Operated by XR Academia · Last updated: 15 October 2026
1. Introduction
This Privacy Policy explains how XR Academia (“we,” “us,” or “our”) handles personal information in connection with the Justin Beavercito virtual reality educational experience (the “Game”), our website, and related services.
Justin Beavercito is an educational virtual reality experience focused on climate change, biodiversity, environmental awareness, and learning through immersive interaction. The Game is designed for users aged 13 and older, subject to applicable platform requirements and local laws.
Justin Beavercito does not collect or store players' personal data or gameplay data in a database operated by XR Academia. Players do not need to create an account or provide personal information to play the Game.
This Privacy Policy also explains how information may be handled when users contact XR Academia separately, purchase institutional licences, or use our website.
Information independently processed by Meta or other platform providers is subject to their own privacy policies and terms.
2. Data Controller and Contact Information
The organisation responsible for the personal data processing described in this Privacy Policy is:
Organisation: XR Academia
Email: xracademia@gmail.com
Website: https://www.xracademia.com
For privacy questions, requests to access or correct personal data, or requests to delete personal data, please contact us using the email address above.
Where required by applicable law, the formal identity and address of the legal entity responsible for processing will be provided in the relevant legal and contractual documentation.
3. Age Requirements
Justin Beavercito is designed for users aged 13 and older.
Users must also meet the minimum age and eligibility requirements imposed by Meta, the relevant application platform, and applicable national laws. If an applicable rule establishes a higher minimum age, that higher minimum age applies.
We do not knowingly seek to collect personal information from children below the applicable minimum age. If we become aware that personal information has been collected unlawfully from a child, we will take appropriate steps to address the situation, including deletion where required by law.
Schools, teachers, parents, and guardians are responsible for ensuring that students are permitted to use the Game under applicable rules and that any necessary permissions are obtained.
4. Personal Data and Information Collection
Justin Beavercito does not collect or store players' personal data or gameplay data in a database operated by XR Academia.
The Game does not maintain player accounts, user profiles, personal progress records, scores, or a database of players' activities.
Players are not required to provide their names, email addresses, or other personal information to play the Game.
If users contact XR Academia separately by email or through other communication channels, we may process the information they voluntarily provide to respond to enquiries, provide support, or manage institutional licensing arrangements. This information is handled separately from gameplay.
5. Gameplay Data and Storage
Justin Beavercito does not store players' gameplay data, learning progress, scores, or activity histories in a database operated by XR Academia.
The Game does not maintain individual player profiles or records of players' in-game activities.
This statement concerns information stored by the Game and XR Academia. It does not mean that the Meta Quest device, the Meta platform, or the operating system never processes technical information independently.
If a future version of the Game introduces data storage, individual learning records, player accounts, or other personal data processing, this Privacy Policy will be updated as appropriate.
6. Device and Technical Information
The Game runs in a virtual reality environment using compatible hardware and software.
The device or platform may process technical information necessary for the operation of the headset, controllers, hand tracking, spatial interaction, application functionality, security, or troubleshooting.
XR Academia does not claim ownership of or access to device information merely because the Game runs on a VR headset.
Any technical, diagnostic, account, or usage information independently collected by Meta or another platform provider is subject to that provider's own privacy policy and terms.
If technical information is made available to XR Academia through a third-party service in the future, the relevant data practices will be assessed and disclosed as required by law.
7. Virtual Reality, Hand Tracking, and Sensor Information
Depending on the hardware and features enabled, the VR device may process information associated with movement, controller input, hand tracking, spatial interaction, or other device capabilities.
The fact that a VR device processes sensor information does not necessarily mean that XR Academia receives or stores that information.
XR Academia does not maintain a database of players' movements, hand-tracking records, or gameplay interactions.
Any information independently processed by Meta or another platform provider is governed by that provider's applicable privacy documentation and settings.
8. Camera, Microphone, Eye Tracking, and Biometric Information
XR Academia does not intentionally collect or store players' camera recordings, microphone recordings, eye-tracking information, or biometric data through the Game.
This statement does not cover information that the device or platform may independently process to provide hardware, operating-system, or platform functionality.
