Privacy Policy

Introduction

Welcome to Head Set Immersive Ltd’s (“Head Set”, “we”, “us”, “our”) privacy policy.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data when you participate in one of our immersive training experiences (‘Events’) either in-person or remotely, when we supply our services (‘Services’) to your organisation, or when you browse our website. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Controller

Head Set is the data controller and is responsible for certain personal data about you.

If you have any questions about this policy or about how we handle your data, please contact our data privacy team:

Email: info@headsetimmersive.com

Address: 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ

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. 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.

Changes

We keep our privacy policy under regular review. This version was last updated on 4th December 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 Parties

Our website may include links to third-party websites. 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 policy of every website you visit.

We are currently using Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

The Data We Collect

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:

Participants in events

Identity Data: includes name, job title, employer/organisation, date of birth, gender.
Contact Data: includes email address and telephone number.
Event Data: that you provide when you register to attend an Event, such as hostile environment experience, medical history, dietary requirements and other information applicable to the metrics of the Event.
Participation Data: includes images, photos and video footage taken during an Event and written accounts of the same.
Profile Data: includes attendance at an Event, and any other information or feedback you chose to provide.
Results Data: includes behavioural performance of a Participant during an Event such as heart rate and breathing.

Representatives of organisations to whom we supply our services

Identity Data: includes name, job title, employer/organisation.
Contact Data: includes email address and telephone number.
Marketing Data: Your preferences in receiving marketing communications from us on behalf of your organisation.

Website visitors or browsers

Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
Usage Data: information about how you use our website, IT, communication and other systems.

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 policy.

Our Events are not aimed at children, neither is our website. We therefore do not knowingly collection information about individuals under the age of 18.

Where we need to collect personal data by law, or under the terms of a contract we have with you, 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. In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time.

How Personal Data Is Collected

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

Direct Interactions: You may give us your personal data by filling in forms such as our registration form or our pre-course questionnaire or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- apply to us directly to attend an Event;
- liaise with us on behalf of your organisation for us to supply Services;
- give us feedback or contact us.
Third Parties: We will receive personal data about you from various third parties such as:
- analytics providers such as Google and Squarespace;
- organisations (and their representatives) to whom we supply our Services.
Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

How Personal Data Is Used

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.
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.
In limited circumstances where you have given your consent.

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

Type of Data

Lawful Basis

To register your interest in attending an Event.

(a) Identity
(b) Contact

Necessary for our legitimate interests (to provide our Services).

To enable your attendance at an Event including the use of our equipment such as our headsets, and the facilities at the Event.

(a) Identity
(b) Contact
(c) Event
(d) Results

(a) Necessary for our legitimate interests (to provide our Services);
(b) Performance of a contract with you;
(c) Compliance with a legal obligation;
(d) Your explicit consent.

To anonymize your information to provide anonymous and aggregated feedback to your organization.

(a) Identity
(b) Contact
(c) Event
(d) Profile

Necessary for our legitimate interests (to provide our Services).

To create marketing material that depicts your participation in an Event.

(a) Participation Data

Necessary for our legitimate interests (to grow our business and for product development).

To your organization as a new customer.

(a) Identity
(b) Contact

Necessary for our legitimate interests (to manage our contract with your organization)

To deliver our Services to your organization and manage our relationship with your organization for example administering our agreement, receiving information with regards to Event attendees or sending you marketing communications.

(a) Identity
(b) Contact
(c) Marketing

Necessary for our legitimate interests (to manage our contract with your organizations, keep our records updated and to study how customers use our products and to grow our business)

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

(a) Identity
(b) Contact
(c) Technical

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 reorganization or group restructuring exercise)

To use data analytics to improve our website, products, marketing, customer relationships, and experiences.

(a) Technical
(b) Usage

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

Marketing

We strive to provide you (as a representative of our customers) with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage, and Marketing Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

You can ask us or third parties to stop sending you marketing messages at any time by unsubscribing.

We may also send you solicited marketing material where you request this is specifically sent to you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

Disclosures of 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
- Service providers acting as processors who provide services such as payment processing services and IT and system administration services.
- Marketing Companies and Online Advertising.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
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 policy.

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.

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.

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.

Data Retention

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.

Details of retention periods for different aspects of your personal data are available from us by contacting us.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your Legal Rights) to find out more about these rights.

If you wish to exercise any of these rights please contact our privacy team.

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.

Your Legal Rights

You have the right to:

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 of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons 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.