Last Updated: March 2026

NOTICE FOR ENTERPRISE CUSTOMERS: Enterprise customers and their Authorized Users are also subject to the Immerse Enterprise Terms of Service (immerse.com/legal/enterprise-terms) and, where applicable, the Data Processing Addendum (immerse.com/legal/dpa). The DPA governs how Immerse processes personal data on behalf of enterprise customers and supersedes this Privacy Policy with respect to enterprise data processing obligations.

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Your privacy is important to us. This Privacy Policy (“Policy”) applies to services provided by Immerse Inc. (“we”, “us”, or “Company”) and our website, product pages, mobile or web applications, or other digital products that link to or reference this Policy (collectively, the “Services”) and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal Information”) and how we use it. This Policy applies to any visitor to or user of our Services.

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We reserve the right to change this Policy at any time. We will notify you of any changes by posting a new Policy to this page and/or by sending notice to the primary email address specified in your account. Changes to this Policy are effective when they are posted on this page. Your continued use of our Services after we publish or send notice about changes to this Policy means that the collection, use, and sharing of your Personal Information is subject to the updated Policy.

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WHAT INFORMATION DO WE COLLECT?

We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person. The categories of Personal Information we may collect are listed below.

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Identifiers

We may collect your first and last name, email address, username, postal address, phone number, IP address, country, time zone, or display name.

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Commercial information

We may collect your sales and subscription history for the Services.

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Voice data

We may receive your voice data through your microphone. Typically we do not store this information, although we reserve the right to process your voice data locally in certain public room instances for moderation purposes. For moderation purposes, some of this voice data may be recorded and sent to a third-party service for additional processing. Any such recordings are anonymized and retained for no more than 30 days. Voice data in private instances is never processed, stored, or sent to third parties, except as expressly provided herein.

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Sensory data

We may receive animation data derived from your head movement and facial expressions. Any such sensory data are anonymized and retained for no more than 30 days.

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Neural and biometric data

Where you access the Services via virtual reality hardware, we may process neural and biometric data generated by your headset, including eye-tracking data, haptic response data, and spatial intent data. This data is used solely to facilitate immersive interaction within the platform — for example, ensuring that AI Avatars respond appropriately to your gaze and physical presence in the virtual environment. We do not sell neural or biometric data, and we do not use it to profile your mental state, aptitude, reliability, or any other personal characteristic for any third-party marketing or employment-related purpose. Neural and biometric data is retained only for the duration of your session and is not stored beyond what is necessary for platform functionality, except where you have provided explicit consent for research purposes.

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Recordings

We may record your session, which includes a video feed of your virtual reality avatar and first name, voice data, and other audio of the session. Your instructor will initiate the Recording and we will give you a notification (visual or otherwise) when recording is enabled. We may use information obtained from Recordings for our internal training and academic research purposes.

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Transcription data

We may collect data contained in transcriptions of your AI conversations and other chat sessions in the Services.

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Internet or other network activity

• We may collect your activity history through cache, cookies, and REST API calls.
• We may collect usage data and history, including search terms entered, pages viewed, and other usage behavior identified by analytics events.

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Other categories

• We may collect information from the content that you create and share publicly in the Services.
• We may collect your responses to surveys that we may ask you to complete for research purposes or to help direct Company activities.
• We may collect any information you provide when communicating with us or that you otherwise voluntarily provide to us.

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FROM WHAT SOURCES DO WE COLLECT PERSONAL INFORMATION?

Directly from you

We may collect your Personal Information when you provide it to us directly. For example:

• When you register for an account, you are required to provide your email address, first and last name, and create a password. We may also collect your phone number, country, and time zone. If you use your Meta account to log in to the Services, we may receive your email and associated Meta account information.
• When you contact us or report a problem with the Services, we may collect records and copies of your correspondence.
• When your instructor or other Immerse employee has initiated a Recording and you have granted permission.
• When the Services crash during play, we may collect your running/loaded DLLs, your username, and the data gathered from a small memory dump.
• When you choose to use your device microphone for voice chat.
• When you respond to a survey or questionnaire, we may collect the information provided.

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On Meta Quest and other VR headsets

Our Services may request permission to access the following on your VR headset:

• Microphone — to support real-time voice chat. Voice chat is optional and may be turned off at any time. The Services will continue to function without voice chat if you choose to deny permission.
• Camera — to animate your virtual avatar in certain scenarios.
• Eye-tracking and spatial sensors — where supported by your headset, to enable avatar responsiveness and immersive interaction features. See Neural and Biometric Data section above.

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Automatically from you

We may collect your Personal Information automatically as you use our Services, including through cache, cookies, and REST API calls. For more information about our use of automatic tracking technologies and your choices, please see the section titled “How Do We Use Tracking Technologies” below.

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From third parties

We may receive Personal Information from or through third parties that help us provide or facilitate your access to the Services, including:

• Meta Quest Store, Apple App Store, Google Play Store, and other virtual reality app store platforms;
• Cloud computing providers;
• Payment platform providers; and
• Data analytics providers.