If future versions of the Game introduce features that require additional personal data processing, XR Academia will assess the applicable legal and platform requirements and update this Privacy Policy where appropriate before introducing those practices.
9. Purposes of Processing
Because Justin Beavercito does not collect or store players' personal data or gameplay data in a database operated by XR Academia, we do not use such stored player data for profiling, individual tracking, or behavioural advertising through the Game.
XR Academia may process information provided voluntarily through separate communications, such as emails about technical support, school subscriptions, institutional licences, or business enquiries.
Such information may be used to:
- Respond to questions and enquiries.
- Provide customer or technical support.
- Manage institutional subscriptions and licences.
- Process payments and invoices where applicable.
- Communicate important contractual or service updates.
- Maintain appropriate business records.
- Comply with applicable legal obligations.
- Establish, exercise, or defend legal claims where necessary.
We will not use information for purposes incompatible with those disclosed here unless permitted by applicable law and, where required, after providing additional information or obtaining consent.
10. Legal Bases Under the GDPR
Where the General Data Protection Regulation (GDPR) applies, XR Academia relies on the legal basis appropriate to each processing activity.
Depending on the circumstances, these legal bases may include:
Contract: Processing necessary to provide a service, manage an institutional subscription, or fulfil contractual obligations.
Legal obligation: Processing required to comply with applicable laws, including accounting and tax requirements.
Legitimate interests: Processing necessary for legitimate business interests, such as responding to business enquiries, maintaining service security, or managing records, provided those interests are not overridden by individuals' rights.
Consent: Processing based on consent where consent is legally required, including certain optional communications or optional data-processing features.
Where processing relies on consent, consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
11. School and Institutional Subscriptions
Schools and educational institutions may contact XR Academia to purchase or manage access to the Game.
For these arrangements, XR Academia may process professional contact details, institution information, licence details, subscription dates, billing information, and communications required to administer the subscription.
Institutional subscriptions are valid for one year, unless expressly agreed otherwise in writing.
After the subscription expires, the school or institution must purchase a new annual subscription or complete the applicable renewal process to continue using the Game under that licence.
An annual subscription does not grant perpetual access or ownership of the Game.
The institution is responsible for managing its subscription, complying with the licence terms, and ensuring that access is used only while authorised.
The Game does not maintain individual player records as part of the institutional subscription. Any information needed to administer the subscription is handled separately from gameplay.
12. Licence Restrictions and Non-Commercial Use
The licence granted to a school or educational institution permits use of Justin Beavercito for authorised educational purposes during the applicable subscription period.
The institutional licence does not authorise commercial exploitation of the Game.
Unless XR Academia has granted separate written authorisation, the institution may not:
- Resell, rent, lease, or sublicense the Game.
- Commercially distribute copies of the Game.
- Sell or charge third parties for standalone access to the Game.
- Use the Game as part of an unauthorised commercial service.
- Transfer the licence to another organisation.
- Copy, modify, redistribute, or exploit the Game beyond the rights expressly granted under the applicable licence.
The institution may use the Game for its intended educational activities, subject to the applicable licence terms.
All intellectual property rights not expressly granted remain with their respective rights holders.
Renewal, subscription pricing, the number of authorised devices, and any other specific commercial terms are governed by the applicable purchase agreement or institutional licence.
13. Meta and Other Platform Providers
If the Game is distributed or accessed through Meta or another third-party platform, that platform may independently collect and process information under its own privacy policy, terms, permissions, and settings.
Although Justin Beavercito does not store players' personal data or gameplay data in a database operated by XR Academia, Meta may independently process device, account, technical, diagnostic, or usage information.
XR Academia does not control every aspect of data processing carried out independently by Meta or other providers.
Users should review the relevant platform privacy documentation to understand what information the platform processes, how it uses that information, and how to exercise rights relating to data held by the platform.
A request sent to XR Academia covers information for which XR Academia is responsible. Separate requests may be necessary for information held independently by Meta or another provider.
14. Third-Party Service Providers
XR Academia may use third-party service providers to operate its website, communicate with customers, manage institutional subscriptions, process payments, or provide other business services.
