retained until you withdraw your consent. This retention applies only if you have voluntarily subscribed to our newsletter separately from using the Application.
- YOUR RIGHTS REGARDING YOUR PERSONAL DATA
In accordance with the FADP and the GDPR (for the users concerned), you have the following rights regarding the personal data that we may hold about you:
6.1. Right of access: Obtain confirmation that data concerning you are processed by us, access them and obtain a copy.
6.2. Right to rectification: Have inaccurate or incomplete personal data we hold corrected (mainly the newsletter email address if you are subscribed).
6.3. Right to erasure (“Right to be forgotten”): Request the deletion of your personal data that we hold, in the cases provided by law.
Data concerned: The personal data we may hold about you (for example, your email address if you are subscribed to the newsletter, or temporary technical logs linked to your IP address before their automatic deletion).
Limitations: This right is not absolute. We may retain certain data if necessary to comply with a legal obligation or to establish, exercise, or defend legal claims. Data processed by Meta are subject to their policy.
6.4. Right to restriction of processing: Request the “freeze” of the use of your data that we hold, in certain situations (contesting accuracy, unlawful processing, etc.).
6.5. Right to object:
Object, on legitimate grounds related to your particular situation, to the processing of your data based on our legitimate interest (e.g., use of the IP address for security).
Object at any time to the processing of your data for direct marketing purposes (mainly concerns the newsletter).
6.6. Right to data portability: Receive the personal data you have provided to us and that we hold (mainly your email address if you are subscribed to the newsletter and the processing is automated) in a structured, commonly used, and machine-readable format, and transmit them to another controller, where the processing is based on consent and carried out by automated means.
6.7. Right to withdraw your consent: Where processing is based on your consent (e.g., newsletter, hand tracking), you may withdraw it at any time, without affecting the lawfulness of prior processing. The withdrawal is carried out via the mechanisms provided (unsubscribe link, setting in the Application for hand tracking) or by contacting us.
6.8. Right to lodge a complaint: If you believe that the processing of your personal data constitutes a violation of the applicable legislation, you have the right1 to lodge a complaint with the competent supervisory authority:
Switzerland: Federal Data Protection and Information Commissioner (FDPIC).
EU: Data protection authority of your country of habitual residence, place of work, or place of the alleged violation.
6.9. Exercising your rights: To exercise your rights listed above, please contact us by email at contact@virtual-hall.com or, for EU residents, also contact our representative at desk@cybelart.dev. We may ask you to prove your identity to ensure the security of your data and will process your request within the legal time limits (generally 30 days).
- CHANGES TO THIS PRIVACY POLICY
We may revise this Policy from time to time, in particular to reflect legal, technological, or functional developments. The applicable version is the one in force on the date you use the Application, as published on our website www.virtual-hall.com/privacy-policy-vhapp (or an equivalent link accessible from the Application). In the event of a substantial change having a significant impact on your rights or on how we process your data, we will inform you by an appropriate means (for example, a notice in the Application or on our website). We encourage you to review this Policy regularly.
- DATA SECURITY
We implement appropriate technical and organizational measures to protect the personal data we process (mainly temporary IP logs and newsletter emails, where applicable) against loss, unauthorized access, disclosure, alteration, or destruction, in accordance with applicable legal requirements and the state of the art. This includes measures such as logical and physical access control, encryption where relevant (for example, for data transfers), pseudonymization where possible, and data processing agreements with our processors that impose strict security obligations on them. However, no security measure is infallible and we cannot guarantee absolute security.
- VALIDITY AND LANGUAGE
Last revised: March 31, 2025
Current version: 2.1.1
Effective date: March 31, 2025
This Policy is written in French. In the event of translation into other languages, the French version prevails in case of discrepancy.
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