A current list of our third-party sub-processors is available at immerse.com/legal/subprocessors.

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HOW DO WE USE THE INFORMATION WE COLLECT?

We use the information we collect:

• To deliver and improve the Services and your overall user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• To link or combine user information with other Personal Information.
• To analyze usage of the Services and understand whether the Services are being used as intended.
• To compare and verify information for accuracy and update our records.
• To email, message, or otherwise contact you with information and updates about us and the Services.
• To respond to your comments and questions and provide customer service.
• To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To analyze how you use the Services with third-party tools to help us understand traffic patterns and know if there are problems with the Services.
• To create targeted advertising to promote the Services and engage our users.
• In connection with a merger, acquisition, reorganization, or similar transaction.
• When required by law or to respond to legal process.
• To protect our users, other individual lives, and/or the rights or property of Company.
• To maintain the security of the Services.
• For any other purpose with your consent.

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HOW DO WE USE ARTIFICIAL INTELLIGENCE SERVICES?

Our platform utilizes Artificial Intelligence (AI) technology, including technology provided by OpenAI and other third-party providers. The following describes how we use this technology and how your data is handled in connection with it.

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AI processing for all users

The AI component within our application is a machine learning model, not a human operator. AI-generated content is provided for educational purposes only and should not be relied upon as professional, legal, or medical advice. We employ automated filters to strip Personally Identifiable Information (PII) from user prompts before they are processed by external AI providers.

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Enterprise customers — enhanced data protections

For enterprise and B2B customers, Immerse processes AI interactions under enterprise-grade agreements with our AI providers. Specifically:

• Customer data and Authorized User inputs are not used by OpenAI or other third-party LLM providers to train their public foundation models.
• Immerse utilizes zero data retention agreements with AI providers for enterprise processing, meaning prompts and responses are not stored by those providers after processing is complete.
• These enhanced protections are in addition to the standard protections described in this Policy and are governed by the Immerse Enterprise Terms of Service and Data Processing Addendum.

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Consumer accounts

For individual consumer accounts, your interactions with AI features are processed in accordance with this Privacy Policy and the applicable terms of our AI providers. We implement measures to anonymize and protect your data. Your data is not used by Immerse to train third-party AI models. For information about how OpenAI handles data, please review OpenAI’s current privacy policy at openai.com/privacy.

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Aggregate and de-identified data

Notwithstanding the above, Immerse shall have the right to collect and analyze data and other information relating to the provision, use, and performance of various aspects of the Services. Immerse may use and disclose such information solely in aggregate or other de-identified form that cannot reasonably be used to identify an individual, in connection with its business operations, service improvements, and academic research. This aggregate data use applies only after data has been genuinely anonymized and no longer constitutes Personal Information under applicable law.

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DO WE SHARE YOUR PERSONAL INFORMATION?

In addition to the specific situations discussed elsewhere in this Policy, we disclose personal information in the following circumstances:

• With our corporate affiliates and subsidiaries.
• With third parties that perform services to support our core business functions and internal operations, including database administrators, cloud computing services, payment processors, advertising services, and application services providers. A current list of our sub-processors is available at immerse.com/legal/subprocessors.
• To support our audit, compliance, and corporate governance functions.
• In connection with a change of ownership or control of all or part of our business, such as a merger, acquisition, reorganization, or bankruptcy.
• If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues.
• If required or permitted by applicable law or regulation, or in the good-faith belief that such action is necessary to: (a) comply with a legal obligation or respond to a request from law enforcement or other public authorities; (b) protect and defend the rights or property of Company; (c) act in urgent circumstances to protect the personal safety of users, customers, or others; or (d) enforce our Terms of Service or otherwise protect against legal liability.
• With your consent or at your direction.

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HOW DO WE USE TRACKING TECHNOLOGIES?

Some features on the Services may require the use of “cookies” — small text files that are stored on your device. You may delete and block all cookies from our Services, but parts of the Services may not work. We use the following categories of cookies:

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Required cookies

Required cookies enable you to navigate the Services and use their features. Because required cookies are essential to operate the Services, there is no option to opt out of these cookies.

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Performance cookies

These cookies collect information about how you use our Services, including which pages you visit most often. Information is only used to improve how the Services function and perform.

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Functionality cookies

Functionality cookies allow our Services to remember information you have entered or choices you make, and provide enhanced, more personal features.

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Targeting or advertising cookies

From time to time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Services. We sometimes use cookies delivered by third parties to track the performance of our advertisements. If you would like more information about interest-based advertising and your choices, please visit the Digital Advertising Alliance’s website at http://www.aboutads.info/.

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HOW DO WE SECURE YOUR PERSONAL INFORMATION?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction, including encryption, firewalls, and secure socket layer technology. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. You can take certain steps to help protect your Personal Information, such as using a strong password, not sharing your password, and logging out of your account after each use.

