This Privacy Policy ("Policy") describes how ORamaVR SA ("ORamaVR", "Company", "we", "us", or "our") collects, uses, transfers, discloses, and protects Personal Data through the ORamaVR products and services (the "Services"), including:
the corporate website and information pages at oramavr.com (the "Website");
the customer portal and Org-Admin Portal at portal.oramavr.com;
the VTC Platform (Virtual Training Center) and components including the SIM Library (comprising both ORamaVR-Owned SIMs and Publisher-Owned SIMs distributed under Publisher Agreement OVR-PUB-001), Partner SIMs, JARIA (Just Another Remarkably Intelligent Assistant — ORamaVR's AI virtual assistant), and OMEN (generative co-pilot for authoring tasks);
ORamaVR Creator (Solo and Pro tiers) and the ORamaVR Custom SIM Service delivery channel;
support, marketing, sales, and forum touchpoints.
This Policy applies to all natural persons whose Personal Data ORamaVR processes in connection with the Services, including Website visitors, prospects, account holders, End Users (Org Admin, Supervisor, Trainee), Authorised Channel Partner contacts, and other professional contacts.
This Policy is supplemented by: the VTC End Customer Terms (Exhibit B) and the Acceptable Use Policy; the Data Processing Agreement (Exhibit C); the JARIA Terms of Use and the JARIA Addendum (OVR-ADD-JAR-001); and the ORamaVR Cookie Policy. In the event of conflict between this Policy and any of the above on a matter within the scope of that document, the relevant document prevails.
The controller responsible for the Personal Data described in this Policy is:
ORamaVR SA
34 route de la Galaise, c/o FONGIT, CH-1228 Plan-les-Ouates, Geneva, Switzerland
Commercial register number CHE-478.871.980
For Personal Data that ORamaVR processes on behalf of an End Customer in the course of providing the VTC Platform (the Article 28 GDPR processing), the End Customer is the controller and ORamaVR is the processor; that processing is governed by the Data Processing Agreement (Exhibit C).
"GDPR" means Regulation (EU) 2016/679.
"Patient-Identifiable Data" has the meaning given in Exhibit B §2. Patient-Identifiable Data is prohibited on the VTC Platform under Exhibit B §4.2(b).
"Personal Data" means any information relating to an identified or identifiable natural person, within the meaning of Article 4(1) GDPR and Article 5(a) revFADP.
"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data, within the meaning of Article 4(12) GDPR.
"Primary Region" means the geographic region within the EEA or Switzerland in which ORamaVR hosts and processes Personal Data by default, as identified in Exhibit C Annex 1.
"revFADP" means the Swiss Federal Act on Data Protection of 25 September 2020.
"Sub-processor List URL" means oramavr.com/legal/sub-processors — the authoritative current list of sub-processors engaged by ORamaVR for Article 28 processing, maintained as the Sub-Processor Register (OVR-POL-008).
We collect Personal Data you knowingly provide, including: account information (name, email address, country, role/title, organisation name); account credentials (username, password stored as one-way hash); internal account identifiers; correspondence content (support, sales, forms, surveys, feedback); and where you use single sign-on, the authentication token and associated email address.
Lawful bases: performance of a contract (Art. 6(1)(b) GDPR); legitimate interests in operating, securing, and improving the Services (Art. 6(1)(f)); your consent for optional data you provide (Art. 6(1)(a)).
When you use the Services, we collect VTC Platform usage metadata, training-session analytics (completion time, scores, session counts, interactions), JARIA interactions (where JARIA is available and the End User has accepted the JARIA Terms of Use), and telemetry (feature-usage counters, performance counters, error logs).
Lawful bases: performance of a contract (Art. 6(1)(b)) for purposes directly required to deliver the Service; legitimate interests (Art. 6(1)(f)) for security operations, abuse prevention, and aggregated product improvement.
Publisher analytics. Where End Users access Publisher-Owned SIMs, ORamaVR derives anonymised, aggregated analytics and shares them with the relevant Publisher in quarterly usage reports (Publisher Agreement OVR-PUB-001 §11.2 and Exhibit B §11.3A). Minimum aggregation threshold: five distinct End Customer organisations. No Personal Data is shared with Publishers. Lawful basis: legitimate interests (Art. 6(1)(f)).
When you access the Website, Org-Admin Portal, customer portal, or support forum, we may automatically collect device and browser data, network data (IP address, inferred country/region), and access patterns (pages visited, referrer). Cookies are described in the ORamaVR Cookie Policy (oramavr.com/legal/cookie-policy).
