Privacy Policy

SENSIBALLVR

PRIVACY POLICY

Privacy Policy

Last Update:June 2026
Version:v3.0

This Privacy Policy (“Policy”):

• www.sensiballvr.com
• SENSIBALLVR platforms
• VR systems
• mobile applications
• web services
• digital training systems
• associated services

It has been prepared to explain how personal data is collected, processed, stored and protected.

SENSIBALLVR:

• user privacy,
• data security,
• protection of child users,
• international data protection standards

aims to care.

This Policy:

• KVKK,
• GDPR,
• applicable international data protection regulations

has been prepared taking into account.

1. DATA CONTROLLER

SensiballVR ARGE A.Ş.

Address:
Yeşiltepe Mah. İsmet İnönü 2 Cad. No:2/57
Tepebaşı / Eskişehir / Türkiye

Website:
SensiballVR

Email:
info@sensiballvr.com

(Hereinafter referred to as “SENSIBALLVR”, “Company” or “We”).

2. WHAT DATA DO WE COLLECT?

SENSIBALLVR may collect and process the following categories of data.

2.1 Account and User Information

• name,
• surname,
• user name,
• date of birth,
• age category,
• team information,
• country information,
• email address,
• account information.

2.2 Performance and Usage Data

The platform can process the following performance data:

• cognitive test results,
• reaction performance,
• benchmark results,
• ranking data,
• training results,
• usage statistics,
• developmental analyses,
• VR usage data.

2.3 Technical Data

• IP address,
• device information,
• operating system information,
• browser information,
• login records,
• session information,
• technical logs,
• security logs,
• error logs.

2.4 Payment Data

Payments can be made via the following methods:

• online payment systems,
• bank transfer,
• third party payment providers.

Card information:
may not be stored directly on SENSIBALLVR systems.

Payment transactions:
may be managed by the relevant payment providers.

2.5 Child User Data

Platform:
It can be used by users under 18 years of age.

Because:

• child user data,
• young athlete performance data
  can be processed.

These data:
protected with additional precision.

3. FOR WHAT PURPOSES DO WE PROCESS DATA?

Personal data may be processed for the following purposes:

• creating a user account,
• providing platform access,
• Providing VR training services,
• performance analysis,
• benchmark systems,
• ranking systems,
• user experience development,
• providing technical support,
• security management,
• fraud prevention,
• subscription management,
• payment transactions,
• organization management,
• technical development processes.

4. LEGAL BASIS

Personal data may be processed based on the following legal bases:

• performance of the contract,
• express consent,
• parent/legal representative approval,
• legitimate interest,
• legal obligations.

5. CHILDREN'S PRIVACY

SENSIBALLVR:

It is a platform that can work with young athletes and child users.

Because:

• parental approval,
• guardian consent,
• child safeguarding processes
  applicable.

Child user data:
It is protected with special care.

SENSIBALLVR:
does not use child user data for advertising profiling purposes.

6. AUTOMATED DECISION MAKING AND PROFILING

Platform:

• ranking,
• benchmark,
• performance analysis
  can offer.

However:
SENSIBALLVR:

• behavioral advertising profiling,
• automatic legal decision making,
• ad targeting systems
  It does not apply.

Platform:

• selection of professional athletes,
• official license evaluation,
• legal decision mechanism
  It is not used as.

7. BIOMETRIC AND EYE TRACKING

Currently platform:

• face recognition,
• biometric identification,
• emotion recognition,
• eye tracking analytics
  does not use.

In the future:

• eye tracking,
• advanced analysis systems,
• new performance technologies
  can be offered.

Some new features:
may require additional user approval.

8. THIRD PARTY HARDWARE AND VR ECOSYSTEM

SENSIBALLVR:

Third party hardware and infrastructures may be used within the scope of VR training and performance systems.

In this context:

• HTC Vive,
• Vive Business products,
• Vive XR systems,
• associated VR hardware

available.

Users:
The respective hardware manufacturers themselves:

• privacy policies,
• terms of use,
• security documents,
• technical requirements

accepts that it could happen.

Official documentation regarding HTC Vive:

• HTC Vive Business Legal Information
• HTC Privacy Policy
• HTC Security & Privacy Whitepaper

SENSIBALLVR:

third-party hardware manufacturers:

• independent data processing activities,
• device manufacturing errors,
• from firmware or system updates,
• from third-party service interruptions

is not directly responsible.