Depending on the services actually used, these providers may include:
- Website hosting providers.
- Email and communications providers.
- Payment and invoicing providers.
- Technical hosting or storage providers.
- Application distribution and platform providers.
- Technical support providers.
The use of a third-party provider does not mean that the Game collects or stores players' gameplay data.
Where a provider processes personal information on behalf of XR Academia, we will take appropriate steps to ensure that suitable contractual and security arrangements are in place where required by law.
The specific providers used should be documented and disclosed where required.
15. Website, Email, and Communications
When you contact XR Academia by email or through our website, we may process the information you provide to respond to your message, manage your request, maintain relevant records, and follow up where appropriate.
This information is provided voluntarily and is separate from gameplay.
Our website may use cookies or similar technologies depending on its configuration. Any optional newsletter or marketing communications will be handled in accordance with applicable law.
Where consent is required, it will be requested before sending marketing communications or activating optional tracking technologies. Users will be provided with a way to unsubscribe from marketing emails where applicable.
The privacy practices of our website may differ from those of the Game.
16. Advertising and Sale of Personal Information
We do not sell personal information to third parties.
We do not use personal data stored by the Game for targeted advertising to players, because the Game does not maintain a database of players' personal data or gameplay data operated by XR Academia.
We do not intend to use personal information obtained through the Game for targeted advertising to children.
If advertising, analytics, or optional tracking technologies are introduced in the future, we will assess applicable platform rules and legal requirements and update our disclosures and consent mechanisms where necessary.
17. Educational and Research Activities
Justin Beavercito is an educational experience focused on climate change, biodiversity, environmental awareness, and immersive learning.
Use of the Game does not automatically constitute consent to participate in a research study.
Any separate research project, classroom evaluation, or formal study involving personal information must have an appropriate purpose and legal basis. Where required, participants, parents or guardians, schools, and institutions will receive additional information and any necessary consent or authorisation will be obtained.
Where educational outcomes can be evaluated using anonymised or aggregated information, we will consider those approaches where appropriate.
The Game itself does not maintain individual learning records in a database operated by XR Academia.
18. Children and Teenagers
The Game is designed for users aged 13 and older, subject to any higher minimum age imposed by applicable law or the platform.
We recognise that children and teenagers may require additional privacy protection. We aim to limit personal information to what is reasonably necessary for the relevant purpose.
The Game does not require players to provide personal information to play and does not maintain a database of players' personal data or gameplay activities operated by XR Academia.
Schools, teachers, parents, and guardians should ensure that use of the Game is appropriate for the student and complies with applicable laws, platform rules, and institutional policies.
If a parent, guardian, school, or user has a privacy concern, they may contact us at xracademia@gmail.com.
19. Sharing Personal Information
XR Academia does not share players' gameplay records with third parties because the Game does not maintain a database of such records operated by XR Academia.
Information voluntarily provided through separate communications or institutional subscription arrangements may be shared where appropriate and lawful, including:
- With service providers supporting our business operations.
- With a school or institution where necessary to administer its subscription or respond to an authorised request.
- With payment or invoicing providers where applicable.
- With professional advisers where necessary.
- With public authorities where required by law.
- In connection with a business transfer or restructuring, subject to applicable legal safeguards.
Any sharing must have an appropriate purpose and legal basis.
Meta or other platform providers may independently process information under their own terms and privacy policies.
20. Data Retention
Justin Beavercito does not store players' personal data or gameplay data in a database operated by XR Academia.
Information voluntarily provided through separate emails, support requests, or institutional subscription arrangements may be retained for as long as reasonably necessary to respond to the request, administer the contract, comply with legal obligations, or resolve disputes.
For example:
- Support correspondence may be retained for the time needed to resolve an enquiry and maintain appropriate records.
- Subscription and invoicing information may be retained for the duration of the business relationship and any legally required accounting or tax period.
- Other business communications may be retained for a period justified by their purpose or by legal obligations.
When information is no longer required, XR Academia will take appropriate steps to delete it or anonymise it, subject to applicable legal retention requirements.
