Privacy Policy for Simutomy Medtech Pvt. Ltd.

Last Updated: 10 August 2026

At Simutomy Medtech Pvt. Ltd. (“Simutomy”, “we”, “us”, or “our”), accessible from www.simutomy.com, we respect the privacy of our users and are committed to protecting the information entrusted to us.

This Privacy Policy explains what information we collect, how we use it, and how we protect it when you interact with our website, applications, products and services.

This Privacy Policy specifically covers:

1. The Simutomy website and online services;

2. VisceR, our virtual reality medical and surgical simulation application distributed through the Meta Quest Store;

3. Our separately offered institutional, B2B and B2G products and applications; and

4. Communications and interactions with Simutomy, including enquiries, demonstrations, customer support and business relationships.

Because different Simutomy products operate differently, the type of information collected may vary depending on the product or service you use. In particular, the consumer version of VisceR distributed through the Meta Quest Store operates differently from our B2B/B2G institutional applications, as described below.

If you have questions about this Privacy Policy or our privacy practices, please contact us using the contact information provided at the end of this Policy.

1. Consent

By accessing or using our website, applications or services, you acknowledge that you have read and understood this Privacy Policy.

Where applicable, we will obtain consent or rely on another lawful basis for processing personal data as required under applicable law.

For applications distributed through third-party platforms such as the Meta Quest Store, your use of those platforms is also subject to the privacy policies and terms of those respective platforms.

2. Information We Collect

The information we collect depends on how you interact with Simutomy.

2.1 Information Provided Directly to Simutomy

If you contact us directly, request information, request a demonstration, communicate with our team, or otherwise interact with us, we may receive information such as:

• Name;

• Email address;

• Telephone number;

• Organization, institution or company name;

• Job title or professional designation;

• Address;

• Contents of messages or enquiries;

• Attachments or documents you choose to provide; and

• Any other information you voluntarily provide to us.

We use this information to respond to enquiries, provide services, communicate with customers and business partners, provide support, and conduct legitimate business activities.

2.2 Website Information

When you visit our website, certain technical information may be automatically collected by our hosting provider, analytics services or other technical infrastructure.

This may include:

• IP address;

• Browser type and version;

• Device type;

• Operating system;

• Internet service provider;

• Date and time of access;

• Referring and exit pages;

• Pages viewed;

• General usage information; and

• Other technical information necessary for operating, securing and improving the website.

3. VisceR – Meta Quest Store Application

3.1 About VisceR

VisceR is Simutomy’s virtual reality-based medical and surgical simulation application designed to help users practice and develop procedural and clinical skills in a simulated environment.

Simutomy distributes certain versions of VisceR through the Meta Quest Store.

The version of VisceR distributed through the Meta Quest Store is a standalone, single-player application designed to operate without an internet connection after installation.

This version is different from Simutomy’s separately offered B2B and B2G institutional applications and deployments, which may contain additional functionality, institutional administration, user management, analytics, networking or other features depending on the agreement and deployment.

4. Personal Information in the Meta Store Version of VisceR

The Meta Store version of VisceR does not separately require users to create a Simutomy account.

The application does not independently ask users to provide information such as:

• Name;

• Email address;

• Telephone number;

• Postal address;

• Date of birth;

• Professional information; or

• Payment information.

The purchase and installation of VisceR through the Meta Quest Store are handled through the Meta platform.

Simutomy does not independently process payment information for purchases made through the Meta Quest Store.

Information that Meta collects in connection with your Meta account, Meta Quest device, purchase, download, installation or use of the Meta platform is governed by Meta’s applicable terms and privacy policies.

Users should review Meta’s privacy documentation for information regarding data that Meta itself may collect or process.

5. Offline Operation of VisceR

The Meta Store version of VisceR is designed to operate without an internet connection.

The application does not require an online connection for its core single-player functionality.

Accordingly, the application does not continuously transmit user activity, practice sessions or performance information to Simutomy’s online servers.

The application does not use an online database to store individual user scores for the Meta Store version.

6. Scores and Practice Data

VisceR may generate information relating to a user’s performance within the simulation, including scores, completion information, performance measurements, errors or other results generated during a practice session.

For the Meta Store version of VisceR, such information is stored locally on the user’s Meta Quest device.

Such locally stored information is not transmitted by VisceR to Simutomy’s online databases or servers as part of the normal operation of the application.

Simutomy therefore does not maintain an online account-based record of individual users’ VisceR scores for this version of the application.

If a user uninstalls the application, resets the device, deletes application data, or otherwise removes locally stored application information, locally stored scores or progress may be lost.

