Privacy Policy

Up360 — InReachXR Privacy Policy

Last Updated: August 20, 2026

Up360 Inc. (“Up360”, “us”, “we”, “our”), is committed to protecting your privacy. We own and operate InReachXR, our XR content management and distribution platform for capturing, authoring, and delivering real-life XR content across web, mobile, and VR headsets (“Platform”), through which we provide the Up360 solutions and offerings, as described on our website, https://up360.co/ (“Website” and together with Platform, the “Services”).

This privacy policy (“Privacy Policy”) describes how we collect, store, use, and distribute your Personal Information when you use the Services. For the purposes of this Privacy Policy, "Personal Information" means any personally identifying information about an individual. Please read the following carefully to understand our practices regarding Personal Information of users of the Services (“User”, “you”, “your”).

We may change this Privacy Policy from time to time at our sole discretion. We encourage you to review this Privacy Policy each time you use the Services to see if the Privacy Policy have been changed, as indicated by the “Last Updated” date set out above. We may, at our sole discretion, highlight the fact that we made material changes by notifying you through the Platform or posting a notice on our Website. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective thirty (30) days from their posting on the Website. Up360 may require you to provide consent to the updated Privacy Policy before further use of the Services is permitted. If you do not agree to any such change(s), you shall stop using the Services. Otherwise, your continued use of the Services constitutes your acceptance of such change(s).

Consent. By using the Services, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be collected, used, or disclosed for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing of such Personal Information in a way that specifically identifies an individual. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using all or part of the Services.
Information You Provide Us. You may disclose information to us as follows:
By Using the Platform. When you use the Platform, the Personal Information we collect includes account registration information, such as your name, email address, phone number, and business address, as well as any other Personal Information you may provide to us while using the Platform.
By Submitting Information via the Platform. We collect any Personal Information you may choose to provide to us while using the Platform.
By Submitting Information via the Website. When you fill out the contact form on our Website, the Personal Information we collect includes your name, phone number, email address, organization, and any other information you choose to provide us in the “Message” box. We ask that you do not disclose sensitive Personal Information (including, without limitation, gender, height, weight, medical information, religion, and philosophical or political beliefs) in your contact form.
By Contacting us through our Social Media Accounts. We provide links to our social media accounts on our Website and you may choose to contact us via our social media accounts. Any Personal Information you submit to our social media accounts will be processed in accordance with this Privacy Policy, but please note that the applicable social media platform may have access to your Personal Information. Please consult the relevant social media platform’s privacy policy to see how they process your Personal Information.
Applying to work with us. If you would like to work with us and submit hiring materials to us, we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. If you submit hiring materials to us, we ask you to only include information relevant to the position you’re applying for, and your employment history and education (including, without limitation, certifications and/or degrees obtained, previous work experience, relevant awards, etc).
Information We Collect When You Use the Services. When you use the Services, Up360 may collect certain information through technologies such as cookies. A cookie is a technology feature that consists of a text file that is placed on your hard disk by a web server. We use cookies for authentication purposes. Please note that if you disable cookies, we will not be able to authenticate your Platform account and you will not be able to access the Platform.

We may also use cookies to compile aggregate statistics about usage of the Services, such as how long individuals spend on the Platform, and what parts or pages of the Website are viewed most often. This information is used to improve the content and operation of the Services. Any usage information we collect for these purposes is aggregated or de-identified, is not used to identify individual Users, is not used for third-party advertising, and is never sold.

How We Use Information We Collect. We use information we collect in the following ways:
To authenticate Users and provide access to the Platform;
To provide, maintain, improve, and enhance the Services;
To develop new Up360 products, features, and services;
To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you, where you have subscribed to receive them;
To find and prevent fraud, and respond to trust and safety issues that may arise;
For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide notice at the time the information is collected.
Who We Share Your Information With. We may share your Personal Information with third parties, such as our selected business partners, suppliers, sub-contractors, and affiliates, in the course of performing our contractual obligations. These third parties may include web hosting partners, IT service providers, and our affiliate company. If you access the Platform through an organization or institution (for example, your employer or school), that organization and its administrators may also access your account information and your course progress and completion records.

We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose.

In addition, we may disclose your Personal Information to third parties:

In connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or shares, including any due diligence exercise carried out in relation to the same, provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information;
If we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; or
If we believe in good faith that such disclosure is required by and in accordance with the law.

Our servers are located in Canada, and your Personal Information and the content you upload to the Platform are stored in Canada. In the limited cases where a third-party service provider processes Personal Information on our behalf outside of Canada, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

Third Parties. The Services may contain links to third-party websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to the collection, storage, use, and sharing of your information by such third parties.
Data Retention and Deletion. We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all of your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another User).
Access and Accuracy. You may access the Personal Information we hold about you to verify accuracy of your Personal Information, to have a general account of our uses of your Personal Information, and to correct your Personal Information as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another User). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate, and to respond to your in a timely manner.
Security. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as reasonably necessary to carry out the stated purposes we have communicated to you.
Children’s Privacy. The Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13 without the consent of a parent, guardian, or supervising organization. Where the Platform is used in an educational or training setting involving minors, the responsible organization or institution is responsible for obtaining any required consents. If you believe a child has provided us with Personal Information without such consent, please contact us using the information below and we will delete it.
Contact Us. If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Data Protection Officer per the information below:
Via email: Email us at john@up360.co using the subject line “Re Privacy Policy”.
Via mail: Mail us correspondence to 950 Queen Street West, Toronto, ON, M6J 1G8, Canada