Privacy Policy immerGallery, immerGallery Demo and immerGallery Business (Meta Quest versions)

Last updated: 22 October 2026

1. Controller

The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

immerVR GmbH
Im Zollstock 12
91093 Heßdorf
Germany
Managing Director: Daniel Pohl
Email: support@immervr.com

If you have any questions about data protection or wish to exercise your data protection rights, you can contact us using the email or postal address above.

2. Scope of this Privacy Policy

This Privacy Policy applies to immerGallery (full version), immerGallery Demo and immerGallery Business on Meta Quest devices and the online app services operated by immerVR GmbH for these versions.

The availability of individual features depends on the app edition and build. The descriptions of optional features apply when you use them. Business-only functionality is identified below.

Our apps are developed using the Unity engine. Where this Privacy Policy refers to an external platform or service, that provider may additionally process personal data under its own responsibility and according to its own privacy policy.

3. General Principles of Data Processing

We process personal data only where necessary for the purposes described in this Privacy Policy and where there is a legal basis for the processing. Depending on the processing activity, the relevant legal bases are in particular:

Where we rely on legitimate interests, our interests are balanced against the rights and interests of the affected persons. We do not sell personal data.

4. App Distribution Through the Meta Horizon Store

Our apps for Meta Quest are distributed through the Meta Horizon Store.

Meta is responsible for the operation of its store, user accounts, downloads and the payment processes it provides. In providing these services, Meta may process information such as:

We do not control the data processing performed independently by Meta. Please refer to its privacy information: https://www.meta.com/legal/privacy-policy/

We do not receive complete payment-card or bank-account details from the Meta Horizon Store.

5. Platform User IDs and Pseudonymous User Accounts

Certain app functionality requires us to identify the same platform user across app sessions, reinstallations or devices. Our app may receive your Meta platform user identifier. For storage in our own systems, we immediately transform the platform identifier into a one-way hash.

We do not store the original plain platform User ID in our backend database. The resulting hashed identifier is pseudonymous data. It may still constitute personal data because it can be associated with the same user over time. We use the hashed identifier in particular to:

Where rewards or StereoGold services are available, the app automatically exchanges account and usage information with our backend, including during startup and reward updates. This may include cumulative app starts and running minutes, multiplayer minutes and connection or authentication-failure counts, your saved multiplayer name, reward information and technical app/device information. These records are linked to your hashed identifiers and used to maintain and restore account information and entitlements, check the consistency of usage history and help prevent misuse of rewards and StereoGold.

We also retain the StereoGold balance changes needed to explain purchases, consumption, daily awards and support corrections. Related technical information, such as app version, app/store platform, operating system and device model, helps us identify purchase or balance errors affecting a particular app version or device platform.

The legal basis for providing and restoring the relevant account functionality is Art. 6(1)(b) GDPR. Error diagnosis, consistency checks and misuse prevention are based on Art. 6(1)(f) GDPR, reflecting our legitimate interests in correcting platform-specific problems, protecting these services against manipulation and maintaining reliable account and entitlement records. This account, rewards and StereoGold backend is operated by us on a server hosted by STRATO in Germany.

We retain account identifiers, balances, entitlements and the history and related technical context needed to maintain, restore and explain them for as long as we provide the corresponding account functionality and the information remains necessary for those purposes. This supports users returning after several years; inactivity alone does not expire their purchased balance or unlocked rewards. Routine diagnostic log files have the shorter retention periods in section 21. If you request deletion, we will delete or anonymize the corresponding records where possible, unless statutory obligations or overriding legal reasons require further retention.

Because we do not store your original platform ID, we may need appropriate information from you to identify the correct pseudonymous record when processing a data access or deletion request.

6. Meta Platform Features

On Meta Quest devices, our apps use Meta platform features including:

These features are used in order to provide app functionality requested by the user. For example, they may be used to:

The persistent identifier stored in our own backend is the hashed identifier described above rather than the plain Meta User ID. Meta may independently process additional account or platform information when providing these features. We do not control Meta's independent platform processing. The legal basis for our processing is Art. 6(1)(b) GDPR. We do not use Meta User IDs or their hashes for advertising or cross-service advertising profiles.

7. App Backend and Hosting

We operate our APIs, databases and app backend services on servers hosted by STRATO AG and Hetzner Online GmbH in Germany. STRATO hosts our account, rewards, StereoGold and licensing backend. Hetzner hosts spatial conversion, developer-log submissions and Business app configuration services.

The servers used by us for these services are located in Germany. Depending on the feature being used, our backend may process technical data necessary to provide the service, such as:

For the servers we operate with STRATO and Hetzner, we normally retain web-access logs for 30 days and system, authentication and technical error logs for 60 days. This allows investigation of technical problems or attacks discovered after a delay. Storage limits may result in earlier deletion. Only relevant extracts may be kept longer where necessary for a specific ongoing investigation.