Users should refer to Meta’s device and operating-system functionality for information concerning device-level backups, storage and data management.

7. No Subscription for the Meta Store Version

The Meta Store version of VisceR is offered as a non-subscription application.

Simutomy does not require users to maintain a recurring subscription in order to use this version of VisceR.

Purchases made through the Meta Quest Store are subject to the applicable purchase, payment, refund and other terms of the Meta platform.

8. No Separate Online Database for Meta Store VisceR

For clarity, the Meta Store version of VisceR is not designed as an online SaaS platform.

The application does not require users to create a Simutomy online account, and individual practice scores are not routinely uploaded to or stored in Simutomy’s online databases.

Simutomy does not use the Meta Store version of VisceR to create an online profile of an individual user’s medical-training activity.

This does not limit information that may be collected independently by Meta or other platform providers in connection with the Meta Quest platform.

9. B2B and B2G Simutomy Applications

The privacy practices described above for the Meta Store version of VisceR do not necessarily apply to Simutomy’s B2B, B2G, institutional or customized applications.

Simutomy separately develops and deploys applications and simulation solutions for medical colleges, universities, hospitals, healthcare organizations and other institutional customers.

Depending on the product, deployment and contractual arrangement, these solutions may include functionality such as:

• User accounts and authentication;

• Institutional user management;

• Online databases;

• Practice-session records;

• Performance and assessment data;

• Scorecards and analytics;

• Leaderboards;

• Multiplayer functionality;

• Team-based practice;

• Administrative dashboards;

• Cloud storage;

• Institutional reporting; and

• Other connected or customized features.

Where such functionality is provided, the applicable data processing practices may differ from those described for the standalone Meta Store version of VisceR.

Institutional customers may also determine how their users are registered and managed and may have their own privacy policies, contractual obligations and data-processing requirements.

Where applicable, Simutomy may process information on behalf of an institutional customer in accordance with the relevant agreement and applicable law.

10. How We Use Information

We may use information collected through our website, communications and applicable services to:

• Provide, operate and maintain our website and services;

• Respond to enquiries and customer-support requests;

• Provide demonstrations and product information;

• Manage business relationships;

• Improve and develop our products and services;

• Understand and analyze website usage;

• Develop new products, services, features and functionality;

• Communicate with customers, users and business partners;

• Provide updates and service-related information;

• Send marketing or promotional communications where permitted by applicable law;

• Maintain security and prevent misuse, fraud or unauthorized activity; and

• Comply with applicable legal and regulatory requirements.

For the standalone Meta Store version of VisceR, the application itself does not require the collection of personal information for normal single-player operation.

11. Log Files

Simutomy may use standard log files and technical logging for its website and online services.

Information may include IP addresses, browser type, Internet Service Provider, date and time stamps, referring and exit pages, and other technical information.

This information may be used for:

• Website administration;

• Security;

• Troubleshooting;

• Analytics;

• Understanding usage trends; and

• Improving our services.

The availability and nature of such logging may vary depending on the service being used.

The standalone Meta Store version of VisceR does not use Simutomy’s online databases to continuously record individual user activity or scores.

12. Cookies and Web Technologies

Like many websites, Simutomy’s website may use cookies and similar technologies.

Cookies may be used to:

• Remember preferences;

• Understand website usage;

• Improve website functionality;

• Analyze traffic; and

• Improve user experience.

The use of cookies may vary depending on the third-party services integrated into our website.

The standalone Meta Store version of VisceR is different from our website and does not rely on website cookies for its normal operation.

13. Third-Party Services and Platforms

Simutomy may use third-party service providers to support its website, applications and business operations.

Depending on the relevant service, these providers may include hosting, analytics, communication, cloud infrastructure, authentication, payment or other technology providers.

Such providers may process information on our behalf where necessary to provide their services.

The standalone Meta Store version of VisceR is distributed through the Meta Quest Store. Meta operates the store and associated platform services independently of Simutomy.

Information collected directly by Meta through the Meta Quest platform, including information relating to Meta accounts, purchases, devices or platform usage, is governed by Meta’s applicable privacy policies and terms.

Simutomy does not control the information independently collected by Meta.

14. Third-Party Privacy Policies

Our Privacy Policy does not apply to third-party websites, platforms or services that we do not control.

This includes platforms such as the Meta Quest Store and other third-party services that may be accessed through or used in connection with our products.

We encourage users to review the privacy policies of such third parties to understand how they collect, use and protect information.

15. Data Security

Simutomy takes reasonable technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, loss or misuse.

However, no electronic transmission, storage system or internet-based service can be guaranteed to be completely secure.