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DATA RETENTION

We retain your Personal Information while your account is in existence or as needed to provide you Services, unless a shorter retention period is required by applicable law or requested by you.

• Identifiers and account data: Retained for the duration of your account and for a reasonable period thereafter for legal and business purposes.
• Voice and sensory data collected for moderation: Retained for no more than 30 days, after which recordings are deleted.
• Neural and biometric data: Retained only for the duration of your session. Not stored beyond what is necessary for platform functionality unless you have provided explicit research consent.
• Session recordings (instructor-initiated): Retained for the duration of the relevant course or program, and then deleted unless retained for academic research with appropriate consent.
• Transcription data from AI conversations: Retained for the duration of your account unless you request deletion.
• Aggregate and de-identified data: May be retained indefinitely as it no longer constitutes Personal Information.

For enterprise customers, data retention is governed by the applicable Order Form term and the Data Processing Addendum, which provides for deletion or return of Personal Data within 30 days of termination.

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MANAGING YOUR PRIVACY

All users may review, update, correct, or delete the Personal Information in their user account by contacting us at support@immerse.online or by accessing your user account. We will try to comply with such requests in a reasonably timely manner. If you wish to cancel your account, please contact us at support@immerse.online and any personally identifiable information associated with your account will be deleted or anonymized in a timely manner or as required by applicable law.

We may use some of the information we collect for marketing purposes, including to send you promotional communications. If you wish to stop receiving these communications, please follow the opt-out instructions in those communications or contact us at support@immerse.online.

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YOUR RIGHTS UNDER APPLICABLE LAW

GDPR (EU and UK users)

If you are located in the European Economic Area or the United Kingdom, you have the following rights regarding your Personal Information:

• Right of access: You may request a copy of the Personal Information we hold about you.
• Right to rectification: You may request correction of inaccurate Personal Information.
• Right to erasure: You may request deletion of your Personal Information in certain circumstances.
• Right to restriction: You may request that we restrict the processing of your Personal Information.
• Right to portability: You may request a copy of your Personal Information in a structured, machine-readable format.
• Right to object: You may object to the processing of your Personal Information for direct marketing purposes or where processing is based on legitimate interests.

To exercise these rights, please contact us at privacy@immerse.online. You also have the right to lodge a complaint with your national data protection authority.

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LGPD (Brazilian users)

If you are located in Brazil, you have the following rights under Brazil’s Lei Geral de Proteção de Dados Pessoais (LGPD):

• The right to confirm the existence of processing of your Personal Information.
• The right to access your Personal Information.
• The right to correct incomplete, inaccurate, or outdated Personal Information.
• The right to request anonymization, blocking, or deletion of unnecessary or excessive Personal Information.
• The right to request portability of your Personal Information to another service or product provider.
• The right to request deletion of Personal Information processed with your consent.
• The right to information about third parties with whom Immerse has shared your Personal Information.
• The right to information about the possibility of denying consent and the consequences of doing so.
• The right to revoke consent at any time.

To exercise these rights, please contact us at privacy@immerse.online. You also have the right to lodge a complaint with Brazil’s Autoridade Nacional de Proteção de Dados (ANPD).

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CCPA / CPRA (California users)

If you are a California resident, you have the following rights:

• The right to know what Personal Information we collect, use, disclose, and sell.
• The right to delete Personal Information we have collected from you, subject to certain exceptions.
• The right to correct inaccurate Personal Information.
• The right to opt-out of the sale or sharing of your Personal Information. Immerse does not sell Personal Information.
• The right to limit the use and disclosure of Sensitive Personal Information. Your enterprise dashboard includes a “Limit the Use of My Sensitive Personal Information” link where applicable.
• The right to non-discrimination for exercising your privacy rights.

To exercise your California privacy rights, please contact us at privacy@immerse.online or by writing to Immerse Inc., 2175 Tustin Ave, Costa Mesa, CA 92627.

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CHILDREN UNDER 16

The Services are not directed to individuals under the age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at support@immerse.online and the information will be deleted.

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LINKS TO THIRD-PARTY WEBSITES

We may provide or the Services may contain links to other websites. We have no control over these websites and they are subject to their own terms of use and privacy policies. We do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third-party websites.

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HOW WE RESPOND TO DO NOT TRACK SIGNALS

We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

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INTERNATIONAL USERS

Immerse Properties can be accessed from countries around the world. Immerse Properties are controlled and offered by Immerse from its facilities in the United States of America. If you are located outside the United States, please be aware that information we collect about you will be transferred to and processed in the United States. By using the Services, you consent to this transfer.

For enterprise customers subject to GDPR, LGPD, or other international data protection regulations, international data transfers are governed by the Data Processing Addendum available at immerse.com/legal/dpa, which implements appropriate transfer mechanisms including Standard Contractual Clauses where required.

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CONTACT US

For general privacy questions: support@immerse.online

For data protection requests, GDPR/LGPD inquiries, or to contact our data protection team: privacy@immerse.online

For enterprise DPA inquiries: legal@immerse.online

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