Privacy Policy

Boldly-XR B.V.

Last updated: March 2026

Boldly-XR B.V. (“Boldly-XR”, “we”, “us”, or “our”) is an immersive technology studio based in Breda, the Netherlands. We create and produce immersive experiences for our clients across a wide range of industries.

We take your privacy seriously. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have under the General Data Protection Regulation (GDPR) and Dutch implementing legislation (UAVG).

This policy applies to:

  • Visitors to our website (boldly-xr.com)
  • Prospective and current clients who contact us or engage our services
  • End-users of XR experiences or interactive installations we deploy on behalf of our clients
  • Subscribers to our XR community newsletter ‘Wonderland’
  • Job applicants

1. Identity & Contact Details

Data Controller:

  • Boldly-XR B.V.
  • Breda, The Netherlands
  • Website: boldly-xr.com
  • Email for privacy matters: quality@boldly-xr.com

If you have any questions about this policy or wish to exercise your rights, please contact us at the email address above.

2. Legal Bases for Processing

We only process personal data when we have a valid legal basis to do so under the GDPR. We rely on the following bases:

  • Consent (Art. 6(1)(a) GDPR) — for example, when you fill in our contact form, subscribe to newsletter Wonderland or opt in to marketing communications
  • Performance of a contract (Art. 6(1)(b) GDPR) — to deliver the services you have engaged us for
  • Legal obligation (Art. 6(1)(c) GDPR) — to comply with Dutch law, tax regulations, and other applicable legislation
  • Legitimate interests (Art. 6(1)(f) GDPR) — for example, to improve our website, respond to enquiries, and develop our business, where these interests are not overridden by your rights

3. Data we collect and why

3.1 Website visitors

When you visit our website, we may automatically collect:

  • IP address (anonymised where possible)
  • Browser type and device information
  • Pages visited and time spent (via analytics tools)

This data is used solely to understand how our website is used and to improve it. We do not use invasive advertising trackers.

3.2 Contact & business enquiries

When you reach out to us via the contact form, email, or phone, we collect:

  • Name and job title
  • Company name
  • Email address and phone number
  • The content of your message

We use this information to respond to your enquiry, follow up on potential projects, and manage our client relationships.

3.3 Client engagements

To deliver our services (AR/VR/XR experiences, interactive installations, training simulations, etc.), we may process:

  • Contact and billing details
  • Project briefs, assets, and technical requirements provided by the client
  • Usage data from deployed XR experiences (e.g., session logs, device telemetry)  only where agreed with the client and disclosed to end-users

3.4 End-users of our experiences

When Boldly-XR deploys immersive experiences or interactive installations on behalf of a client at events, in showrooms, or in training environments, personal data about end-users (e.g., usage analytics, biometric headset data) may be collected. In these situations, Boldly-XR typically acts as a data processor on behalf of the client (who acts as data controller). We process such data only on documented instructions from the client and are subject to a data processing agreement (DPA).

Note: XR headsets (such as VR headsets and the Microsoft HoloLens) may capture spatial environment data and, in some configurations, biometric signals. We minimise data collection to what is strictly necessary for the experience to function and do not store this data beyond the session unless explicitly required and disclosed.

3.5 Wonderland newsletter subscribers

If you join our ‘Wonderland’ XR community, we collect your name and email address to send you updates, tips, and trends on AR, VR, AI, and the Metaverse. Consent is obtained at sign-up and can be withdrawn at any time by clicking ‘unsubscribe’ in any email.

3.6 Job applicants

If you apply for a position at Boldly-XR, we collect:

  • CV, cover letter, and portfolio
  • Contact details
  • Any other information you voluntarily include in your application

We retain application data for up to six months after a recruitment process concludes, unless we ask for and receive your consent to keep it longer for future roles.

4. Sharing Personal Data with Third Parties

We do not sell your personal data. We may share it with:

  • Technology partners and subcontractors who help us deliver our services (e.g., hosting providers, 3D platform vendors, analytics tools), under strict data processing agreements
  • Our client if they are the data controller of end-user data collected within an XR experience we built for them
  • Authorities or courts if we are legally required to do so

We use third-party platforms that may involve transfers of personal data outside the European Economic Area (EEA). Where this is the case, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses).

5. Retention Periods

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. Our standard retention periods are:

  • Website analytics data: maximum 14 months
  • Contact/enquiry records: up to 2 years after last contact, or the duration of the client relationship
  • Client project data: up to 7 years for financial records (statutory Dutch requirement); project files as agreed with the client
  • Newsletter subscriber data: for the duration of your subscription plus 6 months
  • Job applicant data: 6 months after process ends (longer only with consent)

When data is no longer needed, it is securely deleted or anonymised.

6. Automated Decision-Making

We do not make decisions about individuals solely on the basis of automated processing that produce legal or similarly significant effects.

7. Your Rights

Under the GDPR you have the following rights:

  • Right of access — to receive a copy of the personal data we hold about you
  • Right to rectification — to have inaccurate or incomplete data corrected
  • Right to erasure (‘right to be forgotten’) — to have your data deleted, subject to legal retention obligations
  • Right to restriction of processing — to ask us to pause processing in certain circumstances
  • Right to data portability — to receive your data in a structured, machine-readable format
  • Right to object — to object to processing based on our legitimate interests
  • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting prior processing

To exercise any of these rights, please contact quality@boldly-xr.com. We aim to respond within 30 days. We may ask you to verify your identity before acting on your request.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

8. Cookies

Our website uses functional and analytical cookies. Functional cookies are necessary for the website to work. Analytical cookies help us understand how visitors use the site — we use these in an anonymised, privacy-friendly manner.

We do not place advertising or tracking cookies without your explicit consent. Where consent is required, you will be asked via a cookie banner when you first visit our website. You can withdraw or change your consent at any time via our cookie settings.

9. Data Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include encrypted data transmission (TLS/HTTPS), access controls, and regular security reviews.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours and, where required, notify affected individuals without undue delay.

10. Children

Our website and commercial services are not directed at children under the age of 16. We do not knowingly collect personal data from minors. Where an XR experience is intended for a younger audience (e.g., an educational installation), we work with the client to ensure appropriate consent and safeguards are in place in accordance with applicable law.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The most current version will always be available on our website. For significant changes, we will notify you by email (where we hold your contact details) or via a prominent notice on our website.

Do you have question or a complaint? Mail us at: quality@boldly-xr.com.