9. THIRD PARTY SERVICES

The Platform may use the following third-party services:

• authentication services,
• payment providers,
• cloud infrastructures,
• hosting services,
• technical infrastructure providers.

These services:
may have their own privacy policies.

10. HOSTING AND DATA STORAGE

SENSIBALLVR infrastructure:

• cloud systems,
• secure server infrastructures,
• international hosting providers
  can use.

Servers:
It may be hosted within the European Economic Area (EEA) or in regions that comply with applicable data protection standards.

11. COOKIES AND ANALYTICS

Website:

• essential system cookies,
• security cookies,
• session management cookies,
• performance analytics tools
  can use.

Detailed information:
It may be disclosed within the scope of Cookie Policy.

12. ADVERTISING AND MARKETING

SENSIBALLVR currently:

• third party advertising SDK,
• behavioral advertising systems,
• advertising profiling infrastructures

does not use.

User data:
It is not used for advertising profiling purposes.

13. PHOTOS AND MEDIA CONTENT

User images:
It can only be used with the necessary permissions.

Child user photos and videos:
may be subject to separate parental approval processes.

14. WITH WHOM CAN WE SHARE DATA?

Data may be shared with the following parties:

• clubs,
• organization managers,
• coach accounts,
• technical service providers,
• payment systems,
• cloud infrastructure providers,
• regional distributors,
• commercial partners,
• official authorities (in case of legal obligation).

Data:
shared only to the extent necessary.

15. DISTRIBUTORS AND COMMERCIAL PARTNERS

Some services:

• distributors,
• regional partners,
• commercial representatives,
• local organizations

can be provided through.

These partners:
can only have necessary operational access.

Independent data ownership is not granted.

16. HOW LONG DO WE KEEP DATA?

Personal data:

• As long as the account is active,
• within the scope of operational requirements,
• in line with security obligations
  can be stored.

Some records:

• fraud prevention,
• security,
• legal obligations
  It can be kept for a longer time due to

17. ACCOUNT DELETION

Users:
may delete their account or request deletion.

After deletion:

• access can be removed,
• personal data may be deleted,
• Some data may be anonymized.

But some technical records:

• security,
• accounting,
• fraud prevention,
• legal obligations
  It can be stored for a certain period of time due to

18. USER RIGHTS

Users may have the following rights:

• access request,
• correction request,
• request for deletion,
• data portability,
• objection to the processing,
• withdrawal of consent.

These demands:
It is evaluated within the scope of applicable data protection legislation.

19. SAFETY PRECAUTIONS

SENSIBALLVR may implement the following security measures:

• TLS encryption,
• AES-256 encryption,
• role-based access control,
• security logs,
• access restrictions,
• technical security measures,
• internal NDA processes,
• incident response procedures.

20. VR SAFETY WARNING

VR usage:

• dizziness,
• motion sickness,
• loss of balance,
• risk of physical impact,
• eye fatigue,
• neurological sensitivities

can create.

Users:

• must provide a safe usage area,
• should remove environmental barriers,
• should check physical security,
• must comply with the device manufacturer's safety instructions.

Recommended minimum usage area:

2.5m x 2.5m

Additional security and privacy information for HTC Vive devices may be included in the relevant manufacturer's documentation.

21. HEALTH AND NEUROLOGICAL WARNINGS

SENSIBALLVR:

• medical diagnosis,
• healthcare,
• clinical evaluation
  does not offer.

Cautious use is recommended in the following cases:

• epilepsy,
• neurological sensitivities,
• serious balance problems,
• motion sensitivity.

22. SERVICE INTERRUPTIONS

Platform:

• care,
• security updates,
• technical improvements,
• infrastructure works
  may experience temporary interruptions due to

Uninterrupted service is not guaranteed.

23. INTELLECTUAL PROPERTY

Platform belongs:

• software,
• benchmark systems,
• ranking systems,
• VR scenarios,
• algorithms,
• analysis systems,
• contents

It is the property of SENSIBALLVR.

24. INTERNATIONAL USE

SENSIBALLVR:
Can work with international users, clubs and partners.

Some services:
may be provided through regional distributors or commercial partners.

25. POLICY UPDATES

SENSIBALLVR:
This Policy:

• technical developments,
• new features,
• legislative changes,
• operational needs

can update accordingly.

26. COMMUNICATION

For data protection or privacy issues you can contact us:

Email:
info@sensiballvr.com

Website:
SensiballVR Website

27. ENFORCEMENT

This Privacy Policy:
It enters into force on the date of publication.