Data Use Statement

APPLICABLE TO USERS OF VARJO HEADSETS IN THE EU 

This data use statement was updated most recently on 11.9.2025.

When you use our software and hardware with an active Varjo account and internet connection, we collect technical and usage data to enhance our products and services (“Device Data”). Where Device Data consists of raw data or pre-processed data, Device Data shall be subject to Regulation (EU) 2023/2854 (“Data Act”). Where Device Data consists of personal data, as defined in EU’s General Data Protection Regulation 2016/679, our Privacy Policy and any applicable legislation on privacy shall be complied with and shall have priority over the rules of collection and usage of Device Data described herein. This includes comprehensive system information about your computer hardware (processors, graphics cards, memory, motherboard specifications, operating system), details about your Varjo headset and any connected peripherals (device models, serial numbers, controllers, tracking devices), and information about how you use our software (applications launched, session durations, API preferences, display settings, tracking configurations, audio preferences, and other software settings). Device Data may also include diagnostic data such as error messages, performance metrics, and technical notifications to help us identify and resolve issues. 

Frequency of Device Data collection depends on the type of data. Collection can be  continuous. Certain types of Device Data shall be collected and retained as long as, and only as long as, Varjo deems the type of Device Data to be useful for the purposes of use listed above. Device Data shall be stored at third party service providers’ servers in EU.

You can control Device Data collection through your account settings, and enterprise users with secure packages may have collection disabled entirely. 

Where Device Data consists of data that is subject to Data Act, you can request access for yourself or for a third party by sending an access request to Varjo at dataact@varjo.com. Any data access requests are subject to Varjo’s Privacy Policy and applicable legislation. Data access by third parties on the basis of the access request by you is subject to terms and conditions between Varjo and such 
third Party. 

You agree not to use Device Data which you have accessed to develop a product that competes with Varjo’s products or services, nor share the Device Data with a third party with that intent; use Device Data to derive insights about the economic situation, assets and production methods of Varjo; use coercive means to obtain access to Device Data or, for that purpose, abuse gaps in the Varjo’s technical infrastructure which is designed to protect the Device Data; share Device Data with a third party considered as a gatekeeper under article 3 of Regulation (EU) 2022/1925; use Device Data for 
any purposes that infringe EU law or applicable national law.

We use Device Data for product development and improvement, technical support and troubleshooting, quality assurance testing, service optimization, and where you have provided a 
separate consent, for targeted marketing communications. All data is transmitted securely and processed in accordance with applicable privacy laws and our privacy policy. Varjo shall not disclose Device Data to third parties unless requested by you.

Where Device Data is subject to Data Act, you may lodge a complaint with the national competent authority designated in accordance with Article 37 of the Data Act.