We do not use these server logs for advertising or user profiling.

The legal basis is Art. 6(1)(b) GDPR where the processing is required to provide a requested service or app feature, and Art. 6(1)(f) GDPR for security, troubleshooting and abuse prevention. STRATO and Hetzner act as hosting providers and processors where they process personal data on our behalf.

8. Voluntary Developer Log Submissions

Our apps allow users to voluntarily submit a developer log if they encounter a problem and want to provide diagnostic information to us. A developer log is sent to us only when the user explicitly chooses to submit it. Depending on the circumstances, a submitted developer log may contain information such as:

Voice-control audio itself is not included in these logs. Developer logs are stored in access-restricted support systems operated by us, including our Hetzner server and local support archives. We use Pushover, LLC in the United States for brief notifications identifying a submission as internal or external, with a random report link. Your email address, message and log files are not sent to Pushover; opening the report requires authorized sign-in. Privacy information: https://pushover.net/privacy. The legal basis is Art. 6(1)(b) GDPR where the log is submitted in connection with support or the provision of the app, and Art. 6(1)(f) GDPR based on our legitimate interest in diagnosing errors, maintaining app stability and improving the service. Developer logs are normally deleted no later than 12 months after submission, unless the log remains necessary for an ongoing support, security or technical investigation.

9. Local Voice Control

Voice-control recognition inside our app is performed locally on the user's device. We do not send voice-control audio to our servers or to a cloud speech-recognition service. Recognized commands may appear as text in a developer log. Such text is transmitted to us only if the user voluntarily submits that developer log as described above.

10. Multiplayer – Photon Fusion and Photon Voice

Our apps use Photon Fusion and Photon Voice to provide multiplayer and real-time voice communication. The provider is:

Exit Games GmbH / Photon

Privacy information: https://www.photonengine.com/en-US/PrivacyPolicy

When you use multiplayer functionality, your device connects to Photon infrastructure. Depending on the multiplayer session, information processed may include:

Your plain Meta platform User ID is not shared with other multiplayer participants.

In immerGallery Business only, Support View allows the session administrator to see reconstructed participant views. Viewing position and orientation, menu status and media information are transmitted through Photon. The views are reconstructed locally using media already present on the participants’ devices; this feature does not transmit content pixels or media files.

Voice communication

Photon Voice is used to transmit voice communication between multiplayer participants in real time. immerVR does not record or store voice-chat audio. Voice audio is transmitted through the Photon service for the purpose of enabling live voice communication. For information about processing carried out within Photon's infrastructure, please refer to Photon's privacy information. The legal basis for multiplayer and voice processing is Art. 6(1)(b) GDPR because the processing is necessary to provide the multiplayer functionality requested by the user. We use Photon under the applicable data-processing arrangements. Photon operates globally distributed infrastructure. As a result, network and multiplayer data may be processed outside the European Economic Area. Where required, appropriate safeguards for international data transfers apply.

11. OpenStreetMap

Our apps can display maps based on geographic information associated with images or settings used in an .immerVR file. For this functionality we use map material provided through OpenStreetMap. The app connects directly from the user's device to OpenStreetMap infrastructure. We do not proxy this connection through our own servers. As a result, OpenStreetMap may receive technical connection information such as:

The requested map area can indirectly reveal the geographic area being displayed. The map location may originate from GPS metadata contained in an image or from location information selected or configured by the user. The legal basis for our use of this functionality is Art. 6(1)(b) GDPR because the external request is necessary to provide the map feature requested by the user. Information about OpenStreetMap's processing is available at: https://wiki.osmfoundation.org/wiki/Privacy_Policy

12. Pastebin Access

Our apps include an optional function that allows a user to retrieve text from Pastebin. The app contains a predefined pastebin.com address. The user can enter a Pastebin identifier and explicitly press a button to retrieve the corresponding content. Only when the user activates this function does the app make a direct web request to Pastebin. This operates similarly to opening a limited external web resource. Pastebin may therefore receive the user's IP address and technical information associated with the request. We do not control the content the user chooses to retrieve from Pastebin. The legal basis for initiating the connection is Art. 6(1)(b) GDPR because it is performed only in response to the user's explicit request to use this feature. Pastebin's privacy information is available at:

https://pastebin.com/doc_privacy_statement

Users should be aware that Pastebin is an external service and that information published publicly on Pastebin may be accessible to third parties.

13. Spatial Conversion Service

Our apps provide optional server-based spatial conversion functionality. When you explicitly request a spatial conversion, the relevant files are uploaded to our servers hosted by Hetzner in Germany.

