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    Privacy Policy

    Last updated: March 2026

    This privacy notice for ATXR Ltd ('Company', 'we', 'us', or 'our') describes how and why we might collect, store, use, and/or share ('process') your information when you download and use our mobile application (EC7), or any other application of ours that links to this privacy notice.


    ATXR Ltd is the data controller and is responsible for your personal data.

    Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@atxr.co.uk


    We keep our privacy notice under regular review. It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.


    SUMMARY OF KEY POINTS


    What personal information do we process? We do not collect any personal data when you download or use the EC7 app. We may gather usage data and download numbers, but this is done on an anonymised basis and no personal data is gathered as part of this exercise.


    We may gather geolocation data detailing where the App has been used, but we will not be able to identify you from this information. We will only be able to locate where a device has accessed the App, not the identity of the user or any other personal data.


    Do we process any sensitive personal information? We do not process sensitive personal information.


    Do we receive any information from third parties? We do not receive any information from third parties.


    How do we process your information? We process information to provide, improve, and administer our Services, for security and fraud prevention, and to comply with law. We will only process information when we have a valid legal reason to do so.


    With whom do we share personal information? We do not share any personal data with third parties.


    How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.


    What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.


    How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.


    1. WHAT INFORMATION DO WE COLLECT?


    Personal information. We do not process your personal information.

    Sensitive information. We do not process sensitive information.

    Application data. If you use our application, we may collect the following information:

    • Geolocation data (where the App has been used)
    • Usage data (how long someone uses the App for)
    • Download data (how many copies of the App have been downloaded)

    This information is gathered on an anonymous basis and cannot be linked back to you or your device. It is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.


    Information automatically collected


    We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, device name, country, geolocation, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

    The information we collect includes:

    • Log and usage data: Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. This may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, features used, and error reports). We cannot link any of this information to you personally.


    2. HOW DO WE PROCESS YOUR INFORMATION?


    We process information to provide, improve, and administer our Services, for security and fraud prevention, and to comply with law. Specifically:

    • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.


    3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?


    The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal basis we rely on to process your personal information. We may rely on the following legal bases:

    • Legitimate interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests, for example to analyse how our services are used, diagnose problems, and improve user experience.
       
    • Legal obligations. We may process your information where necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, or to disclose information as evidence in litigation.
       
    • Contractual obligations. We may process your personal data where necessary to fulfil our obligations under the licence to the App (should you agree to its terms and download the App).
       

    4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?


    We may need to share your personal information in the following situations:

    • Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


    5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?


    We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.


    6. HOW LONG DO WE KEEP YOUR INFORMATION?


    We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than 6 months.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.


    7. HOW DO WE KEEP YOUR INFORMATION SAFE?


    We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

    We will notify you and any applicable regulator of a personal data breach where we are legally required to do so.


    8. WHAT ARE YOUR PRIVACY RIGHTS?


    In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information.


    We will consider and act upon any request in accordance with applicable data protection laws.


    You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.


    We try to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, we will notify you and keep you updated.


    If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. Contact details for EEA authorities are available at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm


    If you are located in Switzerland, contact details for the data protection authorities are available at: https://www.edoeb.admin.ch/edoeb/en/home.html


    Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details provided below. This will not affect the lawfulness of any processing carried out before your withdrawal.


    If you have questions or comments about your privacy rights, you may email us at hello@atxr.co.uk


    9. CONTROLS FOR DO-NOT-TRACK FEATURES


    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.


    10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?


    In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.


    California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

    If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).


    11. DO WE MAKE UPDATES TO THIS NOTICE?


    In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.


    12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


    If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Anna Burke, by email at anna@atxr.co.uk 


    If you are a resident in the United Kingdom, the 'data controller' of your personal information is ATXR Ltd. ATXR Ltd has appointed Anna Burke to be its representative in the UK. You can contact them directly regarding the processing of your information by ATXR Ltd, by email at anna@atxr.co.uk by visiting atxr.co.uk



    13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?


    Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email at Anna@atxr.co.uk

    Copyright © 2026 ATXR - Immersive training & experiences for industry - All Rights Reserved.

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