Lawful basis: legitimate interests (Art. 6(1)(f)) for site operation, security, and abuse prevention; consent (Art. 6(1)(a)) for cookies that require consent.
When ORamaVR processes Personal Data on behalf of an End Customer in the course of providing the VTC Platform, ORamaVR acts as Processor within the meaning of Article 4(8) GDPR and Article 28. That processing is governed by the Data Processing Agreement (Exhibit C). This Policy does not apply to ORamaVR's processing under Exhibit C as Processor.
Use of JARIA may involve processing of the End User's Prompts, JARIA's Outputs, and associated metadata. AI-specific processing through JARIA is out of scope of Exhibit C (per Exhibit C §1.3) and is governed by the JARIA Terms of Use (OVR-POL-005) and the JARIA Addendum (OVR-ADD-JAR-001), read together with this Policy.
ORamaVR sends marketing communications on the following basis:
Individuals in their personal capacity (B2C): opt-in consent (Art. 6(1)(a) GDPR). We will not send marketing communications without prior consent.
B2B professional contacts: legitimate interests (Art. 6(1)(f) GDPR), with a clear opt-out at every contact point. Receiving professional marketing communications as a business contact is within the reasonable expectations of the commercial relationship.
You may unsubscribe at any time using the unsubscribe link in any marketing email or by writing to dpo@oramavr.com. We do not sell Personal Data to third parties for advertising or marketing purposes. We do not display advertising on the VTC Platform.
We engage sub-processors to provide infrastructure, support, and operational services. The current list of sub-processors authorised for Article 28 GDPR processing is maintained in the Sub-Processor Register (OVR-POL-008) and published at the Sub-processor List URL: oramavr.com/legal/sub-processors. Sub-processor changes are subject to the 30-day notice mechanic in Exhibit C §5.5.
Where you reach the Services through an Authorised Channel Partner (under the Master Distribution Agreement), the Partner may process limited Personal Data (for example, Org Admin contact data) for its own commercial purposes and limited Org-Admin Portal activities. This dual role is described at Exhibit C §5.6.
Where End Users access Publisher-Owned SIMs through the VTC Platform, ORamaVR shares anonymised, aggregated analytics with the relevant Publisher in quarterly usage reports as described in §3.2 above. No Personal Data is shared with Publishers. Publishers are not sub-processors. The relationship is governed by Publisher Agreement OVR-PUB-001.
Within the End Customer's Client Tenant, certain Personal Data of an End User (username, role, training progress, Sub-Tenant assignment) is visible to other End Users in their assigned roles. The visibility model is configured by the End Customer's Org Admin and is described in Exhibit B §3.
We may disclose Personal Data where reasonably necessary to: (a) comply with a court order, lawful regulatory request, or other legal obligation; (b) enforce our agreements; (c) protect the rights, safety, or security of ORamaVR, End Customers, End Users, or the public; (d) detect, prevent, or address fraud, security incidents, or technical issues.
In the event of a merger, acquisition, reorganisation, asset sale, or similar transaction, Personal Data may be transferred to the acquiring party and will remain subject to this Policy or a successor policy providing an equivalent level of protection.
Personal Data described in this Policy is hosted and processed by default within the European Economic Area or Switzerland, in the Primary Region: Azure West Europe (Amsterdam, Netherlands).
Where ORamaVR transfers Personal Data outside the EEA or Switzerland, ORamaVR ensures an appropriate safeguard under Articles 44 to 49 GDPR is in place. Safeguards used include: EU-Switzerland adequacy decision; 2021 Standard Contractual Clauses, Module Two (for EEA-to-third-country transfers); Swiss FDPIC supplemental clauses (where the transfer is also subject to the revFADP); and UK transfers addressed by a separate addendum on a per-customer basis.