21. Your Data Protection Rights
Where the GDPR or other applicable data protection law applies, you may have the right to:
- Request access to your personal information.
- Request correction of inaccurate or incomplete information.
- Request deletion of personal information.
- Request restriction of processing.
- Object to certain processing activities.
- Request data portability where applicable.
- Withdraw consent where processing relies on consent.
- Lodge a complaint with a competent data protection authority.
These rights are subject to applicable legal conditions and exceptions.
To exercise your rights, contact xracademia@gmail.com. We may need to verify your identity before responding to a request.
Because the Game does not maintain a database of players' personal data or gameplay data, there may be no player records held by XR Academia to access, correct, or delete.
22. How to Request Data Deletion
To request deletion of personal information held by XR Academia, email:
Email: xracademia@gmail.com
Subject: Data Deletion Request – Justin Beavercito
Please describe the information you want deleted and provide enough information for us to identify the relevant records. Do not include unnecessary sensitive information in your request.
Because Justin Beavercito does not maintain a database of players' personal data or gameplay data, XR Academia generally has no gameplay records to delete.
If you have contacted XR Academia by email or provided personal information in connection with a support request, school subscription, institutional licence, or other communication, you may request deletion of that information where applicable law permits.
We will review and respond to the request in accordance with applicable data protection law. Certain information may need to be retained where required by law or necessary to establish, exercise, or defend legal claims.
To request deletion of information held independently by Meta or another platform provider, you must contact that provider directly.
23. Information Security
We take reasonable technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse, alteration, or disclosure.
The measures appropriate to a particular service depend on the type of information processed, the systems involved, and the risks associated with the processing.
No system can be guaranteed to be completely secure. We will respond to security incidents in accordance with applicable legal obligations.
24. International Data Transfers
XR Academia may work with service providers or platforms that process information in countries other than the country in which the user is located.
Where the GDPR applies and personal information is transferred outside the European Economic Area, we will implement an appropriate transfer mechanism and safeguards where required by law.
These safeguards may include an adequacy decision, standard contractual clauses, or another legally recognised mechanism, depending on the circumstances.
This section applies to personal information processed through separate communications, institutional subscriptions, our website, or other relevant services. It does not mean that the Game stores or transfers gameplay data.
25. Cookies and Similar Website Technologies
Our website may use cookies or similar technologies to support essential functionality, remember preferences, understand website performance, or provide other features.
The technologies used depend on the website's actual configuration.
Where consent is required for optional cookies or tracking technologies, we will seek consent before activating them. Users may also be able to manage their preferences through the relevant website settings or browser controls.
This section concerns the website and does not automatically describe the data processing performed by Meta or by the Game itself.
26. Third-Party Links
Our website or communications may contain links to third-party websites or services.
We are not responsible for the privacy practices, content, or security of websites and services operated by others. Users should review the privacy notices of those providers before submitting personal information.
27. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in the Game, our services, applicable law, or platform requirements.
The latest version will be published on our designated public privacy-policy webpage, with the updated date shown at the beginning of the document.
We will maintain a publicly accessible privacy policy for as long as required by applicable law and platform rules while the Game is available.
The policy must accurately describe the Game's actual data practices and remain consistent with applicable Meta terms and requirements. Where requested, we will make the relevant policy available to platform reviewers.
If a material change requires notice or consent under applicable law, we will take the appropriate steps.
28. Complaints and Supervisory Authority
If you believe that your personal information has been processed in violation of applicable data protection law, you may contact us first at xracademia@gmail.com.
Where the GDPR applies, you also have the right to lodge a complaint with a competent supervisory authority.
In the Netherlands, the supervisory authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
https://autoriteitpersoonsgegevens.nl
29. Contact Us
For questions about this Privacy Policy, the processing of personal information, or requests to access, correct, or delete personal information, contact:
Organisation: XR Academia
Email: xracademia@gmail.com
Website: https://www.xracademia.com
For deletion requests, please use the subject line:
Data Deletion Request – Justin Beavercito
© 2026 XR Academia. All rights reserved.