For the standalone Meta Store version of VisceR, individual scores and practice information are stored locally on the user’s Meta Quest device rather than being routinely transmitted to Simutomy’s online databases.

Users are responsible for maintaining the security of their own devices and accounts.

16. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide our services, maintain business and legal records, resolve disputes, enforce agreements, or comply with applicable legal obligations.

Because the standalone Meta Store version of VisceR stores scores and practice information locally on the user’s device, Simutomy does not maintain an online repository of those individual scores for that version.

17. Your Privacy Rights

Depending on your location and applicable law, you may have rights concerning your personal information, including rights to:

• Request access to personal information we hold about you;

• Request correction of inaccurate or incomplete information;

• Request deletion of personal information, subject to applicable legal requirements;

• Request restriction of processing in circumstances permitted by law;

• Object to certain processing;

• Request portability of personal information where applicable; and

• Withdraw consent where processing is based on consent.

To exercise applicable rights, please contact us using the contact details provided below.

We may need to verify your identity before processing certain requests.

18. GDPR Data Protection Rights

Where the General Data Protection Regulation (“GDPR”) applies to our processing of your personal data, you may have rights including:

• The right to access;

• The right to rectification;

• The right to erasure;

• The right to restrict processing;

• The right to object to processing;

• The right to data portability; and

• The right to withdraw consent where applicable.

These rights are subject to applicable legal conditions and exceptions.

We will respond to valid requests within the period required by applicable law.

19. California Privacy Rights

Where applicable, California privacy laws may provide California residents with additional rights concerning their personal information.

These may include rights relating to access, deletion, correction, opting out of certain forms of data sharing or sale, and other rights provided by applicable California law.

Simutomy does not sell personal information obtained through the standalone Meta Store version of VisceR.

California residents wishing to exercise applicable rights may contact us using the details below.

20. Children’s Information

Simutomy is committed to protecting children’s privacy.

Our website and services are not intentionally designed to collect personal information from children without appropriate authorization or legal basis.

Simutomy does not knowingly collect personal information from children under 13 through its website.

The Meta Store version of VisceR does not independently require users to submit personal information to Simutomy.

Because VisceR is distributed through the Meta Quest Store, age restrictions, parental controls and other requirements imposed by Meta may also apply.

Parents or guardians who believe that a child has provided personal information directly to Simutomy should contact us so that we can take appropriate action.

21. International Data Transfers

Simutomy is an India-based company and may use service providers located in India or other countries.

Where personal information is transferred internationally, we will take reasonable steps to ensure that such transfers are conducted in accordance with applicable data-protection laws.

For the standalone Meta Store version of VisceR, Simutomy does not routinely transfer individual practice scores or performance information to an online database.

22. Data Protection Under Indian Law

Simutomy recognizes its obligations under applicable Indian data-protection and privacy laws, including the Digital Personal Data Protection Act, 2023, and applicable rules and regulations as and when effective and applicable to our processing activities.

Where applicable, Simutomy will process personal data in accordance with the requirements of applicable Indian law.

The specific rights and mechanisms available to an individual may depend on the nature of the processing and the applicable law.

23. Changes to This Privacy Policy

Simutomy may update this Privacy Policy from time to time to reflect changes in:

• Our products and services;

• Our data-processing practices;

• Applicable laws and regulations;

• Third-party services; or

• Our business operations.

Any updated version will be published on this page with an updated “Last Updated” date.

We encourage users to periodically review this Privacy Policy.

24. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise applicable privacy rights, please contact:

Simutomy Medtech Pvt. Ltd.

Website: www.simutomy.com

Email: [Insert Privacy/Support Email Address]

Address: [Insert Registered Office Address]

25. Important Distinction Between VisceR Versions

For clarity, Simutomy currently operates different types of VisceR and simulation solutions.

Meta Quest Store Version

The standalone Meta Store version:

• Is primarily intended for individual users;

• Is distributed through the Meta Quest Store;

• Is single-player;

• Operates without an internet connection;

• Does not require a separate Simutomy account;

• Does not have a subscription;

• Stores scores and practice information locally on the Meta Quest device;

• Does not routinely transfer individual scores to Simutomy’s online databases; and

• Does not independently require users to provide personal information to Simutomy.

B2B / B2G / Institutional Versions

Simutomy’s institutional products may contain substantially different functionality, including online accounts, institutional administration, cloud databases, analytics, multiplayer functionality, user management and other connected services.

The privacy practices applicable to those products may therefore differ and may be governed by additional agreements, institutional policies, notices or data-processing arrangements.

Users of institutional versions should refer to the privacy notices and terms applicable to the particular product and deployment.

This Privacy Policy was last updated on 10 August 2026.