JBA Group Inc. (JBA) trading under SkillsVR (we/us/our) is committed to protecting your personal information. SkillsVR follows the directives from the CCPA (California Consumer Privacy Act), GDPR (General Data Protection Regulation European Union) and Privacy Act 2020 (New Zealand) and this Privacy Policy has been designed to help you understand how and why we collect information from you, how we store it, how you can access and correct that information and when we might disclose information to other people.

This Privacy Policy is relevant when you visit our website, use our services (SkillsVR Enterprise Cloud Solution, SkillsVR Content Creation Kit (CCK), SkillsVR Headset Applications, SkillsVR Provisioning App, SkillsVR Mobile App, EVA (Education Virtual Assistant) and other services supplied by SkillsVR or contact us in any way.

The information we collect depends on which of our applications or services you use:

We may collect:

● Personal and account information such as name, email address, organisation, role, phone number, and general location
● Learning records associated with training activities, such as participation, progress, completion status, and related educational metadata, where applicable
● User communications, including support requests, feedback, queries, and survey responses
● Usage and interaction data relating to how you use our websites, applications, VR experiences, and EVA
● Technical and device information, including application versions, device identifiers, configuration details, and diagnostic data
● Analytics and tracking data to understand usage patterns and improve our services

Service-specific information

● VR solutions and applications: details of VR sessions, session metadata, headset identifiers, firmware and application versions, and locations where sessions are conducted
● Provisioning and headset management: device configuration and deployment information, Application version and related technical data.
● Mobile app: authentication via your SkillsVR account; login credentials are not stored by the mobile app and no additional personal information is collected
● EVA (Education Virtual Assistant): user interaction data (such as questions, prompts, and responses), contextual educational information required to deliver assistance, and usage analytics.

Providing some information is optional. However, if you choose not to provide the required details, we may be unable to register you or provide access to certain services.

How do we use the information we have collected?

We collect your personal information to:


● Verify your identity
● Provide, operate, and improve our services and products, including:
- Allowing users to participate in VR sessions via headset and facilitator applications
- Enabling users to create, manage, and modify VR sessions through the website
- Managing and provisioning hardware devices used to run VR sessions
- Managing user access to VR sessions, EVA, and related educational content
- Delivering AI-powered educational assistance through EVA

● Respond to enquiries, support requests, complaints, and customer care activities
● Communicate with you about updates, features, and service-related notices
● Market our services and products to you, including electronic communications (such as email or text), where permitted by law*
● Bill you and collect payments owed to us
● Protect, enforce, or defend our legal rights and interests
● Comply with legal obligations and applicable privacy laws
● Any other purpose authorised by you or permitted under the Privacy Act


*You will always have the option to unsubscribe from marketing communications.
EVA does not independently make decisions that produce legal or similarly significant effects on users. EVA is designed to support learning and facilitation and does not replace human decision-making.

We securely store your data with trusted third-party cloud service providers.
Data is hosted in the region closest to your location, where possible, and we take reasonable steps to avoid unnecessary cross-regional data transfers while maintaining service reliability and security.

If we have collected personal information about you, we'll take reasonable steps to ensure that the information is stored in a secure environment protected from unauthorised access, modification, or disclosure.

We respect your right to privacy, view, and update the personal information we hold about you.

Where possible, we aim to provide you with access to your personal information and give you ways to update it, except where prohibited by legislation or it affects our business.

In some cases, you may need us to update your information on your behalf. In such instances, we will ask you to verify your identity before we can act on your request.

You can do this by contacting us at one of the addresses described in this policy below.

If you request that your personal information be deleted, we will remove all personally identifiable attributes (name, email address, contact details) from your records, unless we need to retain that information for legitimate business or legal purposes.

If you wish to make a complaint, please contact us. Our contact details are at the end of this Policy. We will acknowledge your complaint within 15 working days and will contact you in an attempt to resolve your complaint.

We may disclose your personal information to another party where the applicable law permits. Such as when the disclosure directly relates to the purpose, we collected it for, the client's instructions, to comply with laws, to enforce our rights, to prevent fraud, and for safety.

Access to personal information is strictly limited to authorised personnel who require it to perform their job duties. We implement technical and organisational controls to maintain confidentiality, prevent unauthorised access, and ensure that staff understand their privacy responsibilities through regular training.

We retain personal information, including EVA (Education Virtual Assistant) interaction data, only for as long as necessary to provide our services, comply with applicable privacy and education laws, resolve disputes, and enforce our agreements. Where our services are used in educational settings, we process personal information only as required to deliver the services or as instructed by the relevant organisation or institution.

When personal information is no longer required, we take reasonable steps to securely delete, anonymise, or de-identify the data in accordance with applicable laws and industry best practices.

Personal information and EVA interaction data are not used to train public or third-party AI models. Any use of data to improve our services is conducted in accordance with this Privacy Policy and applicable privacy laws.

In the event of a privacy breach, we are committed to promptly investigating the incident. If the breach involves a significant risk of harm to individuals, we will notify relevant authorities and affected individuals as required by applicable laws and regulations.

We prioritize the privacy and security of your information by implementing reasonable technology and cybersecurity measures to protect against unauthorized access and ensure data integrity. While we continuously review and improve these measures, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

We use cookies to enhance user experience on our platform. This includes necessary cookies that help the platform function properly. Additionally, on our marketing site, we use cookies from Google Analytics and HotJar to gather anonymized insights on user behaviour and preferences, helping us improve the overall user experience. For more details, please refer to the cookie pop-up displayed on our marketing site.

privacy@skillsvr.com

The Privacy Officer, SkillsVR, Level 3/24 Balfour Road, Parnell, Auckland 1052, New Zealand.

We may change this Privacy Policy from time to time by uploading a new version on the website.