Processing of uploaded files

Files are encrypted on the device before upload. For conversion, the files are temporarily processed on our server. They are decrypted only as required to perform the requested conversion and the result is encrypted again for retrieval by the app. Original filenames are replaced with technical filenames before upload and restored locally by the app where applicable. This does not make the media content itself anonymous. The download information for a completed conversion is provided to the requesting immerGallery app.

Uploaded source files and temporary working files are removed after processing where possible. Abandoned files are normally removed once they have been inactive for 24 hours. Completed results are normally available for up to 48 hours after completion and are then removed by regular cleanup. Active uploads and conversions are allowed to finish before cleanup, which can extend these periods while processing is in progress.

We do not acquire ownership or other rights to the user's uploaded content as a result of the conversion process.

The legal basis is Art. 6(1)(b) GDPR because this processing is necessary to perform the conversion explicitly requested by the user.

Conversion logs

For operation, troubleshooting, capacity planning, enforcement of usage limits and protection against misuse, we may log information such as:

Hashing an identifier does not necessarily make it anonymous. We therefore treat such identifiers as pseudonymous data where they can still be associated with a user. The legal basis for these logs is Art. 6(1)(f) GDPR. Our legitimate interests are secure service operation, error diagnosis, capacity planning, prevention of abuse and enforcement of technical usage limits. Identifiable or pseudonymous conversion log data is normally deleted after 90 days. Genuinely aggregated or anonymized statistical information that no longer permits identification of an individual user may be retained for longer periods for service statistics and capacity planning.

14. Optional Cloud Storage – OneDrive, Dropbox and Nextcloud

You can optionally connect Microsoft OneDrive (personal), Dropbox or a Nextcloud server. The app processes account identifiers, connection settings, file and folder metadata, thumbnails and media to provide browsing, playback, favorites and file operations, including uploads, copies, moves, renaming, deletion and folder creation where permitted. The legal basis is Art. 6(1)(b) GDPR for providing these requested features.

Microsoft and Dropbox sign-in takes place on their websites. Access and refresh tokens or Nextcloud app passwords are stored encrypted on your device for reconnection until you disconnect in Settings > Cloud.

Cloud requests and transfers run directly between your device and the relevant provider or server, which receives your IP address and request information. Our servers do not receive your cloud credentials or relay these transfers. If you request spatial conversion or submit a diagnostic log, sections 13 and 8 apply respectively.

Media and thumbnails may be cached locally until cache cleanup or manual clearing. Temporary transfer copies are normally removed after the operation; abandoned copies are cleaned on the next app startup. Favorites, including their saved thumbnails, and downloaded files remain until you remove them. Disconnecting removes the saved login credentials; it does not delete these local copies or revoke authorization at the provider. You can revoke authorization or the app password in the provider's or server's account settings.

immerVR is responsible for data handling and protection within our app. The selected provider or server operator independently processes data under its own privacy information, including retention and international transfers (see also section 20):

Microsoft: https://www.microsoft.com/en-us/privacy/privacystatement

Dropbox: https://www.dropbox.com/privacy

Nextcloud: the privacy information of the operator of the server you choose.

15. Configuration Sharing – immerGallery Business

In immerGallery Business only, you can upload selected app settings to our backend and retrieve them using a configuration code. These settings may include configured names, URLs, paths and content preferences. The upload includes a hashed account identifier or, where unavailable, a device identifier. Configurations have no automatic expiry so that they remain available for long-term restoration; your deletion rights described below apply. The legal basis is Art. 6(1)(b) GDPR.

16. Meta Horizon Store Purchases

Purchases made through the Meta Horizon Store are processed through Meta's purchasing system. We may receive limited information required to provide the purchased product or feature, such as:

We do not receive complete payment-card details from Meta. The legal basis for the processing performed by us is Art. 6(1)(b) GDPR. Meta independently determines its processing of payment, account and store data.

17. Direct Licensing of immerGallery Business – Lemon Squeezy

For licenses of immerGallery Business sold outside an app store, we use Lemon Squeezy, operated by Sold through Link, LLC (formerly Lemon Squeezy LLC). Lemon Squeezy acts as merchant of record for purchases made through its checkout and handles functions including payment processing, invoicing, applicable tax handling, refunds and related transaction administration. We do not receive complete credit-card or bank-account details. We may receive information necessary to fulfil the purchase, manage the license and provide support, such as:

We receive license and billing notifications from Lemon Squeezy to maintain entitlements and resolve subscription and payment issues. Detailed notifications are normally retained in the active database for 180 days after receipt; a reduced event history is retained for 400 days to support investigations across annual subscription cycles and delayed customer enquiries. Records required to provide an active license or subscription remain available for as long as needed for that purpose. Relevant records may be kept longer while necessary for an unresolved support case, dispute or legal obligation.