The current cross-border transfers, and the transfer mechanisms applied, are documented in Exhibit C Annex 4 (in respect of the JARIA transfers) and, in respect of all sub-processors, in the Sub-Processor Register (OVR-POL-008), published at the Sub-processor List URL; this Policy does not restate the sub-processor list. JARIA LLM inference and OMEN image generation are performed via ORamaVR’s managed sub-processors identified in the Sub-Processor Register (OVR-POL-008); JARIA speech-to-text and text-to-speech are processed by Microsoft Azure Speech (East US region; origin Azure West Europe, Amsterdam). Each managed transfer is governed by the 2021 EU Standard Contractual Clauses (Module 2), together with the UK Addendum and the Swiss FDPIC supplemental clauses where the UK or Swiss regimes respectively apply; the EU-US Data Privacy Framework applies as an additional safeguard in respect of any DPF-certified recipient. OMEN text and content authoring operates on a bring-your-own-key model: prompts are routed to the customer’s own third-party account under the customer’s own API key and agreement with that provider; ORamaVR does not process or transfer such data, and that provider is not an ORamaVR sub-processor. ORamaVR’s AI-training posture is set out in the JARIA Terms of Use (OVR-POL-005) §5.3: by default, customer content is not used to train or fine-tune any AI model.
We have implemented appropriate legal, organisational, technical, and administrative security measures designed to protect Personal Data from accidental loss and from unauthorised access, alteration, or disclosure. The technical and organisational measures are set out in Annex 2 of Exhibit C, and include: encryption in transit (TLS 1.2+) and at rest; role-based access control with MFA; logical isolation of Client Tenant data; access logging; daily backups + weekly archives; and annual third-party penetration testing.
We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected. The principal retention periods are:
| Category | Retention period |
| Active accounts | Duration of the subscription or Creator Solo eligibility. |
| Inactive accounts | 24 months from last login, after which the account is deactivated and Personal Data is deleted or anonymised. |
| Training-session analytics (End Customer's Client Tenant) | As specified in the End Customer's instructions under Exhibit C; on termination returned or deleted per Exhibit C §9. Default: 12 months after subscription end if no End Customer instruction is given. |
| Support correspondence | 36 months from closure of the support case. |
| Telemetry (identifiable) | 12 months from collection, subject to extension for active security investigations. |
| Anonymised aggregates | Indefinite. |
| Marketing engagement records | 24 months from last engagement. |
| Forum / community posts | Duration of account + 24 months. |
| VTC session records | Customer-defined; default 12 months after subscription end. |
| Marketing-communications consent records | Duration of consent plus 12 months following withdrawal. |
| Personal Data subject to legal hold | For the duration of the legal hold or active dispute. |
Subject to the conditions set out in the GDPR, the revFADP, and other applicable data protection law, you have the following rights in respect of Personal Data we hold about you as Controller: right of access (Art. 15); right to rectification (Art. 16); right to erasure (Art. 17); right to restriction of processing (Art. 18); right to object (Art. 21); right to data portability (Art. 20); right to withdraw consent (Art. 7(3)); and right to lodge a complaint (Art. 77).
Where ORamaVR processes Personal Data as Processor on behalf of an End Customer, Data Subjects should direct rights requests to the End Customer in the first instance. ORamaVR will assist the End Customer in accordance with Exhibit C §5.7.
Data Protection Officer: dpo@oramavr.com
General contact: info@oramavr.com
Postal: ORamaVR SA, 34 route de la Galaise, c/o FONGIT, CH-1228 Plan-les-Ouates, Geneva, Switzerland
You may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch, or with the data protection supervisory authority of your country of habitual residence.
The Services are not directed at, and are not intended for use by, minors. Account holders must be at least eighteen (18) years of age. The Educational Tier may be used by accredited academic institutions for enrolled students; the institution is responsible for obtaining any necessary consents in its capacity as controller under Exhibit C.
The Services may include links to third-party websites. Those websites operate under their own privacy policies; ORamaVR does not accept responsibility for them.
ORamaVR may update this Policy from time to time. Where a change is material (change in lawful basis, cross-border transfer mechanism, new category of Personal Data, or new category of recipient), we will notify affected Data Subjects through reasonable means at least thirty (30) days before the change takes effect. This Policy is amended in accordance with the Standard-Form Document Amendments mechanism in the relevant Principal Agreement (the Master Distribution Agreement §15.6 (or the equivalent in the applicable Principal Agreement)).
This Policy is governed by the laws of Switzerland, without prejudice to any mandatory provisions of EU data protection law (including the GDPR) that apply by virtue of the Data Subject's residence in the EEA or by other operation of law.
Where the GDPR applies to processing described in this Policy, ORamaVR maintains Personal Data in accordance with the principles of the GDPR. Where the revFADP applies, references in this Policy to the GDPR shall be read as references also to the corresponding revFADP provisions; references to supervisory authorities shall be read as including the FDPIC.