PRIVACY POLICY – VRAINERS APP

We would like to describe how we process the personal data (Data) that we collect for the purpose of using the Vrainers App (App) and browsing our website (Site), and what your rights are.

This privacy policy is made in accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR). Vrainers undertakes to process your Data in accordance with the applicable European and Italian regulations.

Who processes your data?

The Data Controller is Vrainers, with registered office in Cisterna di Latina (LT), Italy. You can contact us at any time by writing to: info@matteozaralli.com

What kind of data do we process?

· NAVIGATION DATA, such as IP addresses, domain names of the computers used by users, etc. These data are collected automatically and exclusively for enabling navigation on the site and, in anonymous form, may be used for statistical surveys.

· DATA VOLUNTARILY PROVIDED BY YOU, such as your name, surname, and contact details, is required to use the services offered by the App/Site. The optional, explicit, and voluntary sending of messages to our email address involves the acquisition of contact data necessary to reply. To keep your personal data for the purpose of sending further communications, we will obtain your free and explicit consent, which you can withdraw at any time by writing to info@matteozaralli.com.

· VOICE DATA The use of the App's services involves the recording of your voice. Each recording is stored only until the next use of the App's services. All previous recordings are permanently deleted.

· META PLATFORM DATA (USER_ID and USER_PROFILE) When you access the App through the Meta Quest platform, we collect the following data provided by Meta's Platform Features:

• USER_ID: a unique identifier associated with your Meta account, used to authenticate your session, save your progress, and associate your data with your account across uses of the App.

• USER_PROFILE: basic profile information (such as your display name and avatar) provided by Meta, used to personalize your in-app experience.

This data is collected solely for the purposes described above and is not sold or shared with third parties for marketing or advertising purposes.

Why do we process your data?

• Navigation data: to allow Site navigation and obtain anonymous statistics.

• Contact data: to respond to your requests and, with your consent, send communications about our services.

• Voice data: to provide the App's core voice-based functionality.

• META USER_ID and USER_PROFILE: to authenticate users, personalize the experience, and maintain session continuity within the App.

To whom do we disclose your data?

In order to offer our Services, we may share your Data with carefully selected third-party processors who are required to comply with this Privacy Policy. Data may also be accessed by members of the Vrainers team, acting under the authority of the Data Controller and only on their instructions.

Data may be transferred outside the European Union only when necessary for the purposes outlined in this notice and only where the receiving country provides adequate safeguards in accordance with Articles 46, 47, or 49 of the GDPR.

How long do we store your data?

Data is stored for as long as necessary to fulfill the purposes described in this policy or as required by law. Data processed on the basis of your consent will be stored until you withdraw it, and in any case for no longer than 24 months. Voice recordings are deleted immediately after each new use of the App. Meta USER_ID and USER_PROFILE data is retained only for the duration of your active use of the App and deleted upon account deletion request.

How to request the deletion of your data

You have the right to request the deletion of your personal data at any time, including your Meta USER_ID and USER_PROFILE data collected through the App.

To submit a data deletion request, please contact us at info@matteozaralli.com with the subject line: "Data Deletion Request – Vrainers App"

We will process your request within 30 days and confirm deletion by reply email.

What are your rights?

You may at any time exercise your rights under Articles 15 et seq. of the GDPR, including: access, rectification, deletion, restriction of processing, objection, and data portability.

To exercise your rights, contact: info@matteozaralli.com

You may also lodge a complaint with the Italian Data Protection Authority: https://www.garanteprivacy.it/

Changes to the Privacy Policy

We may modify this Privacy Policy at any time, including in response to legal updates. Changes will be effective upon publication on the Site/App. We invite you to check this section regularly.

The App/Site may contain links to third-party sites; please refer to their respective privacy policies for information on how they handle your data, including Meta's Privacy Policy: https://www.meta.com/legal/privacy-policy/

Last update: April 2026