VIVE — Privacy Policy

Effective date: 1 August 2026

This Privacy Policy explains how personal data is collected, used, and protected on the website of the VIVE project (the “Website”), in accordance with Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) and applicable European data protection law.

VIVE is a project funded by the European Union’s Horizon Europe research and innovation programme (Grant Agreement No. 101297780). XR4Europe acts as the communications partner of the VIVE consortium and, in this capacity, operates the Website and its newsletter, and manages the data described in this Policy.

Personal data is collected through the two channels: the contact form and the newsletter sign-up. By submitting the contact form or subscribing to the newsletter, you acknowledge that you have read and understood this Privacy Policy.

1. Who is responsible for your data (Data Controller)

XR4Europe, acting as the communications partner of the VIVE project, is the data controller responsible for the personal data collected through the Website.
  Registered address: Avenue des Arts 56, 1000 Brussels, Belgium
  Contact: contact@xr4europe.eu
  Data Protection contact: Michael Barngover, Managing Director, XR4Europe

2. What personal data we collect

We collect personal data only through the following two channels, and only to the extent you choose to provide it:

  • Contact form: when you use the Website’s contact form to send a message to the project, we collect your name, email address, and the content of your message, together with any other information you choose to include.
  • Newsletter sign-up: if you subscribe to the project newsletter, we collect your email address (and, where requested, your name) via our newsletter platform, Mailchimp.

We do not collect personal data through account registration, as the Website has no membership or login functionality. We do not knowingly collect any special categories of personal data (e.g. health, political opinions, religious beliefs), and we ask that you do not include such data in your messages.

3. Why we collect and use your data

We use the personal data described above strictly for the following two purposes, and for no others:

  • To respond to you by email when you submit a message through the contact form. XR4Europe, as the entity managing project communications, is responsible for reviewing and answering messages sent through the Website.
  • To send you the project newsletter via Mailchimp, if you have subscribed to it, and to manage your subscription (including processing unsubscribe requests).

We do not use your personal data for any other purpose, such as advertising, profiling, or automated decision-making, and we do not use contact-form submissions to add you to the newsletter, or vice versa, unless you separately opt in to each.

4. Legal basis for processing

We rely on the following legal bases under Article 6 GDPR:

  • Legitimate interests (Art. 6(1)(f) GDPR): to process and respond to messages submitted through the contact form, where this is necessary to handle your enquiry and does not override your rights and interests.
  • Consent (Art. 6(1)(a) GDPR): to send you the newsletter via Mailchimp. You may withdraw this consent at any time (see Section 7).

5. Sharing of your data with third parties

We do not sell, rent, or trade your personal data. We do not share your data with third parties, except in the following limited cases:

  • Mailchimp: if you subscribe to the newsletter, your email address (and name, where provided) is shared with Mailchimp (operated by The Rocket Science Group LLC / Intuit Inc.), the platform we use to manage and send the newsletter. Should the project 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: data submitted through the contact form or newsletter sign-up 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, access to contact-form and newsletter data is restricted to the personnel responsible for managing VIVE’s communications and the Website.

We may also disclose personal data where required by law, regulation, or a valid legal request from a public authority.

6. Data retention

We retain your personal data only for as long as necessary for the two purposes described in Section 3, and for no longer:

  • Contact form messages and any related correspondence are retained only for as long as necessary to handle and resolve your enquiry, after which they are deleted.
  • Newsletter data (your email address, and name where provided) is retained for as long as you remain subscribed. If you unsubscribe, your data is removed from Mailchimp, save for a minimal record of your consent history where required to demonstrate compliance.

We do not retain contact-form or newsletter data for any purpose beyond these two uses, and we do not build a combined profile of Website visitors.

7. 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’);
  • 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 subscription, 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 [Insert VIVE project contact email].

8. 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.

9. 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.

10. Children's privacy

The Website is 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.

11. 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.

12. 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, on behalf of the VIVE project
Avenue des Arts 56, 1000 Brussels, Belgium
contact@xr4europe.eu

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