Privacy Policy

EXTEND ROBOTICS LIMITED – PRIVACY NOTICE

Introduction

Welcome to the Extend Robotics Limited (Extend Robotics, or variously “we”, “us” or “our”) privacy notice.

Extend Robotics respects your privacy and is committed to protecting your personal data. This privacy notice will tell you about your privacy rights, how the law protects you, and how we look after your personal data. This privacy notice is for:

The staff of our corporate customers

The staff of our potential corporate customers

The staff of our suppliers

The staff of our potential suppliers

Our customers who are individuals

Our potential customers who are individuals

Staff of our corporate partners

Staff of our potential corporate partners

Visitors to Our Site

Individuals who receive our marketing communications

Job/internship applicants

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Extend Robotics collects and processes your personal data through your use of our Site, https://www.extendrobotics.com (Our Site), including any data you may provide through Our Site or otherwise when you or the organisation you work for uses our products and/or services, including but not limited to our MetaQuest application (App), for the MetaQuest 2 and MetaQuest Pro.

We also collect personal data when you contact us, partner or seek to partner with us, when we conduct customer satisfactory surveys, business to business marketing, hold events, and address complaints.

We do not knowingly collect children’s personal data, nor do we provide our services to children. Our Site is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice is not intended to be the sole document pertaining to how we collect, process, and secure your personal data.

Controller/processor

Extend Robotics is the controller and responsible for your personal data.

We have appointed a data protection manager (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Extend Robotics Limited

Email address: info@extendrobotics.com

Postal address: 5 – 9 Merchants Pl, Reading, RG1 1ET

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on 8 February 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, marital status, title, job title, and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you or the organisation you work for and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you or the organisation you work for, and the balance that is attributed to your profile.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Our Site.
CV Data for example your employment and education history data, your academic qualifications and your interests as they may appear on a CV or other media.
Usage Data includes information about how you use Our Site.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We receive Aggregated Data from Meta, which is different from the other personal data we receive from Meta, that records your physical usage of the MetaQuest headset and/or our products whilst you utilise the App. This includes information such as headset position, hand/controller tracking, and how you interact with the physical environment via the App. Meta does not provide this data otherwise than in an anonymised form. To review Meta’s policies in this respect, please click here.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you or the organisation you work for, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or the organisation you work for (for example, to provide you with services). In this case, we may have to cancel a service you or the organisation you work for has with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise, and when using our services (including the App). This includes personal data you provide when you:
- purchase for our products or services or do so on behalf of the organisation you work for;
- subscribe to our service or publications;
- request marketing to be sent to you; and/or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with Our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third Parties. We may receive Identity Data and Profile data from Meta in order for you to use our products and services.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you or the organisation you work for.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us. We do not use any MetaQuest headset User Data or Aggregate Data for marketing purposes.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

To provide our products or services to you or your organisation

Type of data

(a) Identity

(b) Contact

(d) Transaction

(e) Profile

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you or the organisation you work for

Purpose/Activity

To partner with you and the organisation you work for

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to promote our aims)

Purpose/Activity

To consider whether to partner with you and the organisation you work for

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to potentially promote our aims)

Purpose/Activity

To administer and protect our business and Our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

Purpose/Activity

To receive your organisation’s goods or services

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to receive goods or services from suppliers)

Purpose/Activity

To consider your organisation’s offer to supply goods or services to us

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to identify potential suppliers to receive goods or services from)

Purpose/Activity

To consider your application for a job or internship with us

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to consider job or internship applicants)

Purpose/Activity

To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

(a) Identity

(b) Contact

(d) Marketing and Communications

(e) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity

To use data analytics to improve Our Site, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep Our Site updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity

To receive communications from you via Our Site

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to enable users to contact us via Our Site)

Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a contract between us and you or the organisation you work for, you contacting us, or other interactions or transactions listed above.

Our Site uses cookies. Please refer to our Cookie Policy for more information about the cookies you use and how you can opt-out from them when visiting Our Site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

External Third Parties as set out in the Glossary.
Specific third parties such as Meta Platforms Technologies LLC. Where personal data is shared with Meta, it is solely for the purposes described in this Privacy Notice. The App communicates with our internal servers in order to provide our services to you when you utilise the App.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity and other related data types) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure (deletion) of your personal data. This enables you to ask us to delete or remove your personal data. We will do so if you ask us to (without undue delay), or if your Meta account is deleted. We also periodically review our personal data to decide whether it is necessary to provide our services to you; if it is not necessary, we will delete your personal data. If Meta asks us to delete your personal data, we will do so. We will also erase your personal data to comply with local law or where you have successfully exercised your right to object to processing (see below),

Note, however, that we may not always be able to comply with your request of erasure if required by local law, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you and the organisation you work for the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or the organisation you work for is a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors that provide IT and system administration services, including marketing providers such as HubSpot.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.