XR4Europe — Privacy Policy
Effective date: 1 August 2026
XR4Europe (“XR4Europe”, “we”, “us” or “our”) is committed to protecting the privacy and personal data of the visitors and registered users of its website (the “Website”). This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have, in accordance with Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) and applicable European data protection law.
By using the Website or registering an account, you acknowledge that you have read and understood this Privacy Policy.
1. Who is responsible for your data (Data Controller)
XR4Europe is the data controller responsible for the personal data collected through the Website.
XR4Europe
Registered address: Avenue des Arts 56, 1000 Brussels, Belgium
Contact: contact@xr4europe.eu
Data Protection contact: Michael Barngover, Managing Director
2. What personal data we collect
We collect personal data only to the extent necessary for the purposes described in this Policy. Depending on how you interact with the Website, this may include:
- Browsing data: general, non-identifying visit data generated by your use of the public pages of the Website.
- Account registration data: name, email address, company/organisation, and country, provided when you create a free membership account.
- Newsletter opt-in status: a record of whether you have chosen to subscribe to our newsletter.
- Correspondence: any information you provide when you contact us directly (e.g. by email).
We do not knowingly collect any special categories of personal data (e.g. health, political opinions, religious beliefs) through the Website, and we ask that you do not submit such data to us.
3. Why we collect and use your data
We use the personal data described above for the following purposes:
- To create and manage your free membership account and give you access to exclusive, members-only areas and resources of the Website.
- To contact you for administrative reasons relating to your membership, your account, or your access to the Website, including account confirmation, password resets, technical notices, and important changes affecting your membership or access.
- To provide the information and communication services associated with XR4Europe membership, including occasional communications concerning important industry news, policy and regulatory developments, XR4Europe activities, opportunities, and other matters relevant to members. These communications may be sent independently of the routine newsletter where appropriate.
- To send you our routine newsletter via Mailchimp, but only if you have expressly opted in to receive it.
- To maintain the security, integrity, and proper technical functioning of the Website.
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.
4. Legal basis for processing
We rely on the following legal bases under Article 6 GDPR:
- Consent (Art. 6(1)(a) GDPR): to subscribe you to XR4Europe’s routine newsletter distributed through Mailchimp. Newsletter subscription is optional, is not required for membership, and consent may be withdrawn at any time.
- Performance of a contract or requested service (Art. 6(1)(b) GDPR): to create and administer your membership account, provide access to member resources, and carry out processing necessary to provide the membership service you have requested.
- Legitimate interests (Art. 6(1)(f) GDPR): to operate and secure the Website; administer and develop XR4Europe’s membership services; and communicate important industry, policy, organisational, and other developments that are reasonably relevant to XR4Europe members and form part of the expected membership service. In relying on legitimate interests, XR4Europe considers the nature, necessity, and proportionality of the processing, as well as the reasonable expectations and rights of its members.
5. Sharing of your data with third parties
We do not sell, rent, or trade your personal data. We do not share registrant data with third parties, except in the following limited cases:
- Mailchimp: if you opt in to our newsletter, your name and email address are shared with Mailchimp (operated by The Rocket Science Group LLC / Intuit Inc.), the third-party platform we use to manage and send our newsletter. Should XR4Europe change newsletter provider in the future, your data would be transferred to that new provider under equivalent safeguards, and this Policy would be updated accordingly.
- Website hosting provider: your account and registration data may be accessible to Sat-lit (https://sat-lit.be/), our website hosting provider, solely as necessary to host, maintain, and secure the Website and its underlying database.
Any such third-party provider acts as a data processor on our behalf and is bound by a data processing agreement requiring it to protect your data and to process it only for the purposes we specify, in accordance with Article 28 GDPR.
Within XR4Europe itself, access to your registration data is restricted to members of the executive team responsible for managing the Website and membership. We may also disclose personal data where required by law, regulation, or a valid legal request from a public authority.
6. International data transfers
Where a service provider such as Mailchimp processes personal data outside the European Economic Area (EEA), we ensure that an adequate level of protection is in place, such as the European Commission’s Standard Contractual Clauses or another valid transfer mechanism recognised under GDPR.
7. Data retention
We retain your account and registration data for as long as your membership account remains active, and for a reasonable period thereafter to comply with our legal obligations, resolve disputes, and enforce our agreements. If you withdraw your newsletter consent, we stop sending you the newsletter and, where you request it, remove your data from Mailchimp, while we may retain a minimal record of your consent history as required to demonstrate compliance. You may request deletion of your account and associated data at any time, as described in Section 8.
8. Your rights under GDPR
Subject to the conditions set out in the GDPR, you have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate or incomplete data;
- Erase your data (‘right to be forgotten’), including closing your account;
- Restrict or object to the processing of your data;
- Data portability, i.e. to receive your data in a structured, commonly used, machine-readable format;
- Withdraw your consent at any time, in particular your newsletter opt-in, without affecting the lawfulness of processing carried out before withdrawal;
- Lodge a complaint with your national data protection supervisory authority.
You may unsubscribe from the newsletter at any time using the “unsubscribe” link included in every Mailchimp email, or by contacting us directly. To exercise any other right listed above, please contact us at contact@xr4europe.eu.
9. Data security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration, taking into account the nature of the data and the risks involved. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Cookies
The Website may use essential cookies necessary for its technical operation, and, where applicable, analytics or functional cookies. Where required by law, we will request your consent for non-essential cookies through a dedicated cookie banner or settings tool at the time of your visit.
11. Children's privacy
The Website and its membership services are not directed at children. We do not knowingly collect personal data from individuals under the age of 16. If you believe a child has provided us with personal data, please contact us so that we can delete it.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, our use of third-party providers, or legal requirements. The updated version will be posted on this page with a revised effective date. We encourage you to review this Policy periodically.
13. Contact us
If you have any questions about this Privacy Policy or how we handle your personal data, or if you wish to exercise any of your rights, please contact us at:
XR4Europe
Avenue des Arts 56, 1000 Brussels, Belgium
contact@xr4europe.eu
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