Privacy Policy

01Data controller

Digital Toolbox GmbH, Friedrichstrasse 11, 74545 Michelfeld, Germany, is the controller responsible for the processing of personal data described in this policy.

For any privacy question or to exercise your rights, contact us at tobias@digitaltoolbox.gmbh.

02Scope

This policy applies to our corporate website (digitaltoolbox.gmbh) and to both of our product platforms:

• ToolboxVR — our immersive, device-agnostic 3D platform for training, onboarding, sales and events.
• GuidedGenius — our AI-supported, multilingual learning platform.

03Data we collect

Depending on how you interact with us, we may process the following categories of personal data:

• Contact & account data — name, email address, phone number, organisation and login credentials.
• Communication data — the content of enquiries, support requests and correspondence.
• Usage & device data — IP address, browser and device type, pages viewed and interaction logs, collected to operate and secure the services.
• Learning data (GuidedGenius) — questions you ask, prompts, progress and generated guidance, used to deliver and improve adaptive tutoring.
• Session data (ToolboxVR) — participation in immersive sessions and in-experience interactions where a training scenario records them.

04How we use your data and legal bases

We process personal data for the following purposes and on the following legal bases under Art. 6 GDPR:

• To provide and operate the website and products — performance of a contract (Art. 6(1)(b)).
• To respond to enquiries and provide support — pre-contractual steps and/or legitimate interest (Art. 6(1)(b), (f)).
• To secure, maintain and improve the services — legitimate interest (Art. 6(1)(f)).
• To send service or, where you have opted in, marketing communications — consent and/or legitimate interest (Art. 6(1)(a), (f)).
• To comply with legal obligations — Art. 6(1)(c).

05AI processing in GuidedGenius

GuidedGenius uses AI models to generate guided, step-by-step learning support. When you interact with the tutor, your inputs are processed to produce a response. We apply data-minimisation so that only what is needed to deliver guidance is processed, and we do not use your personal learning content to train third-party foundation models without a lawful basis.

GuidedGenius is designed to support understanding rather than to provide authoritative or professional advice; you remain responsible for verifying outputs before relying on them.

06Sharing and processors

We do not sell personal data. We share it only with service providers (processors) acting on our instructions under a data-processing agreement, including hosting, infrastructure, analytics and communication providers. Our production hosting is located in Frankfurt, Germany.

Digital Toolbox operates through a Germany–India model; members of our team in India may access data strictly to develop, operate and support the services, subject to appropriate safeguards.

07International transfers

Where personal data is transferred outside the European Economic Area — for example to our engineering team in India — we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses together with additional technical and organisational measures.

08Data retention

We keep personal data only as long as necessary for the purposes described here or as required by law. Contract and billing records are retained for statutory periods; account and usage data are deleted or anonymised when no longer needed.

09Your rights

Subject to the GDPR, you have the right to access, rectify, erase, restrict and port your personal data, and to object to certain processing. Where processing is based on consent, you may withdraw it at any time without affecting prior processing.

To exercise any right, contact tobias@digitaltoolbox.gmbh. You also have the right to lodge a complaint with a supervisory authority, such as the data-protection authority of Baden-Württemberg.

10Deleting your account and data

You can delete your account and its associated data directly in each product. This removes the personal data associated with that account, subject to any records we are required to keep by law.

If you need help, or would like us to action an erasure request on your behalf, contact tobias@digitaltoolbox.gmbh.

11Cookies and analytics

Our website uses strictly necessary cookies to function and, where you consent, analytics cookies to understand usage and improve the site. You can manage cookies through your browser settings and any cookie banner we provide.

12Children and education

Some of our work supports schools and vocational education. Where products are used by minors, they are deployed under the responsibility of the school or organisation acting as controller, and we process data as a processor on their documented instructions.

13Security

We apply appropriate technical and organisational measures — including encryption in transit, access controls and hosting in a GDPR-aligned environment — to protect personal data against unauthorised access, loss or misuse.

14Changes to this policy

We may update this policy to reflect changes in our services or legal requirements. The current version is always available on this page, with the effective date shown above.

15Contact

Questions about this policy or our data practices? Write to tobias@digitaltoolbox.gmbh or Digital Toolbox GmbH, Friedrichstrasse 11, 74545 Michelfeld, Germany.