Last updated: 06/05/2026
A. About usNautilus Experiencias Digitales, S.L. (hereinafter «NAUTILUS», «we», «us» or «our») is the developer of the TierraXR platform and its associated virtual reality applications, including: TIERRAXR, VIRTUAL SMART MOBILITY, TIERRAXR Content Creator, OHS Automotive, Reciclaje automoción, OHS Welding, FP English, Simulador Virtual PLC, TierraXR PRL Aero, TierraXR Welding and InmersIA (hereinafter referred to as «Apps»).
Depending on the context, NAUTILUS acts either as a data controller (when collecting data through its own website) or as a data processor on behalf of the educational institution that contracts the TierraXR platform (for student data processed through the Apps). This privacy policy covers NAUTILUS’s role as a data processor in relation to the Apps.
The full privacy policy covering both our website and the platform is available at: tierraxr.com/politica-de-privacidad
The data controller for personal data of students («Users») processed through the Apps is the educational institution or company («Client») that has contracted the TierraXR platform services. NAUTILUS acts as a data processor on behalf of the Client, in accordance with the Data Processing Agreement (DPA) annexed to the TierraXR General Terms and Conditions.
If you wish to exercise your data protection rights as a User, you should contact your educational institution directly. If your institution does not respond, you may contact NAUTILUS at info@tierraxr.com for guidance.
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Username, session ID | User identification and platform access | Your training contract (Art. 6.1.b GDPR) | Duration of Client contract |
| Scores, times, completed exercises | Tracking and assessment of training activities | Your training contract (Art. 6.1.b GDPR) | Duration of Client contract |
| Voice (real-time processing, not stored) | Pronunciation assessment and immediate feedback during exercises | Your training contract (Art. 6.1.b GDPR) | Session only (not stored) |
| Voice (stored recording) | Review by your teacher and tracking your learning progress over time | Your explicit consent (Art. 6.1.a GDPR) | Maximum 1 year from recording |
| Transcriptions and derived metrics | Linguistic analysis and performance assessment | Your training contract (Art. 6.1.b GDPR) | Duration of Client contract |
About voice recordings
During exercises that involve voice (pronunciation, conversation, simulated interviews), your voice is processed in real time to generate immediate feedback. This processing is necessary for the educational service and does not require additional consent. Your voice data is processed transiently by transcription, analysis and evaluation services and is not stored beyond the session.
If you choose to save an exercise, you will be asked for explicit consent to store the voice recording. Without this consent, the exercise is saved with its results (scores, transcription) but without the audio recording. You can revoke your consent at any time through your educational institution.
| Provider | Service | Data processed | Location |
|---|---|---|---|
| Google Cloud Platform | Platform hosting and storage | Activity data, voice, transcriptions | EU (europe-west1) |
| Deepgram | Speech-to-text transcription | Voice audio | USA |
| OpenAI | AI assistants and language processing | Voice, transcriptions, interactions | USA |
| Microsoft Azure | Text-to-speech synthesis | Text required to generate synthetic speech | EU (West Europe) |
| Groq | Third-party large language model inference, including Llama 4 Maverick, for automated exercise evaluation, conversational feedback and language processing | Transcriptions, answers, user interactions and exercise context | USA |
| Pinecone | Intelligent content search (RAG) | Derived data, including embeddings and indexed content | USA |
| LiveKit | Live streaming sessions | Real-time audio/video, not stored by NAUTILUS for this purpose | EU / USA |
Transfers of personal data to providers located outside the European Economic Area are carried out under appropriate safeguards, including the EU-US Data Privacy Framework where applicable, Standard Contractual Clauses adopted by the European Commission, and/or other valid transfer mechanisms under GDPR.
NAUTILUS configures its AI service providers so that student data is not used for training, improving, or developing their models, unless expressly authorized by the Client or User where required by applicable law.
Groq and the Llama 4 Maverick model are used only to provide the core AI functionality requested by the User, such as automated exercise evaluation, conversational feedback, and language-related processing. NAUTILUS does not sell, rent, or share student data for advertising, tracking, profiling, or unrelated purposes.
If you access our Apps through the Meta Quest Store, Meta may collect personal information from you in accordance with their terms:
NAUTILUS implements technical and organizational measures to protect personal data, including encryption of communications (TLS), encryption at rest for voice recordings, role-based access controls, and audit logging.
The platform uses artificial intelligence systems to generate automated evaluations. These are indicative only and subject to teacher supervision. No legally significant decisions are made solely based on automated processing.
Some Apps use third-party artificial intelligence and large language model services to provide educational features such as automated exercise evaluation, conversational practice, feedback generation, pronunciation or language analysis, and interactive learning support.
For this purpose, NAUTILUS may send the minimum necessary data to the relevant AI service provider, such as the User’s transcription, written answer, exercise context, scoring data, or interaction history within the exercise.
For the LLM provider, NAUTILUS uses Llama 4 Maverick served through Groq. Groq is used only as a service provider/sub-processor to support the Apps’ core AI functionality.
NAUTILUS does not permit student data processed through these AI services to be used for advertising, profiling, unrelated purposes, or model training/improvement, unless expressly authorized by the Client or User where required by applicable law.
AI-generated evaluations and feedback are intended to support the educational process and are indicative only. They may be reviewed, corrected, or overridden by teachers or authorized staff of the Client.
| Right | Description |
|---|---|
| Access (Art. 15) | Obtain confirmation and access to your data |
| Rectification (Art. 16) | Correct inaccurate data |
| Erasure (Art. 17) | Request deletion |
| Restriction (Art. 18) | Limit processing |
| Portability (Art. 20) | Receive your data in structured format |
| Objection (Art. 21) | Object to processing |
| Withdrawal (Art. 7.3) | Withdraw consent |
Requests can be made through your educational institution or by contacting info@tierraxr.com.
You may lodge a complaint with the Spanish Data Protection Authority: www.aepd.es
Users under 14 require parental consent. Educational institutions must verify age and obtain consent where necessary.
We may update this policy from time to time. Changes will be published on our website.
Nautilus Experiencias Digitales, S.L.
Paseo Santxiki 2, L3.3, Mutilva Alta, 31192 (Navarra), Spain
Email: info@tierraxr.com
The full privacy policy in Spanish is available at: tierraxr.com/politica-de-privacidad
Esta empresa ha recibido el apoyo del "Programa NEOTEC mujeres emprendedoras 2022".
Esta empresa ha recibido el apoyo de las "Ayudas para proyectos de desarrollo experimental e innovación de procesos a través de tecnologías asociadas al Metaverso y Web3". Año 2022.