Our legal bases are:

Privacy information: https://www.lemonsqueezy.com/privacy

18. Email Contact and Support

If you contact us by email, we process your email address, any name or other contact details you provide, and your message to respond to your enquiry. Our email service is hosted by STRATO in Germany.

The legal basis is Art. 6(1)(b) GDPR where your enquiry concerns a contract, purchase, support request or pre-contractual matter, or Art. 6(1)(f) GDPR for other enquiries, based on our legitimate interest in communicating with users and responding to enquiries.

Correspondence is retained only for as long as necessary to deal with the respective matter. Where communications form part of a contractual or business relationship, statutory commercial or tax-related retention obligations may require longer storage.

You can contact us at support@immervr.com. Voluntary developer-log submissions are described in section 8.

19. Other Recipients

Depending on the particular feature you use, personal data may also be processed by or transmitted to providers described in this Privacy Policy, including:

Some of these providers act as processors on our behalf, while others independently determine some or all of their processing as separate controllers.

20. Transfers Outside the European Economic Area

Some external providers operate globally or are established outside the European Economic Area. As a result, personal data may in some circumstances be processed outside the EEA. Where we are responsible for such a transfer, we use a legally recognized transfer mechanism where required, such as:

Where an external platform or provider processes personal data independently, further information about its international data transfers is available in that provider's privacy policy.

21. Storage Periods

We retain personal data only for as long as required for the purpose for which it was collected.

Important retention periods described in this Privacy Policy include:

Aggregated or anonymized statistical information that can no longer be associated with an identifiable individual may be retained for longer periods.

Other personal data is deleted when it is no longer required for the relevant purpose unless statutory requirements require continued retention. In particular, commercial and tax laws may require certain contractual, transaction, invoice or accounting records to be retained for statutory periods.

Data may also be retained where necessary for the establishment, exercise or defense of legal claims.

22. Data Security

We use appropriate technical and organizational measures designed to protect personal data against unauthorized access, alteration, loss, disclosure or destruction. These measures are reviewed and adapted where appropriate in view of the nature of the processing, the available technology and the relevant risks. No electronic transmission or storage system can provide an absolute guarantee of security.

23. Provision of Personal Data

Certain information may be required to provide a service or feature that you explicitly request. For example:

If information necessary for a requested service is not provided, we may be unable to provide that particular service or functionality.

24. Your GDPR Rights

Subject to the respective legal requirements, you have the following rights concerning personal data relating to you:

Right of access – Art. 15 GDPR

You may request information about whether we process personal data concerning you and, where applicable, obtain access to that data.

Right to rectification – Art. 16 GDPR

You may request correction of inaccurate personal data and completion of incomplete data.

Right to erasure – Art. 17 GDPR

You may request deletion of your personal data where the legal requirements for deletion are met.

Right to restriction of processing – Art. 18 GDPR

You may request restriction of processing in the circumstances provided by law.

Right to data portability – Art. 20 GDPR

Where the statutory requirements apply, you may receive personal data you have provided to us in a structured, commonly used and machine-readable format and may have the right to transmit that data to another controller.

Right to object – Art. 21 GDPR

Where we process personal data on the basis of Art. 6(1)(e) or Art. 6(1)(f) GDPR, you have the right to object to such processing for reasons arising from your particular situation.

Where a valid objection is made, we will cease the processing unless there are compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is required for the establishment, exercise or defense of legal claims.

Withdrawal of consent – Art. 7(3) GDPR

Where processing is based on consent, you may withdraw your consent at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out before the consent was withdrawn.

25. Exercising Your Rights

To exercise your rights concerning personal data processed by immerVR GmbH, contact us at:

support@immervr.com

or by post:

immerVR GmbH
Im Zollstock 12
91093 Heßdorf
Germany

We may need to request appropriate information to verify your identity or to identify the relevant data. This can be particularly important for our app backend because we do not store original platform User IDs and instead use one-way hashed identifiers. Where personal data is processed independently by Meta or another external provider described in this policy, requests concerning that provider's independent processing should generally be directed to the respective provider.

26. Right to Lodge a Complaint

You have the right under Art. 77 GDPR to lodge a complaint with a competent data protection supervisory authority. The supervisory authority responsible for private-sector companies at our place of establishment is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach
Germany

You may also contact another competent supervisory authority where permitted by the GDPR.

27. Changes to this Privacy Policy

We may update this Privacy Policy where our services, technical infrastructure, third-party providers or applicable legal requirements change. The version published on our website at the relevant time applies.